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This policy sets out our policy on the privacy of the individual. This website is not intended for children and we do not knowingly collect data relating to children unless a parent or guardian has given consent on behalf of the child. If you are under the age of 18 you should request that your parent or guardian gives their consent. It is important that you read this privacy notice 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 privacy notice supplements the other notices and is not intended to override them. Business Process Technologies LP is the controller and responsible for your personal data. We have appointed a data protection officer DPO who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. Postal address: Street: Queen Street No. We would, however, appreciate the chance to deal with your concerns before you approach the EDPS so please contact us in the first instance. 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. Your use of this website signifies your consent to us collecting and using personal data about you as specified below in accordance with this policy statement. Should we choose to change these terms for any reason, the changes will be posted here so that you are always kept informed about the collection and use of your personal information, and when we disclose it. 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. 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. You are notified that Google Ireland Limited will be the data controller responsible for information and for complying with applicable privacy laws. Google Privacy Policy can be found here. We implement Pseudonymisation for physical or mental health conditions, biometric data which is considered to be Sensitive Personal Data so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure. Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences; 4. Transaction Data includes details about payments to and from you and other details of services you have purchased from us; 4. We do not collect Financial Data which includes bank account and payment card details; 4. Contact Data includes billing address, delivery address, email address and telephone numbers; 4. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender; 4. We use different methods to collect data from and about you including through: 5. Direct interactions. You may give us your Identity, Contact by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you: 5. We will only use your personal data when the Data Protection Requirements allows us to. Most commonly, we will use your personal data in the following circumstances: 6. Where we need to perform the contract we are about to enter into or have entered into with you; 6. 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; 6. Where we need to comply with a legal or regulatory obligation. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. We may to use your personal data to: 7. 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. Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us 7. 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 will receive marketing communications from us if you have requested information from us and 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 for marketing purposes. Opting out 7. Change of purpose 7. 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 the Data Protection Requirements. We may have to share your personal data with 8. The personal data disclosed to third parties may: 8. 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 privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the Data Protection Requirements. 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. Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries; 9. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. It is normally sent by a web server to you and enables the server to collect information back from your site visit. 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. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. In some circumstances you can ask us to delete your data: see \\\\\\\\\\\\\\[Request erasure\\\\\\\\\\\\\\] below for further information. Under certain circumstances, you have rights under Data Protection Requirements in relation to your personal data. 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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 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. We try to respond to all legitimate requests within one month. Occasionally it may 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. Request access to your personal data. 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 continuing 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 restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following cases: 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. Настоящие Условия распространяются на любой доступ и использование нашего веб-сайта webwellness. Используя наш Сервис на webwellness. Если вы не согласны с настоящими Условиями использования, не переходите к дальнейшей информации. Устройства не являются медицинскими; программное обеспечение не имеет медицинского предназначения. Предоставленная информация основана на множестве биорезонансных маркеров и является только частью более полной картины. Могут быть и другие непроверенные причины, факторы окружающей среды, различия в образе жизни и проявления, которые являются важными прогнозируемыми аспектами в отчете. Прежде чем вносить какие-либо изменения в вашу терапию, диету или образ жизни, вы должны сначала проконсультироваться с квалифицированным врачом, терапевтом или соответствующим специалистом. Если вы считаете, что вам может потребоваться экстренная помощь, вы должны обратиться к своему врачу или в скорую помощь, полицию или пожарную службу. Ничто в этом пункте не влияет на ваши законные права как потребителя. Приведенные положения и рекомендации не были рассмотрены Управлением по по надзору за качеством пищевых продуктов и медикаментов, и не предназначены для диагностики, лечения или предотвращения заболеваний. Предполагается, что пользователь, как получатель первичной медицинской помощи, будет консультироваться или обращаться к сертифицированному медицинскому специалисту если сочтет это необходимым. Business Process Technologies LP About this document An internal-facing Data Protection Policy for use by a business setting out the principles and legal conditions that organisations must satisfy when obtaining, handling, processing, transporting or storing personal data in the course of their operations and activities, including customer, supplier and employee data Data Protection Policy. Automated Decision-Making ADM : when a decision is made which is based solely on Automated Processing including profiling which produces legal effects or significantly affects an individual. Profiling is an example of Automated Processing. Company name : Business Process Technologies LP Company Personnel : all employees, workers, contractors, agency workers, consultants, directors, members and others. Data Controller : the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Data Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes. Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programs involving the Processing of Personal Data. Explicit Consent : consent which requires a very clear and specific statement that is, not just action. Personal Data : any information identifying a Data Subject or information relating to a Data Subject that we can identify directly or indirectly from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Sensitive Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal Data Breach : any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach. Privacy by Design : implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR. Privacy Notices also referred to as Fair Processing Notices or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific gro Processing or Process : any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties. Pseudonymisation or Pseudonymised : replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure. Sensitive Personal Data : information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions. The Company also considers the following types of data to be Sensitive Personal Data: safeguarding, behaviour and sanctions data. This Data Protection Policy sets out how Business Process Technologies LP 'we', 'our', 'us', 'the Company' handle the Personal Data of our customers, suppliers, employees, workers and other third parties. This Data Protection Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject. This Data Protection Policy sets out what we expect from you in order for the Company to comply with applicable law. Your compliance with this Data Protection Policy is mandatory. Related Policies and Privacy Guidelines are available to help you interpret and act in accordance with this Data Protection Policy. You must also comply with all such Related Policies and Privacy Guidelines. Any breach of this Data Protection Policy may result in disciplinary action. This Data Protection Policy Policy together with Related Policies and Privacy Guidelines is an internal document and cannot be shared with third parties, clients or regulators without prior authorisation from the DPO. We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. All Directors, HODs, and Employees, are responsible for ensuring all Company Personnel comply with this Data Protection Policy Policy and need to implement appropriate practices, processes, controls and training to ensure such compliance. In particular, you must always contact the DPO in the following circumstances:. If you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making see section \\\\\\\\\\\\\\[ If you need help complying with applicable law when carrying out direct marketing activities see section \\\\\\\\\\\\\\[ Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed Data Minimisation. Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed Storage Limitation. Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage Security, Integrity and Confidentiality. Not transferred to another country without appropriate safeguards being in place Transfer Limitation. We are responsible for and must be able to demonstrate compliance with the Data Protection Policy principles listed above Accountability. Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject. You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. These restrictions are not intended to prevent Processing, but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices or Fair Processing Notices;. A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters. Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented. Unless we can rely on another legal basis of Processing, Explicit Consent is usually required for Processing Sensitive Personal Data, for Automated Decision-Making and for cross border data transfers. Usually we will be relying on another legal basis and not require Explicit Consent to Process most types of Sensitive Data. You will need to evidence Consent captured and keep records of all Consents so that the Company can demonstrate compliance with Consent requirements. The GDPR requires Data Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. Such information must be provided through appropriate Privacy Notices or Fair Processing Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them. Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the GDPR including the identity of the Data Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Fair Processing Notice which must be presented when the Data Subject first provides the Personal Data.. You must also check that the Personal Data was collected by the third party in accordance with the GDPR and on a basis which contemplates our proposed Processing of that Personal Data. Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes. You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary. Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed. You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties. You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes. Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate. You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data. Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed. You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements. The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time. This includes requiring third parties to delete such data where applicable. You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice or Fair Processing Notice. Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage. We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks including use of encryption and Pseudonymisation where applicable. We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must exercise particular care in protecting Sensitive Personal Data from loss and unauthorised access, use or disclosure. You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested. You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as Follows:. Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it. Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed. Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes. You must comply with all applicable aspects of our Record of Processing Activity Log and Company Communications policy and comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the GDPR and relevant standards to protect Personal Data. We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so. If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. You should preserve all evidence relating to the potential Personal Data Breach. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country. You must verify the identity of an individual requesting data under any of the rights listed above do not allow third parties to persuade you into disclosing Personal Data without proper authorisation. You must immediately forward any Data Subject request you receive to the line Manager who in turn will address action required with the DPO. The Data Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with Data Protection Policy principles. The Data Controller is responsible for, and must be able to demonstrate, compliance with the Data Protection Policy principles. The Company must have adequate resources and controls in place to ensure and to document GDPR compliance including:. The Company must maintain a record of training attendance by Company Personnel; and. These records should include, at a minimum, the name and contact details of the Data Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data retention period and a description of the security measures in place. In order to create such records, data maps should be created which should include the detail set out above together with appropriate data flows. We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance. You must undergo all mandatory data privacy related training and ensure your team undergo similar mandatory training. You must regularly review all the systems and processes under your control to ensure they comply with this Data Protection Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data. We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures like Pseudonymisation in an effective manner, to ensure compliance with data privacy principles. Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:. If certain types of Sensitive Data are being processed, then grounds b or c will not be allowed but such Sensitive Data can be Processed where it is necessary unless less intrusive means can be used for substantial public interest like fraud prevention. If a decision is to be based solely on Automated Processing including profiling , then Data Subjects must be informed when you first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. We must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision. We are subject to certain rules and privacy laws when marketing to our customers. The limited exception for existing customers known as 'soft opt in' allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message. The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future. Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place. You may only share the Personal Data we hold with another employee, agent or representative of our group which includes our subsidiaries and our ultimate holding company along with its subsidiaries if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions. You may only share the Personal Data we hold with third parties, such as our service providers if:. We reserve the right to change this Data Protection Policy at any time without notice to you so please check back regularly to obtain the latest copy of this Data Protection Policy. This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where the Company operates. Certain countries may have localised variances to this Data Protection Policy which are available upon request to the DPO. WEB Wellness. Авторизация в программе. WebWellness Privacy Policy. Запомнить меня. Не помню пароль. Data security 3. The data we collect about you 4. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: 4. How do we collect personal information about you and how is it used? How we use your personal data 6. Purposes for which we will use your Personal Data 7. Disclosure of your Personal Data 8. International transfers 9. What are cookies and how do we deal with them? If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly Data retention Your legal rights Дата: E-mail: Я согласен: Имя: Подтверждаю и отправляю на e-mail. Interpretation 1. Definitions: Automated Decision-Making ADM : when a decision is made which is based solely on Automated Processing including profiling which produces legal effects or significantly affects an individual. Scope We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Collected only for specified, explicit and legitimate purposes Purpose Limitation. Accurate and where necessary kept up to date Accuracy. Lawfulness, fairness, transparency 5. Lawfulness and fairness Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices or Fair Processing Notices; You must identify and document the legal ground being relied on for each Processing activity. Transparency notifying data subjects The GDPR requires Data Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. Purpose limitation Personal Data must be collected only for specified, explicit and legitimate purposes. Data minimisation Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed. Accuracy Personal Data must be accurate and, where necessary, kept up to date. Storage limitation Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed. Security integrity and confidentiality Protecting Personal Data Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage. You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as Follows: Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it. Data Subjects have rights when it comes to how we handle their Personal Data. Accountability The Data Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with Data Protection Policy principles. The Company must maintain a record of training attendance by Company Personnel; and regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort. You should conduct a DPIA and discuss your findings with the DPO when implementing major system or business change programs involving the Processing of Personal Data including: use of new technologies programs, systems or processes , or changing technologies programs, systems or processes ; Automated Processing including profiling and ADM; large scale Processing of Sensitive Data; and large scale, systematic monitoring of a publicly accessible area. Automated Processing including profiling and Automated Decision-Making Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless: a Data Subject has Explicitly Consented; the Processing is authorised by law; or the Processing is necessary for the performance of or entering into a contract. Direct marketing We are subject to certain rules and privacy laws when marketing to our customers. Sharing Personal Data Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place. Changes to this Data Protection Policy We reserve the right to change this Data Protection Policy at any time without notice to you so please check back regularly to obtain the latest copy of this Data Protection Policy.

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