Datenschutzerklärung
1. Important Information and Who We Are
The purpose of this Policy
We are Glitterbels Germany UG (haftungsbeschränkt), registered with the commercial register of the Local Court of Hanau under HRB 97920, and our registered and trading address is at Leipziger Str. 72 Halle 4/5, 63571 Gelnhausen. In this privacy and cookies policy (“Policy”), Glitterbels Germany UG (haftungsbeschränkt) is referred to as “GGU”, “we”, “us” or “our”, as appropriate.
We respect your privacy and are committed to protecting your personal data. This Policy, amongst other matters, will inform you as to how we look after your personal data when you use our website at www.glitterbels-europe.com and, where applicable, our mobile application. Our mobile application is for use by our third-party Educators (being those third parties appointed by us to deliver our training courses) only.
This Policy further explains when and why we collect personal information about website and/or app users, GGU customers, participants in the “Nailist” Recognition and Rewards Program (“Program”), people who contact or interact with us, and our third-party Educators, how we use that personal information, the conditions under which we may disclose it to others and how we keep it secure. Neither our website nor our app is intended for children, and we do not knowingly collect data relating to children.
It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
References in this Policy to a ‘section’ shall be to the relevant section of this Policy.
Controller
We are the controller and are responsible for your personal data. By this, we mean that we determine the purposes for which and the manner in which your personal data is, or is to be, processed.
Contact details
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, our privacy practices or want to submit a request to exercise your legal rights (as set out in section 10 below), please contact our data privacy manager using the details set out below:
Full name of legal entity: Glitterbels Germany UG (haftungsbeschränkt)
Name of Data Privacy Manager: Mac Maginnis, Finance Director
Email address: mac@glitterbels.com
Postal address: Leipziger Str. 72 Halle 4/5, 63571 Gelnhausen
Telephone number: +44 7780 766589
You have the right to make a complaint at any time to a supervisory authority for data protection issues. You can contact either the supervisory authority for your habitual residence, place of work or the registered office of our company. However, we would appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
Changes to this Policy and your duty to inform us of changes
We keep this Policy under regular review. This Policy was last updated in July 2026, and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is current and accurate. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our website and/or our app may include links to third-party websites, plug-ins and applications. 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 applications and are not responsible for their privacy statements. When you leave our website or our app, we encourage you to read the privacy notice of every website that you visit or app that you use.
2. The 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 the identity 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:
|
Category of Data |
Information Collected |
|
Identity Data |
includes first name, last name, username or similar identifier and in respect of Educators, photographs that you use for display photos. |
|
Contact Data |
includes delivery address, billing address, email address and telephone numbers. |
|
Financial Data |
includes bank account and payment card details. |
|
Transaction Data |
includes details of products and services you have purchased from us. |
|
Technical Data |
includes Internet protocol (IP) address, 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 our website and/or our app. |
|
Profile Data |
includes your username and password, history, interests, preferences and feedback. |
|
Usage Data |
includes details of your use of our website and/or our app including, but not limited to, traffic data and other communication data and the resources that you access. |
|
Marketing and Communications Data |
includes your preferences in receiving marketing from us and our third parties and your communication preferences. |
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may 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/app 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 Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your 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 offences.
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 (including to administer and run the Program), or in order to provide you with information or products or services that you have requested from us, 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 products or services or with rewards and benefits earned as part of the Program) or provide you with the information requested. In this case, we may have to cancel a product, service or membership you have with us, but we will notify you if this is the case at the time.
3. How do we collect personal information from you?
You may provide this to us through our website forms and/or our app, emails, phone conversations, documents that you provide to us, or when you contact us for any other reason by any media, for example, when you:
- Create an account on our website and/or our app
- Purchase products and/or training courses from us
- Enrol in the Program
- Contact or interact with us through our website and/or our app
- Provide feedback to us
- Request marketing and/or other communications to be sent to you
This includes Identity, Contact, Financial, Transaction, Profile, Usage and Marketing and Communications Data.
Automated technologies or interactions
We also obtain personal information relating to you (including information about your equipment, browsing actions and patterns) using automated technical means when you visit our website and/or our app. We collect this personal data using cookies, server logs and other similar technologies. Our website and our app use cookies to distinguish you from other users of our website and/or our app. This helps us to optimise your experience of our website and/or our app and services, and also allows us to improve our website and/or our app. For detailed information on the cookies we use and the purposes for which we use them, please see section 5 below.
Information we receive from other sources.
We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data and Usage Data from analytics providers and search information providers.
- Contact Data from providers of technical services.
- Identity and Contact Data from publicly available sources.
4. 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 (Art. 6 para. 1 lit b GDPR);
- 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 (Art. 6 para. 1 lit. f GDPR); and/or
- Where we need to comply with a legal obligation (Art. 6 para. 1 lit c GDPR)
- Where you have given us your consent (Art. 6 para 1 lit a GDPR).
The table below describes all the ways in which 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.
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 using the details set out in section 1 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 create an account and register you as a new customer |
(a) Identity (b) Contact (c) Profile |
(a) Performance of a contract with you |
|
To process and deliver your order for products and/or services (including training courses) |
(a) Identity (b) Contact (c) Financial (d) Profile |
(a) Performance of a contract with you |
|
To register you as a member of the Program, administer and run the Program and manage your membership of and participation in the Program |
(a) Identity (b) Contact (c) Transaction (d) Profile |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to reward brand loyalty and to further develop and grow our business) |
|
To manage our relationship with you, which will include: (a) notifying you of changes to our website and/or our app; and (b) communicating with you where you have asked us to do so; |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Usage (f) Technical |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and to analyse how customers use our website, app and services) (c) Necessary to comply with a legal obligation |
|
Where you are one of our third-party Educators: (a) to manage our relationship with you, which will include providing you with instructions on training courses you are required to deliver; (b) displaying the data which you have provided to us to help our customers select an appropriate training course |
(a) Identity (b) Contact
|
(a) Performance of a contract with you (b) Your consent |
|
To enable you to provide feedback |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Usage
|
Necessary for our legitimate interests (to study how customers use our services, to develop them and further grow our business) |
|
To administer and protect our business and our website/app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and preventing fraud) |
|
(a) To deliver relevant website/app content and advertisements to you; (b) To measure and analyse the effectiveness of the advertising we serve you;
|
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
|
(a) Necessary for our legitimate interests (to study how customers use our services, to develop them, to further grow our business and to inform our marketing strategy) |
|
To use data analytics to improve the website, app, services, marketing, customer relationships and experiences |
(a) Technical (b) Usage
|
Necessary for our legitimate interests (to define types of customers for our services, to keep our website and our app updated and relevant, to develop our business and to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- We may use your Identity, Contact, Transaction, Technical, Usage, Profile and Marketing and Communications 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 services and offers may be relevant for you (we call this marketing).
- You will receive marketing communications from us only if you have given us your prior express consent or if we have obtained your electronic mail address in connection with the sale of goods or services and use the address for direct advertising of similar goods and services and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.
- Opting out: You can ask third parties or us 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, service experience or other transactions.
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. In this case, we will inform you on the use of your personal data for another reason. 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 (using the details set out in section 1).
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.
5. Cookies and Plugins
Our website and our app use cookies.
About Cookies
Cookies are tiny text files that identify your computer to our server as a unique user when you visit certain pages on our website and/or our app and they are stored by your Internet browser on your computer's hard drive. Cookies can be used to recognise your Internet Protocol address, saving you time while you are on our website and/or our app.
We only use cookies for your convenience in using our website and/or our app, and not for obtaining or using any other information about you (for example, targeted advertising). Your browser can be set to not accept cookies, but this would restrict your use of our website and/or our app.
If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.
A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies again:
- Strictly necessary cookies: These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. The website cannot function properly without these cookies;
- Functional cookies: These cookies enable the site to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly;
- Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular; and
- Targeting cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Legal Basis
The legal basis for cookies that are absolutely necessary to provide you with the expressly requested service is Section 25 para. 2 no. 2 of the German Act on Data Protection and the Protection of Privacy in Telecommunications and Digital Services (Gesetz über den Datenschutz und den Schutz der Privatsphäre in der Telekommunikation und bei digitalen Diensten, “TDDDG”). Such necessity exists, for example, with regard to ensuring the following functionalities / achieving the following purposes:
- identifying bot traffic and preventing bot attacks;
- ensuring system security/detecting and preventing "fraud";
- verifying that the service is functioning properly;
- provision of individual "features" (displaying the shopping cart, displaying the wish list, enabling and maintaining login, integration of payment service providers, etc.);
- complying with legal requirements (including documenting the granting/withdrawal of tracking opt-ins);
- general audience (reach) measurement;
- carrying out billing (e.g., settlement with partners).
With regard to the data processing operations that are necessary for the operation of the website/app, you do not have a right to object.
Any use of cookies that is not absolutely technically necessary constitutes data processing that is only permitted with your express and active consent (Section 25 para. 2 TDDDG, Article 6 para. 1 sentence 1 lit. a GDPR). This applies in particular to the use of functional, performance and targeting cookies. Furthermore, we will only pass on your personal data processed by cookies to third parties if you have given your express consent (Article 6 para. 1 sentence 1 lit. a GDPR) to do so.
Please note that we collect data from our website and our app about the use of our website and our app (as applicable) using a web analysis tool that uses cookies that are (able to be) used to generate pseudonyms for a user’s profile. This means that using cookies (which may be stored on your computer after you leave our website and our app) can store information about your visit.
As set out in section 6 below, we use services provided by Shopify to allow us to operate an e-commerce platform for the sale of our products and/or services. For a complete list of Shopify cookies, please see the ‘Merchant Storefronts’ section of the Shopify cookie policy, which can be accessed via https://www.shopify.com/de/legal/cookies.
We also use services provided by Book That App by Zetya to allow us to make available to our third-party Educators a mobile application that helps us to manage training course bookings with our Educators. If you want to find out more information about cookies used on our app, we recommend that you contact Zetya directly (https://www.zetya.com/).
Consent
You give this consent by clicking the "Accept All" button in a banner on our website or in our app that links to these consent texts, or by ticking the checkbox for individual cookies or for all cookies and then clicking "Save Preferences." By clicking the "Accept All" or "Save Preferences" button, you consent to our storing data on your device (e.g., by setting cookies) or accessing data from your device.
The data collected in this way (tracking data) is, on the one hand, further processed for purposes in which we have a legitimate interest and where your interest in such further processing not taking place does not override our legitimate interests. Detailed information on the further processing of tracking data for legitimate interests can be found in our Cookie Policy [https://glitterbels-europe.com/pages/cookie-policy].
In addition, by clicking the "Accept All" or "Save Preferences" button - provided that you have ticked the checkbox for targeting cookies - you consent to the use of certain third-party advertising functionalities whose use is itself subject to consent. The data processing carried out in connection with these advertising functionalities is described in our Cookie Policy [https://glitterbels-europe.com/pages/cookie-policy]. All data processing covered by the consent you give by clicking the "Accept All" or "Save Preferences" button (provided that you have ticked the checkbox for targeting cookies) serves the same purpose, namely "advertising."
Withdrawal of Consent
You can withdraw all consents that you have given by clicking the "Accept All" or "Save Preferences" button shown in the banner with a single click here [https://glitterbels-europe.com/pages/withdrawal-request].
More Information
For more information on what cookies we use, what data is collected, how it is processed, how long it is stored and how you can manage your cookie settings and disable certain types of tracking, please see our Cookie Policy [https://glitterbels-europe.com/pages/cookie-policy].
Browser and app settings
You can, of course, configure your browser so that it does not store our cookies on your device. The help function in the menu bar of most web browsers explains how to stop your browser from accepting new cookies, how to have your browser notify you when you receive a new cookie, and how to delete all cookies you have already received and block any further ones.
Below are three examples of how to do this in the "Google Chrome", "Microsoft Edge" and "Firefox" browsers:
In the Google Chrome browser:
- Click on the three-dot icon in the browser's toolbar and select "Settings."
- Click on "Privacy and security."
- In this tab, various functions are available to you, for example:
- under "Clear browsing data," you can delete the cookies that have been set;
- under "Third-party cookies," you can configure specific settings for third-party cookies, such as blocking them by default;
- under "Ad privacy," you can configure settings for advertising suggested by websites (e.g., block it).
In the Microsoft Edge browser:
- Select the menu (the three dots in the top right) and then, in the "Tools" menu, the "Settings" item.
- Click on the "Privacy, search, and services" tab. You can now configure the security settings for the internet zone. Here you set whether and which cookies should be accepted or rejected. In addition, you can choose complete tracking prevention or various levels thereof. You can also delete cookies and browser data that have already been set here.
- If you select "Cookies and site permissions" in the settings, you can likewise manage how cookies and site data are handled.
In the Firefox browser:
- In the "application menu" (the three lines in the top right), select "Settings."
- Click on the "Privacy & Security" section.
- Now, in the "Cookies and Site Data" section, choose the settings you want, or the option to delete all cookies and site data when the browser is closed.
- In addition, in the "Enhanced Tracking Protection" section, you can choose between the "Standard," "Strict," and "Custom" settings, each of which in turn includes different settings for cookies. You can also select the Do Not Track setting under "Website Privacy Preferences."
If you would like to delete individual cookies set in your browser, or find out which service providers/vendors have set cookies in your browser, you can also do this via a "preference manager." One such tool is available, for example, at www.youronlinechoices.com.
If, in addition to a browser, you also use apps, your device (smartphone, tablet, or similar) offers a function that lets you influence tracking by apps. For example, you can disable the transmission of tracking data by:
- disabling the "Allow Apps to Request to Track" setting on your iOS device; or
- enabling the "Opt out of Ads Personalisation" setting on your Android device.
To learn more about how these opt-out functions work, please consult your device settings.
Social Media Plugins
We do not use social media plugins on our websites. If our websites contain icons from social media providers, we only use these for passive linking to the pages of the respective providers. User information is only transferred to the respective provider after redirection. For information on the handling of your personal data when using these websites, please refer to the respective data protection policies of the providers you use.
6. Disclosures of Your Personal Data
We may share your personal data with third parties we use to help deliver our products and/or services to you and/or to administer and run the Program. For example, where you have purchased a training course from us, we will share your name, address and contact details with our Educators, who are appointed by us as independent third parties to deliver our training courses. Also, we use third-party service providers to deliver products you have ordered and to manage any returns.
If you are one of our Educators, we may display your personal data (including name, contact details and a profile picture) so that GGU customers can make an informed choice about what training course to enrol on.
We may also share your personal data with the parties set out below for the purposes set out in the table in section 4 above. If any of these organisations are based, or have a group or affiliated companies that are based, outside of the EU, then section 7 below sets out the basis on which your personal data is transferred to them.
If you require further information on how our third parties (set out in the table below) are processing your personal data, we recommend that you consult their privacy policies or contact them directly.
|
Third-Party service providers |
Service |
Further Details and Third-Party Links |
|
Shopify |
Shopify allows us to operate an e-commerce platform for the delivery of our products and/or services. |
You can access Shopify’s terms and conditions and privacy policy on its website. https://www.shopify.com/legal/terms, https://www.shopify.com/legal/privacy |
|
Book That App by Zetya |
Book That App is an e-commerce plugin that helps us to manage bookings with our Educators for our training courses via our app.
|
You can access Book That App’s terms and conditions and privacy policy on its website. |
|
Third-Party Payment Processing Services (such as Stripe, PayPal and DivideBuy) |
These third-party providers allow us to process your payment to us. GGU does not store your payment information.
Your payment details are provided to the payment processing service you have selected. Please see the terms and conditions and refer to its privacy policy (for details of how they process your personal data). This information can usually be found on the relevant processing service provider’s website.
|
You can choose from different payment methods for payment processing on our website. Depending on the payment method you choose, we transmit data to different payment service providers. The data processing serves the purpose of being able to offer you different payment methods by processing payments via different payment service providers. If you have chosen one of the payment methods, the data required for payment processing will be transmitted to the respective payment service provider. This covers basic identifying information such as your name and address, financial details such as account or credit card numbers, security credentials such as passwords, TANs, and checksums, and details relating to the underlying contract, the payment amount, and the recipient. All of this is required in order for the transaction to be carried out and therefore this data processing is carried out on the basis of Article 6 para. 1 sentence 1 lit. b GDPR. The terms and conditions and privacy notice of the specific payment service provider involved, each of which can be accessed on that provider's own website or within its transaction application. We refer you to those same documents for further information and for exercising your right of withdrawal, your right of access, and your other data subject rights.
|
|
Professional advisers |
Our professional advisers act as processors or joint controllers. This includes lawyers, bankers, auditors and insurers based within the EU who provide consultancy, banking, legal, insurance and accounting services.
|
|
|
Google Ireland Limited |
Google Ireland Limited is a company incorporated and registered in Ireland at Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). We use analytic services provided by Google in the management of our website and our app.
|
To design our website and app in line with users' needs and to continuously improve it, we also use "Google Analytics" on the basis of your consent. Google Analytics is a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Among other things, Google Analytics uses so-called "cookies" (text files) and similar technologies that are stored on your device and allow your use of the website to be analysed. This information is used to evaluate your use of the website/app, to compile reports on website and app activity, and to optimise the delivery of advertising. Once we have transmitted the data to Google Ireland Limited, it is processed by Google as the sole controller under data protection law. In this context, Google Ireland Limited, acting as the sole controller, may store data about you in the USA. With regard to the USA, the European Court of Justice has found it to be a country that does not provide an adequate level of data protection. In particular, there is a risk in this context that your data may be processed by US institutions or authorities for monitoring and surveillance purposes, without you having any adequate legal remedy available against this. On 10 July 2023, the European Commission adopted its adequacy decision for the "EU-U.S. Data Privacy Framework." This means that, for transfers made on the basis of this agreement, the European Commission regards the level of data protection in the USA as comparable to that within the EU and therefore as safe. Google is certified under this framework and relies on it for any transfer of data to the USA. The legal basis for this data processing is Article 6(1)(a) GDPR (consent). You can find further information on Google Analytics, as well as Google's privacy policy, here. You can withdraw the consent you have given for the use of Google Analytics here using the cookie widget located in the bottom left of the website. |
We may also share your personal data with other third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
Further, we may need to disclose your information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use, or to protect the rights, property or safety of our business, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
We will take all reasonable steps to ensure that third parties respect the security of your personal data and 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.
7. International Transfers
Some of the third parties identified in section 6 above are based outside the EU or have a group or affiliated companies based outside of the EU, so their processing of your personal data may involve a transfer of data outside the EU.
Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use EU Standard Contractual Clauses (https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_de)
Please contact us using the details set out in section 1 if you want further information on the specific mechanism used by us when transferring your personal data out of the EU..
8. Data Security
All information you provide to us is stored on our secure servers.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website and/or our app, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.
Certain services may include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
The transmission of unencrypted (or inadequately encrypted) data over the Internet is inherently insecure, and for this reason, we cannot guarantee the security of data sent between us over the Internet.
9. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including 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 with 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 unauthorised 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.
In some circumstances, 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.
In some circumstances, you can also ask us to delete your data: see section 10 for further information.
In the event that you create an account on our website and/or our app and do not use the account for a period of one (1) year, then we will treat the account as expired, and your personal data may be deleted.
10. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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 to the processing of 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 restriction of the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information for 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.
To exercise any of these rights, please contact us (using the details set out in section 1).
Pursuant to Art. 77 GDPR, you may lodge a complaint with a supervisory authority. Generally, you can contact the supervisory authority for your habitual residence, place of work or the registered office of our company.
No fee is usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested 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 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.
