The Company is committed to safeguarding Users’ privacy by achieving the highest standards of privacy and security, as well as being transparent about how the Company uses and process Users’ data.
It is Users’ decision to provide the Company with their personal information. Users are not legally obligated to provide the Company with this information, but in order to provide Users with the Company’s services (the “Services“), the Company shall need access to the information detailed below.
COMPLIANCE WITH DATA PROTECTION LAW
Company acknowledges and undertakes to comply with the laws and regulations governing the processing of personal data, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and any other national applicable laws or regulations governing the processing of personal data in the framework of the Services.
Contact Point / EU Representative. Company acts as data controller and has appointed a contact point in the EU. The data contact officer and/or the EU Representative appointed by Company shall be contacted by using the following Email:firstname.lastname@example.org
PERSONAL IDENTIFICATION INFORMATION
Company may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit the Site, register on the Site, fill out a form, sign a contract, purchase a product and in connection with other activities, use applications and benefit from Services proposed by the Company. Users may be asked for, as appropriate, name, date of birth, email address, mailing address, phone number, etc.
NON-PERSONAL IDENTIFICATION INFORMATION
Company may collect non-personal identification information about Users whenever they use the Site or other service. Non-personal identification information may include technical information about Users means of connection, such as the operating system and the internet service provider utilized, geographical information such as country of origin, behavioral information such as time spent on the Site, as well as further non-personal analytical data to improve customer experience, products and services.
Each User recognizes and accepts that the performance of the Services may depend on the collection and processing of personal identification information and non-personal identification information.
COOKIES AND OTHER TRACKING TECHNOLOGIES
Some of the Site’s pages utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about Site activity. Some cookies and other technologies may serve to recall personal information previously indicated by a Site User. Most browsers allow Users to control cookies, including whether or not to accept them and how to remove them.
Users may set most browsers to notify them if they receive a cookie, or they may choose to block cookies with their browser, but please note that if Users choose to erase or block their cookies, they will need to re-enter certain identifying information, should the Company in the future require such information, to gain access to certain parts of the Site.
USE OF COLLECTED INFORMATION
Principally, personal and non-personal identification information is used to provide the Users with the Services and to insure a full efficiency of the Services they have registered for or they requested in any other manner.
In this framework, Company may collect and use Users’ personal and non-personal identification information for the following purposes:
- To improve Services – Information Users provided will assist the company to respond to certain Users’ requests.
- To personalize User experience – Company may use non-personal identification information to understand how Users as a group use the Company’s Services.
- To improve Company’s websites and other internet presence as well as other communication tools or tools for specific Services – Company may use feedback that Users provide to improve its products and services.
- To send periodic emails and other text messages and/or notifications – Company may use the email address or mobile phone number provided by Users to respond to inquiries, questions, and/or other requests. If Users decide to opt-in to Company notification list, they will receive periodic information that may include Company news, updates, related product or service information, private sales, information from Company service providers on joint projects etc. (the “Periodic Information Service”). For the case that, at any time, Users would like to unsubscribe from the Periodic Information Service, Company includes detailed unsubscribe instructions at the bottom of each such email or other text message.
LEGAL BASIS FOR PROCESSING
Company collection and processing of personal identification information is based on the following:
- The need to carry out the above processing of information, which is in anticipation of entering into engagements or as part of the performance of existing engagements with Users.
- To the extent that Company uses the personal identification information for advertising or promotional activities, including direct mailing and targeted advertising, it will request Users specific, freely-given, unbundled, informed and separate consent to such uses.
- To the extent that Company uses the personal identification information to improve the Site or for analyzing statistics, the basis for collection of data is its legitimate interest to conduct such improvements and analysis.
PROTECTION OF PERSONAL IDENTIFICATION INFORMATION
Company adopts appropriate data collection, storage and processing practices and security measures, taking into consideration the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of processing Users’ personal identification information, to protect against to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal identification information within the limits of Company’s role with respect to the relevant Services (as certain specific services might be rendered by third parties).
While Company strives to protect Users’ personal identification information, it cannot ensure the security of the information Users transmit, and so Company urges Users to take every precaution to protect their personal identification information when they are on the Internet.
SHARING PERSONAL INFORMATION
Company does not and will not sell, trade, or otherwise transfer to third parties Users’ personal identification information for their own direct marketing use unless it provides clear notice to Users and obtain their explicit consent for their data to be shared in this manner. However each User accepts that his/her personal identification information can be transmitted to website hosting and editing partners and other sub-contractors who assist Company in providing the Services, conducting its business, or servicing the User, so long as those sub-contractors undertake to process the information only according to Company’s instructions and to comply with the applicable law regarding the protection of personal identification information.
Company will only provide those sub-contractors the information they need to deliver the Services, and they are prohibited from using that information for any other purpose.
In addition, Company may transfer personal identification information to third parties in the event of sale or transfer of all or substantially all of its shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing.
Company may also transfer personal identification information to its service providers and subcontractors in order to keep Users up to date on any information they may like to hear about either from Company or from its business partners (unless Users have opted out of these types of communications), subject to Users’ opt-in consent to such processing activities; or
Company may transfer personal identification information to third parties, where needed for corporate audits or to investigate or respond to a complaint or security threat, to prevent illegal uses of its services, to defend itself against third party claims and assist in fraud prevention or investigation; or
However, Users non-personal identification information may be provided to third parties for marketing, advertising, or other uses.
THIRD PARTY SITES
- As long as the Company maintain an ongoing relationship with the User (e.g., where the User is a recipient of Company’s Services, or is lawfully included in Company’s mailing list and has not unsubscribed);
- With the User’ prior consent, until the expiry of any additional retention period.
The Company undertakes to delete or to anonymize the User’ personal data upon expiry of the retention period as described above.
DATA SECURITY AND DATA TRANSFER
The Company has implemented appropriate technical and organizational security measures designed to protect the User personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law.
The User is responsible for ensuring that any personal data that he/she send to us are sent securely.
The Company does not transfer personal data to any third country nor to any international organization, except as the case may be on the basis of:
- Adequacy decisions;
- Suitable Standard Contractual Clauses; or
- Other valid transfer mechanisms under GDPR.
DATA ACCURACY AND MINIMIZATION
The Company take reasonable measures:
- To ensure that the User’ personal data are accurate and, where necessary, kept up to date and accurate; and
DATA SUBJECT RIGHTS
Each User benefits under data protection law from a right of access, modification and opposition to the processing of its personal data, a right to erasure and a right to portability of its personal data by sending an email to email@example.com. Those rights may only be exercised within the limits of any contractual or legal obligation. Each User has also a right to lodge a complaint with the supervisory authority from his/her country of residence, or from the country he/she is located when his/her personal data are collected.