What information we collect
We collect two types of data and information from Users who access our Site.
The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your access to the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g., browser type, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. clicks, actions, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information includes:
- Contact information: The Site may provide you with the option to fill in contact information. If you choose to contact us through our Site or by any other means, you will be asked to provide us with your name, email address and phone number.
- Device Information: We may also collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) and other information which relates to your activity through the Site.
If we associate Non-personal Information with Personal Information, we will treat such information as Personal Information.
How the information is used and with whom we share the information
- Communicating with you – If you have contacted us, for any reason, we will use your information in order to further communicate with you.
- Conducting statistical and analytical purposes, intended to improve the Site.
- Providing you with our Service, including providing a personalized display of our Site;
- Storing and processing such information on our behalf;
- Performing research, technical diagnostics or analytics;
We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to:
(i) comply with any applicable law, regulation, legal process or governmental request;
(ii) enforce our policies, including investigations of potential violations thereof;
(iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
(iv) to establish or exercise our rights to defend against legal claims;
(v) prevent harm to the rights, property or safety of us, our users, yourself or any third party;
(vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
In any case we will conclude that disclosure of Personal Information is necessary, we will only disclose that portion of the Personal Information that is required in order to satisfy the basis for disclosure. We will share the Personal Information under appropriate safeguards.
Legal basis for processing
The legal basis for processing of Personal Information is the following:
- Performance of a contract, compliance with a legal obligation: It is necessary for us to process your Personal Information where it is necessary for the performance of a contract (among other things, providing you with our services) or in order for us to comply with our various legal and/or regulatory responsibilities.
- Legitimate interests: We also process your Personal Information where we deem such processing to be in our legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include:
(i) where we disclose your Personal Information to any one or more of our associate/subsidiary companies following a restructure or for internal administrative purposes;
(ii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network;
(iii) sharing personal information with our advisers and professional services providers (such as auditors).
- Consent: Our processing of your Personal Information will primarily be necessary for us to provide you with the services. However, on certain occasions we may ask for your consent to processing Personal Information. In these instances, your Personal Information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.
You may request to:
a. Receive confirmation as to whether personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
b. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
c. Request rectification of your personal information that is in our control.
d. Request erasure of your personal information.
e. Object to the processing of personal information by us.
f. Request to restrict processing of your personal information by us.
g. Lodge a complaint with a supervisory authority.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the aforementioned rights, or receive more information, please contact us at email@example.com
How long we retain the information
We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, un-used information at the earliest reasonable time.
Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Third party collection of information
Transfer of data outside the EEA or the UK
Please note that some data recipients may be located outside the EEA or the UK. In such cases we will transfer your data only to such countries as approved by the European Commission or the UK Information Commissioner’s Office as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
How we safeguard your information
The Site is intended to the use of individuals over the age of 18 In the event that we become aware that a user under the age of 18 has shared any information, we will discard such information. If have any reason to believe that a child under 16 has shared any information with us, please contact us at firstname.lastname@example.org
How to contact us
If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at email@example.com or write to:
Global Compass RO Srl
City Offices (2nd Floor)
2 Oltenitei Road