1. Introduction
We are committed to safeguarding the privacy of
our website visitors and service users. This
policy
applies where we are acting as a data controller
with respect to the personal data of our website
visitors and service users; in other words,
where we determine the purposes and means of the
processing
of that personal data. We use cookies on our
website. Insofar as those cookies are not
strictly
necessary for the provision of our website and
services, we will ask you to consent to our use
of
cookies when you first visit our website. Our
website incorporates privacy controls which
affect how
we will process your personal data. By using the
privacy controls, you can specify whether you
would
like to receive direct marketing communications
and limit the publication of your information.
2. How we use your personal data
In this Section 2 we have set out:
-
the general categories of personal data that
we may process;
-
in the case of personal data that we did not
obtain directly from you, the source and
specific
categories of that data;
-
the purposes for which we may process
personal data; and
-
the legal bases of the processing.
When you submit data to us via the Contact
Request form on our website, you will also be
subscribed to our newsletter mailing list,
provided by Mailchimp, to receive future
communications from us. You can unsubscribe
any time by going to this
page.
We may process data about your use of our
website and services ("usage data"). The
usage data may
include your IP address, geographical location,
browser type and version, operating system,
referral
source, length of visit, page views and website
navigation paths, as well as information about
the
timing, frequency and pattern of your service
use. The source of the usage data is Google
Analytics. This usage data may be
processed for the purposes of analysing the use
of the
website and services. The legal basis for this
processing is our legitimate interests, namely
monitoring and improving our website and
services.
We may process your website user account data
("account data“). The account data may
include your
name and email address. The account data may be
processed for the purposes of operating our
website,
providing our services, ensuring the security of
our website and services, maintaining back-ups
of
our databases and communicating with you. The
legal basis for this processing is our
legitimate
interests, namely the proper administration of
our website and business and the performance of
a
contract between you and us and/or taking steps,
at your request, to enter into such a contract.
We may process information that you post for
publication on our website or through our
services
("publication data"). The publication
data may be processed for the purposes of
enabling such
publication and administering our website and
services. The legal basis for this processing is
our
legitimate interests, namely the proper
administration of our website and business and
the performance
of a contract between you and us and/or taking
steps, at your request, to enter into such a
contract.
We may process information contained in any
enquiry you submit to us regarding goods and/or
services
("enquiry data"). The enquiry data may be
processed for the purposes of offering,
marketing and
selling relevant goods and/or services to you.
The legal basis for this processing is our
legitimate
interests, namely the proper administration of
our website and business and the performance of
a
contract between you and us and/or the taking
steps, at your request, to enter into such a
contract.
We may process information relating to
transactions, including purchases of goods
and/or services,
that you enter into with us and/or through our
website ("transaction data"). The
transaction data may
include your contact details, your card details
and the transaction details. The source of the
transaction data is Keeet and EasyBill. The
transaction data may be processed for the
purpose of
supplying the purchased goods and/or services
and keeping proper records of those
transactions. The
legal basis for this processing is the
performance of a contract between you and us
and/or taking
steps, at your request, to enter into such a
contract; providing that, if you are not the
person
contracting with us, the legal basis for this
processing is our legitimate interests, namely
the
proper administration of our website and
business.
We may process information that you provide to
us for the purpose of subscribing to our email
notifications and/or newsletters
("notification data"). The notification
data may be processed for
the purposes of sending you the relevant
notifications and/or newsletters. The legal
basis for this
processing is our legitimate interests, namely
communications with our website visitors and
service
users.
We may process any of your personal data
identified in this policy where necessary for
the establishment,
exercise or defence of legal claims, whether in
court proceedings or in an administrative or
out-of-court
procedure. The legal basis for this processing
is our legitimate interests, namely the
protection
and assertion of our legal rights, your legal
rights and the legal rights of others.
We may process any of your personal data
identified in this policy where necessary for
the purposes
of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional
advice. The
legal basis for this processing is our
legitimate interests, namely the proper
protection of our
business against risks.
In addition to the specific purposes for which
we may process your personal data set out in
this
Section 2, we may also process any of your
personal data where such processing is necessary
for
compliance with a legal obligation to which we
are subject, or in order to protect your vital
interests
or the vital interests of another natural
person.
Please do not supply any other person's personal
data to us, unless we prompt you to do so.
3. Providing your personal data to others
We may disclose your personal data to our
insurers and/or professional advisers insofar as
reasonably
necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks,
obtaining
professional advice, or the establishment,
exercise or defence of legal claims, whether in
court
proceedings or in an administrative or
out-of-court procedure.
Your personal data submitted via the
Contact Request form is held on the servers of our email newsletter
provider Mailchimp. Additionally,
your personal data is stored on our email
servers and company servers.
In addition to the specific disclosures of
personal data set out in this Section 3, we may
disclose
your personal data where such disclosure is
necessary for compliance with a legal obligation
to which
we are subject, or in order to protect your
vital interests or the vital interests of
another natural
person. We may also disclose your personal data
where such disclosure is necessary for the
establishment,
exercise or defence of legal claims, whether in
court proceedings or in an administrative or
out-of-court
procedure.
4. Retaining and deleting personal data
This Section 5 sets out our data retention
policies and procedure, which are designed to
help ensure
that we comply with our legal obligations in
relation to the retention and deletion of
personal data.
Personal data that we process for any purpose or
purposes shall not be kept for longer than is
necessary
for that purpose or those purposes.
We will retain your personal data as follows:
-
Usage data will be retained for a minimum
period of two years following the date of
collection,
and for a maximum period of five years
following that date;
-
Account data will be retained for a minimum
period of two years following the date of
closure of
the relevant account, and for a maximum
period of five years following that date;
-
Publication data will be retained for a
minimum period of two years following the
date when the
relevant publication ceases to be published
on our website or through our services, and
for a
maximum period of five years following that
date;
-
Enquiry data will be retained for a minimum
period of two years following the date of
the enquiry,
and for a maximum period of five years
following that date;
-
Transaction data will be retained for a
minimum period of two years following the
date of the
transaction, and for a maximum period of
five years following that date;
-
Notification data will be retained for a
minimum period of two years following the
date that we
are instructed to cease sending the
notifications, and for a maximum period of
five years following
that date (providing that we will retain
notification data insofar as necessary to
fulfil any
request you make to actively suppress
notifications); and
-
Notwithstanding the other provisions of this
Section 5, we may retain your personal data
where
such retention is necessary for compliance
with a legal obligation to which we are
subject, or in
order to protect your vital interests or the
vital interests of another natural person.
5. Your rights
In this Section 6, we have listed the rights
that you have under data protection law.
Your principal rights under data protection law
are:
-
the right to access - you can ask for copies
of your personal data;
-
the right to rectification - you can ask us
to rectify inaccurate personal data and to
complete
incomplete personal data;
-
the right to erasure - you can ask us to
erase your personal data;
-
the right to restrict processing - you can
ask use to restrict the processing of your
personal data;
-
the right to object to processing - you can
object to the processing of your personal
data;
-
the right to data portability - you can ask
that we transfer your personal data to
another
organisation or to you;
-
the right to complain to a supervisory
authority - you can complain about our
processing of your
personal data; and
-
the right to withdraw consent - to the
extent that the legal basis of our
processing of your personal
data is consent, you can withdraw that
consent.
These rights are subject to certain limitations
and exceptions. You can learn more about the
rights
of data subjects by visiting
https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
.
You may exercise any of your rights in relation
to your personal data by written notice to us,
using
the contact details set out below.
6. About cookies
A cookie is a file containing an identifier (a
string of letters and numbers) that is sent by a
web
server to a web browser and is stored by the
browser. The identifier is then sent back to the
server
each time the browser requests a page from the
server.
Cookies may be either "persistent" cookies or
"session" cookies: a persistent cookie will be
stored
by a web browser and will remain valid until its
set expiry date, unless deleted by the user
before
the expiry date; a session cookie, on the other
hand, will expire at the end of the user
session,
when the web browser is closed.
Cookies do not typically contain any information
that personally identifies a user, but personal
data that we store about you may be linked to
the information stored in and obtained from
cookies.
7. Cookies that we use
We use cookies for the following purposes:
-
authentication and status - we use cookies
to identify you when you visit our website
and as you
navigate our website, and to determine if
you are logged into the website;
-
personalization - we use cookies to store
information about your preferences and to
personalize
the website for you;
-
security - we use cookies as an element of
the security measures used to protect user
accounts,
including preventing fraudulent use of login
credentials, and to protect our website and
services
generally;
-
advertising - we use cookies to help us to
display advertisements that will be relevant
to you;
-
analysis - we use cookies to help us to
analyze the use and performance of our
website and services;
and
-
cookie consent - we use cookies to store
your preferences in relation to the use of
cookies more
generally.
8. Cookies used by our service providers
Our service providers use cookies and those
cookies may be stored on your computer when you
visit our
website.
We use Google Analytics. Google Analytics
gathers information about the use of our website
by means
of cookies. The information gathered is used to
create reports about the use of our website. You
can
find out more about Google's use of information
by visiting
https://www.google.com/policies/privacy/partners/
and you can review Google's privacy policy at
https://policies.google.com/privacy
.
9. Managing cookies
Most browsers allow you to refuse to accept
cookies and to delete cookies. The methods for
doing so
vary from browser to browser, and from version
to version. You can however obtain up-to-date
information
about blocking and deleting cookies via these
links:
Blocking all cookies will have a negative impact
upon the usability of many websites.
If you block cookies, you will not be able to
use all the features on our website.
10. Amendments
We may update this policy from time to time by
publishing a new version on our website.
You should check this page occasionally to
ensure you are happy with any changes to this
policy.
11. Our details
This website is owned and operated by Elias
Khattar for Reto App.
Our principal place of business is at
Lohmühlenstraße 65 Berlin, 12435 Germany.
You can contact us:
