Table of Contents
Information about this policy
The purpose of this policy is to explain when, why and how we process information related to you (“personal data”). It also contains important information about your legal rights. This policy does not intend to override the terms of any contract you have entered into with us or any of your rights under data protection rights.
Click a topic in the list below to learn more about each topic by following the different links. We have marked sections of the policy to help you navigate to the information that is most relevant to you.
1. Who is responsible for maintaining your personal data?
Company Name, Address, is primarily responsible for your personal data (your data controller). Data controller means the company that determines the means and purposes of processing personal data.
You should be aware that while we are generally responsible for maintaining your personal information, information may be stored in databases to which other companies have access. When accessing your personal information, all companies adhere to the standards set out in this Policy.
2. What personal data do we process?
We may process the following personal data about you:
- IP Address
- Location Data
- Website Usage
3. What do we use your personal data for and when do we process it?
Company Name collects information directly from you when you use our services or visit our websites.
We use your personal data to:
- Analyze information in our systems and databases in order to improve the way we conduct our business and operate our websites based on users’ preferences in order to provide better service and better user experience.
- Improve and target advertisements that you that you see on our website.
- To comply with our legal obligations or rights.
We will only process your personal data for the purposes set out in this section 3 and only if we are convinced that:
- you have given us your consent to use the data in this way, or
- our use of your personal data is necessary to support the ‘legitimate interests’ that we have as a company (for example, to improve our products or to perform analysis on our records) in a manner that is proportionate and respects your privacy.
4. Who do we share your personal information with?
We work with many third parties to help us manage our business and provide our services. These third parties may require access to your personal information from time to time:
- Service providers or data processors that process your personal data based on our instructions, such as cloud services.
- Where we are required to disclose a legal obligation or to protect our interests or safety.
5. International Data Transfers
International data transfers mean that personal data is transferred to a country outside the European Union.
As set out in Section 4 above, we may provide access to your personal information to third parties located outside the European Union.
We may also share your personal information when we receive a legal or regulatory requirement from a foreign law enforcement agency outside the European Union.
We will always take steps to ensure that international data transfers are carried out in a manner that protects your rights and interests. Information requests we receive from law enforcement or regulatory authorities are carefully reviewed before any personal information is disclosed.
You have the right to request more information from us about the security measures mentioned above.
6. How long do we keep your personal data?
We will retain your personal data for as long as is reasonably necessary for the purposes set out in Section 3 of this Policy.
We may retain your personal information for a specified period of time, for example to comply with legal, tax or accounting requirements.
We have a data retention policy for the data we entrust. If your personal data is no longer needed, we will ensure its secure solution or anonymisation.
7. What rights do you have?
You have different rights with regard to your personal data. See the table below for more information about each of these rights.
To exercise your rights, you can contact us by email at [email protected] or write to Company Name at the address specified in section 1 above.
Please note the following if you wish to exercise your rights:
You can ask us:
- To confirm whether we are processing your personal data.
- Give you a copy of this information.
- Provide you with more information about your personal information, such as what information we have, what we use it for, with whom we share it, whether we transfer it to countries outside the EU and how we protect it, how long we retain it, what rights you have, how you can file a complaint, where we collect your information and whether we have done automated decision-making or profiling unless this information has already been provided to you in this policy.
You can ask us to delete your personal data, but only:
- When they are no longer needed for the purposes for which they were collected; or
- If you have withdrawn your consent (if the processing was based on consent) or
- After successful exercise of the right of objection (see “Dispute” below) or
- They have been processed unlawfully; or
- To comply with a legal obligation.
We are under no obligation to comply with your request for deletion of your personal data if the processing of your personal data is necessary to:
- Comply with a legal obligation; or
- Assert, exercise or defend legal claims.
There are certain other circumstances in which we do not have to comply with your request for deletion, although these are the two most likely circumstances in which we would reject this request.
You can ask us to restrict (i.e. store, but do not use) your personal information, but only if:
- Their accuracy is disputed (see Correction) so that we can verify its accuracy; or
- The processing is unlawful, but you do not want the data to be deleted; or
- The personal data is no longer needed for the purposes for which it was collected, but we must continue to assert, exercise or defend legal claims; or
- You have exercised your right of objection and the examination of the primary grounds has not yet been completed.
We may continue to use your personal information following a request for restriction:
- If we have your consent or
- To assert, exercise or defend legal claims; or
- To protect the rights of another person or entity.
You may request us to provide you with your personal data in a structured, commonly used and machine-readable format or have your personal data transferred directly to another data controller, but only if:
- The processing is based on your consent or on the performance of a contract concluded with you, and
- Processing is carried out by automatic means.
You may object to the processing of your personal data based on the legal basis of our “legitimate interests” if you believe that your fundamental rights and freedoms are more important than our legitimate interests.
We have the opportunity to demonstrate that we have compelling legitimate interests that take precedence over your rights and freedoms.
International Data Transfers
You can ask us for a copy or reference to the safeguards under which your personal data is transferred to countries outside the European Economic Area. We may edit data transfer agreements or related documents for business sensitivity reasons (i.e. make certain information contained in those documents illegible).
You have the right to complain to the competent local supervisory authority about our processing of your personal data. We ask you to try to resolve issues with us first, although you are always entitled to contact your regulatory authority.