Personal Data Protection Policy For Customers

Collection of Personal Data

The Company collects personal data that you provide directly to the Company, such as

1. Membership registration

2. Telephone

Types of Personal Data Collected

1. Personal data, such as first name and last name

2. Contact data, such as telephone number, email, etc.

3. Transaction and financial data, such as order history, credit card details, bank account, etc.

4. Device and tool data, such as IP address, cookies via Google Analytic, usage history, etc.

5. Other data, such as articles, images, suggestions and other information, etc.

Minors

The Company’s services are not directed at persons under 20 years of age. The Company therefore does not collect personally identifiable information of such persons. If it becomes known that the Company has collected personal data from such a person without confirmed consent from a parent or guardian, the Company will delete that data from its servers.

How Personal Data Is Kept

The Company keeps your personal data in documentary form and in electronic form.

The Company keeps your personal data as follows

1. SENTR™

2. Hubspot

3. Microsoft 365

4. Google Drive

Processing of Personal Data

So that you may use the Company’s products or services in accordance with your purposes, the Company will collect, use and disclose your personal data for the following purposes

1. To create and manage accounts

2. Direct marketing

3. Provision of products and services

4. Improvement and development of products and services

5. Administration and management of the Company

6. Marketing and sales promotion

7. Sales services

Disclosure of Personal Data

The Company will not disclose your personal data to other persons.

Products and Services

The Company will share your data within the Company as necessary in order to improve and develop the Company’s products and services. The Company may aggregate data internally for its various products or services under this policy, for the greater benefit of you and others.

Service Providers

The Company may use service providers to assist in providing the Company’s services, such as payment, marketing and development. Service providers cannot access your data other than as necessary to perform these tasks and are obliged not to disclose it or use it for any other purpose. These service providers have their own personal data protection policies.

Business Transfers

The Company will disclose data, including your personal data, for corporate restructuring, reorganisation, merger or sale of the business or other transfer of assets, on condition that the receiving party agrees to treat your personal data in a manner consistent with this personal data protection policy and with personal data protection law.

Law Enforcement

Where required by law or where requested by a government authority, the Company will disclose your personal data to the extent necessary to government authorities, such as a court or a state agency.

Retention Period of Personal Data

The Company will retain your personal data for as long as necessary while you are a customer of, or have a relationship with, the Company, or for as long as necessary to fulfil the purposes related to this policy, which may need to be retained thereafter if required by law. The Company will delete or destroy the personal data, or render it unable to identify you, once it is no longer necessary or once that period has ended.

Security of Personal Data

The Company applies security measures for personal data covering administrative management, technical measures and physical safeguards that are reasonable and concrete, in order to protect your personal data from loss and theft and to prevent unauthorised access, use and alteration. These measures are designed to provide a level of security appropriate to the risk of processing your personal data.

Payment Information Security

The Company stores your payment details, such as a credit card number or a payment token, in its secured systems for your future payments and for billing.

Your Rights Regarding Personal Data

You may exercise various rights under the requirements of the law and the policy as prescribed at present, or as may be amended in the future, as well as under the criteria established by the Company.

1. Right To Withdraw Consent

   If you have given consent, the Company will collect, use and disclose your personal data, whether that consent was given before or after the personal data protection law came into force. You have the right to withdraw your consent at any time.

2. Right Of Access

   You have the right to request access to your personal data that is under the Company’s responsibility, to request that the Company make a copy of such data for you and to request that the Company disclose how it obtained your personal data.

3. Right To Data Portability

   You have the right to obtain your personal data where the Company has organised that personal data in a format that is readable or usable by tools or equipment operating automatically, and where the personal data can be used or disclosed by automated means. You also have the right to request that the Company send or transfer the personal data in such format to another data controller where this can be done by automated means, and the right to obtain personal data that the Company sends or transfers in such format directly to another data controller, except where this cannot be done for technical reasons.

4. Right To Object

   You have the right to object to the collection, use and disclosure of your personal data at any time, where the collection, use and disclosure of your personal data is carried out for operations necessary under the legitimate interests of the Company or of another person or juristic person, without exceeding what you could reasonably expect or is carried out for a mission in the public interest.

5. Right To Request Erasure Or Destruction Of Data

   You have the right to request the deletion or destruction of your personal data, or to have your personal data rendered unable to identify you, if you believe that your personal data has been collected, used and disclosed unlawfully under the relevant law, or if you consider that the Company no longer needs to retain it for the purposes related to this policy, or once you have exercised the right to withdraw consent or the right to object as described above.

   You have the right to request the temporary suspension of the use of personal data where the Company is verifying your request to exercise the right to rectify personal data or your objection, or in any other case where the Company no longer has a need and must delete or destroy your personal data under the relevant law but you request that the Company suspend its use instead.

6. Right To Request Suspension Of Processing

   You have the right to request that the Company suspend the processing of your personal data while the Company examines your request for rectification or objection. The same applies where the personal data must be erased or destroyed under the relevant law but you ask the Company to suspend the processing instead.

7. Right To Request Rectification Of Data

   You have the right to request that your personal data be corrected so that it is accurate, current, complete and not misleading.

8. Right To Lodge A Complaint

   You have the right to lodge a complaint with the competent authority under the relevant law if you believe that the collection, use and disclosure of your personal data is carried out in a manner that violates or fails to comply with the relevant law.

You may exercise your rights as a data subject as set out above by contacting the Company’s personal data protection officer using the details at the end of this notice. The Company will notify you of the outcome within 30 days from the date the Company receives such a request. If the Company refuses the above request, the Company will notify you of the reason for the refusal by email.

Advertising and Marketing

For the benefit of your receiving the Company’s products and services, the Company uses your data to analyse and improve products or services and to carry out marketing through Google, Facebook, pixel tracking code and others. The Company uses such data to make products or services suitable for you.

Communications

The Company will send messages or news for the purpose of offering things of interest to you. If you no longer wish to receive communications from the Company by email, you may click “Unsubscribe” in the email link.

Individual Tracking Technology (Cookies)

To make your experience complete and effective, the Company will use individual tracking technology (cookies) or similar technology in order to improve access to products or services, deliver appropriate advertising and track your usage. The Company uses cookies to identify and track website users and website access.

If you do not want cookies to be placed on your computer, you may set your browser to refuse cookies before using the Company’s website. This refusal will not affect your use of the Company’s website.

Notification of a Personal Data Breach

In the event that a breach of your personal data occurs, the Company will notify the Office of the Personal Data Protection Committee without delay within 72 hours from becoming aware of the incident, to the extent practicable. Where the breach carries a high risk of affecting your rights and freedoms, the Company will notify you of the breach together with remedial guidance without delay, through the following channels

Email

Amendments to the Personal Data Protection Policy

The Company will amend this policy from time to time. You can learn of the terms and conditions of the amended policy by email.

This policy was last amended and has been in effect since 24 September 2020

Personal Data Protection Policies of Other Websites

This personal data protection policy applies only to the offering of the Company’s products and services and to the use of the Company’s website. If you visit another website, even through a channel on the Company’s website, the protection of personal data will be governed by that website’s personal data protection policy, with which the Company is not involved.

Bot Protection (Cloudflare Turnstile)

The Company uses Cloudflare Turnstile on its websites and forms to detect automated abuse and to protect submissions. Turnstile may process technical signals such as IP address, browser and device characteristics and similar data. Cloudflare processes this data as described in the Cloudflare Turnstile Privacy Addendum.

Contact Details

If you have suggestions or wish to enquire about the details of the collection, use and disclosure of your personal data, including the exercise of rights under this policy, you may contact the Company and the personal data protection officer as follows