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Privacy Policy

Privacy Policy

INTRODUCTION

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you interact with us or visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.


This privacy policy is provided in a layered format and explains the specific areas set out below.


IMPORTANT INFORMATION AND WHO WE ARE

THE DATA WE COLLECT ABOUT YOU

HOW YOUR PERSONAL DATA IS COLLECTED

HOW WE USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

INTERNATIONAL TRANSFERS

DATA SECURITY

DATA RETENTION

YOUR LEGAL RIGHTS

CALIFORNIA REQUIREMENTS

GLOSSARY

 

IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy aims to give you information on how Aleph Group collects and processes your personal data through your use of this website, including any data you may provide through this website when you insert your contact details to our Contact us website form, chat with us, order a service or sign up for one of our events, webinars or video calls.

This website is not intended for children, and we do not knowingly collect data relating to children.


It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.


CONTROLLER

Aleph Group, Inc is the holding company of different legal entities and a provider of this webpage. When we mention »Aleph Group«, »we«, »us«, or »our« in this privacy policy, we are referring to the relevant company, part of the Aleph Group, providing you services and responsible for processing your data, which is also considered to be the data controller of your personal data.


We have appointed a Global Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Global Data Protection Officer using the details set out below.


CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our Global Data Protection Officer in the following way:


Email address: [email protected].

Address: Httpool, Internet Marketing, d.o.o., Litostrojska cesta 52, 1000 Ljubljana, Slovenia


You have the right to make a complaint at any time to your country’s supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so, please contact us in the first instance.


CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on February 1, 2024. Historic versions can be obtained by contacting us.


It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. For example we use Google forms, SalesForce, Statamic, Netlify, Typeform, Learndash, Calendly, Hubspot, Hotjar, AWS and Mailchimp for the contact forms on the website, occasionally we embed videos from our youtube channel and we might link to content on our partner’s websites or other similar sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.


DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where personally identifiable information  has been removed (anonymous data).


We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:


Identity Data includes first name, last name, email address, company, country, username or similar identifier, title, date of birth, gender, image (whether static or moving) and voice (jointly, your “image”).

Contact Data includes delivery address, email address and telephone number.

Bank Account Data includes bank account numbers.

Transaction Data includes your billing address and other details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Platform Profile Data includes your Platform username and password, profile ID, ad account ID, Business Manager ID, Platform Page ID, campaign results, test results, orders made by you, your interests, preferences, feedback, and survey responses and any other Platform-related information you share with us while using our chat feature.

Usage Data includes information about how you use our website, services, etc. All of the information processed is used to solve our clients issues/restrictions and improve their advertising on Meta platforms through us. 

Marketing and Communication Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.


We may also collect, use and share Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.


We do not collect any Special Categories of Personal Data about you (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.


IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.


HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:


Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us by chat, post, phone, email, participation in synchronous live meetings or otherwise. This includes personal data you provide when you;

  • Apply for our products or services;

  • Create an account on our website;

  • Subscribe to our service or publications;

  • Contact us by any means of communication (for example using our chat feature).

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. 

  • Third parties or publicly available sources. We might receive personal data about you from various third parties and public sources as set out below:


Technical Data from the following parties:


1 Analytics providers, such as D&B, local reports;

2 Advertising networks; 

3 Search information providers; 

4 Contact, Financial and Transaction Data from providers of technical, payment services, such as COFACE;

6 Identity and Contact Data from publicly available sources: 

7 Social media interactions with any of our channels.


HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:


Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.


PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity


Type of data 


Lawful basis for processing


To register you as a new customer



  1. Identity

  2. Contact

  3. Profile

  1. Performance of a contract with you

  2. Necessary to comply with a legal obligation

  3. Necessary for our legitimate interests (to conduct a background check)




To process and deliver your order:

  1. Manage payments

  2. Collect and recover money owed to us

  1. Identity 

  2. Contact

  3. Bank Account 

  4. Transaction

  5. Marketing and Communications



  1. Performance of a contract

  2. Necessary for our legitimate interests (to recover debts due to us)


To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy


  1. Identity

  2. Contact

  3. Profile


  1. Performance of a contract with you

  2. Necessary to comply with a legal obligation

  3. Necessary for our legitimate interests (to keep our records updated) 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

  1. Identity

  2. Contact

  3. Technical

  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization exercise)

  2. Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationship experience

  1. Technical

  2. Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you 


  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile

  6. Marketing and Communications


Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).


You might receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. 


THIRD PARTY MARKETING

We will get your express consent before we share your personal data with any third party for marketing purposes.


OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.


Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transactions.


COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.


If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

i. Aleph group companies

We share your personal data within the Aleph Group of companies to: 

i. provide you with the best service;

ii. send you information about Aleph Group products and services we think you’ll be interested in hearing about.


ii. Suppliers 

Here we have included companies that help Aleph Group provide the services you use, and need to process details about you for this reason. We always share as little information as we can and encrypt and/or make it impossible for the recipient to identify you where possible. These are:

  • analytical and cyber security service providers that help us with fraud and security checks;

  • cloud computing power, storage and software providers, such as AWS, Hetzner and Google Cloud;

  • our business intelligence and analytics platform provider;

  • companies that help us with functional analytics (to help us solve technical problems with the app, for example);

  • companies that help us with marketing (we won't share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time);

  • software companies that we use to email you, or for processing and storing emails with you;

  • companies that help us with customer support, surveys and developers.

iii. Partners who help to provide our services 

We may share your personal data with our partners to provide you with certain requested services. We‘ll only share your personal data in this way if you have asked for the relevant service. From time to time, we may work with other partners to offer co-branded services or promotional offers, and we will share some of your personal data with those partners. We will always make sure you understand how we and our partners process your personal data for these purposes. 


iv. For legal reasons 

We also share your personal data with government authorities, law enforcement authorities, tax authorities or courts:

  • if we have to do so under any law or regulation;

  • if we sell our business;

  • in connection with suspected or actual criminal or fraud investigations;

  • to enforce our rights (and those of our customers or others);

  • in connection with legal claims.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


INTERNATIONAL TRANSFERS

We might share your personal data within the Aleph Group with employees, agents, contractors and other third parties who have a business need to know.


TRANSFERRING DATA OUTSIDE THE COUNTRY OF YOUR RESIDENCE 


In short: We may transfer, store, and process your information in countries other than your own.

We provide an international service which, in some instances, may require transferring, storing, and processing of your personal data in a country outside the country of your residence. To do so, we have taken all necessary steps to ensure that your data is afforded a level of protection that is essentially equivalent or higher to that guaranteed within your country. For that reason, we will only transfer your data to a country other than the country of your residence:



  • if the European Commission has adopted a decision confirming that a third country provides adequate protection (or the competent authority in UK, Switzerland or any other country where you reside) has done so for transfers outside these territories); or

  • if we’ve agreed to Standard Contractual Clauses (“SCCs”) approved by the European Commission (for EEA), to SCCs via the ICO’s UK Addendum (for the UK) or an equivalent mechanism (for Switzerland and any other country where you reside for transfers outside these territories) with a third party.


Please contact us if you want further information on the specific mechanism used when transferring your personal data outside the country of your residence.   


DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.


We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?


We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


You can request details of retention periods for different aspects of your personal data by contacting us.


Under certain  circumstances you can ask us to delete your data: see your legal rights below for further information.


In some cases we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


YOUR RIGHTS

FOR RESIDENTS IN THE EU/EEA, UK AND SWITZERLAND

‍ In short: Under data protection legislation in the UK, EU/EEA and Switzerland you may have certain rights, including but not limited to the right to access or manage your personal data, to delete or update it, and restrict its use.


  • Right to be informed: you have the right to be informed about how we collect and use your personal data. We provide you with this information in this Privacy Policy and by answering any privacy-related questions you address to us.


  • Right to access your data: you have the right to request a copy of the personal data we hold about you.


  • Right to rectification: you have the right to have inaccurate or incomplete personal data rectified.


  • Right to erasure: under certain circumstances, you may have the right to have your personal data deleted. Examples of when this request may be granted include when:


  • it is no longer necessary to process your data for the purpose it was collected,

  • you have withdrawn your consent for consent-based data processing,

  • we have used your personal data unlawfully, or

  • we have a legal obligation to remove your data.


  • Right to restrict or object to the processing of your personal data: in certain circumstances, we may agree to restrict or suppress the processing of your personal data. Examples of when we may agree to this include:


  • you have asked us to verify the accuracy of your data,

  • we have processed your data unlawfully, but you do not wish your data to be deleted,

  • we no longer need your personal data, but you do not wish your data to be deleted in order to establish, exercise, or defend a legal claim, or

  • you objected to us using your personal data, but your objection was outweighed by our legitimate interests.


  • Right to challenge an automated decision: you have the right to request us to manually review an automated decision made about you if that decision has a legal or similarly significant effect on you.


  • Right to withdraw consent: if the legal basis we use for the processing of your personal data is consent, you can withdraw your consent at any time.


  • Right to opt-out of commercial communication: you have the right to opt-out of any future commercial communication through the unsubscribe link provided with each commercial email. You further have the right to not be contacted by phone regarding any commercial offering. Please note that your country may offer a telemarketing do-not-call-list. 


FOR RESIDENTS OUTSIDE THE EU/EEA, UK, CA AND SWITZERLAND.

Depending on the country where you reside, you might have certain rights under applicable data protection or e-commerce laws, such as the rights described in the previous section. You can contact us to inquire further information or exercise your rights. If you try to exercise a right not granted to you under your country’s applicable legislation, we will let you know as soon as possible. In all other instances, we will respond to your request within the deadline set in the applicable legislation (if any). If the applicable data protection and e-commerce laws of your country require us to provide you detailed information about how and why we process your personal data, please refer to the information provided in the corresponding sections above.


If you wish to exercise any of the rights set out above, please contact us at: [email protected].



THE GROUNDS ON WHICH WE PROCESS YOUR PERSONAL INFORMATION

We can process your personal information solely if we have a legal basis for such processing. 

Legal bases are as follows:

  • your consent to the relevant processing activities;

  • compliance with a legal or regulatory obligation that lies with us;

  • the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;

  • vital interests of the data subject or another individual;

  • performing  a contract and its preliminary procedures, in cases where you are a party to said contract;

  • our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and

  • performance of a task carried out in the public interest or in the exercise of official authority vested in us.


To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.


CATEGORIES OF PERSONAL INFORMATION PROCESSED

To find out what categories of your personal information are processed, you can read the section titled “The Data We Collect About You” within this document.


WHY WE PROCESS YOUR PERSONAL INFORMATION

To find out why we process your personal information, you can read the sections titled “Purposes for which we will use your personal data” within this document.


HOW TO FILE YOUR REQUEST

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.


HOW AND WHEN WE WILL RESPOND TO YOUR REQUEST

We will strive to promptly respond to your requests.


In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.


In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.


You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.


In the latter case, we’ll respond as soon as possible, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.


In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.


NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 


WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


TIME LIMIT TO RESPOND

We try to respond to all legitimate requests as soon as possible and at least within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.



 CALIFORNIA REQUIREMENTS

i. Processing your information


This notice describes the categories of personal information we may collect, the sources of that information, and our deletion policies. We’ve also included information about how we may process your information, which includes for "business purposes" under the CCPA  such as to protect against illegal activities and offer you new products. If you have questions about the categories of information we may collect about you and our processing activities, please be sure to visit sections THE DATA WE COLLECT ABOUT YOU, HOW YOUR PERSONAL DATA IS COLLECTED and HOW WE USE YOUR PERSONAL DATA. If you have any questions or would like to exercise your rights under the CCPA, you can use our contact details above. 


ii. Exercising your rights

If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act (“CCPA”). This notice explains the tools that we have made available to you to exercise your data rights under the CCPA, such as the right to deletion and the right to request access to the categories of information we have collected about you. You will not be discriminated against for exercising any of your rights under the CCPA. In order to protect your information from unauthorized access or deletion, we may require you to provide additional information for verification. If we cannot verify your identity, we will not provide or delete your information. 


  • Right to opt-out of selling 

You have the right to opt-out of having your personal information sold.  We don’t sell your personal information. We do share your information with others as described under section SHARING YOUR PERSONAL DATA WITH THIRD PARTIES of this notice. We've provided more information about how you can manage your advertising, and do-not-track preferences, within this notice. 


In addition, California Civil Code Section 1798.83 permits customers who are California residents to request certain information regarding our disclosure of personal information to third-parties for their direct marketing purposes. Please allow 30 (thirty) days for a response.


  • Right against discrimination


You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales. 


  • Right to know

You have the right to request in writing:  a list of the categories of personal information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes, and;  


(i) the names and addresses of all such third parties.  


(ii) In addition, you have the right to request:  


(i) the categories of personal information we have collected about you,  


(ii) the categories of sources from which personal information is collected,  


(iii) the business or commercial purpose for the information collection,  


(iv) the categories of third parties with whom we have shared personal information, and  


(v) the specific pieces of personal information we hold about an individual.  


You have the right to request a copy of the specific personal information we collected about you during the twelve (12) months before your request. 


  • Right to delete

You have the right to request us delete any personal information we have collected from you or maintain about you, subject to certain exceptions. To assert your right to know or your right to delete your personal information, please see our contact information in the CONTACT DETAILS section above. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot confirm your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. 


GLOSSARY


LAWFUL BASIS


Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.


Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


THIRD PARTIES


INTERNAL THIRD PARTIES

Other companies in the Aleph Group acting as joint controllers or processors and who are based in EU and non-EU countries and provide services, such as IT and Legal internal support.


EXTERNAL THIRD PARTIES

Service providers acting as processors who provide IT and system administration services.

Professional advisers acting as processor or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.


YOUR LEGAL RIGHTS


You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.


Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.


Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.


Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.


Request restrictions of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:


  • If you want us to establish the data´s accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.


Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.