Privacy Policy

last updated June 2025

Data Subject Rights (continued)

If any of the reasons mentioned previously apply, a data subject may request the erasure of personal data stored by us at any time. Any employee of the controller can be contacted to ensure that the erasure request is fulfilled without delay.

Where personal data has been made public and erasure is required, we will take reasonable steps—considering available technology and implementation cost—to inform other controllers of the data subject's request to erase any links to, or copies of, the data. An employee will handle such measures in each case.

Right of Restriction of Processing

Data subjects have the right to request restriction of processing where one of the following applies:

- The accuracy of personal data is contested by the data subject, allowing time for verification.

- The processing is unlawful, and the data subject prefers restriction to erasure.

- The controller no longer needs the data, but the data subject requires it for legal claims.

- The data subject has objected to processing, pending verification of overriding legitimate grounds.

If any of these conditions apply, the data subject may contact an employee to request restriction.

Right to Data Portability

Data subjects have the right to receive their personal data in a structured, commonly used, machine-readable format and transmit it to another controller, provided the processing is based on consent or contract and carried out by automated means.

Where feasible, personal data may be transmitted directly from one controller to another. To assert this right, a data subject can contact any employee.

Right to Object

Data subjects have the right to object at any time to the processing of their personal data on grounds relating to their particular situation, especially when processing is based on Article 6(1)(e) or (f) of the GDPR, including profiling.

If personal data is processed for direct marketing, the data subject may object at any time, and the data will no longer be used for that purpose.

Objection is also allowed regarding scientific, historical, or statistical research unless necessary for public interest. To exercise this right, the data subject may contact any employee or use automated means where applicable.

Automated Individual Decision-Making, Including Profiling

Data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, that significantly affects them, unless the decision is:

- Necessary for a contract,

- Authorised by law with safeguards, or

- Based on explicit consent.

In such cases, suitable measures will be in place to safeguard rights and allow human intervention. To exercise this right, contact any employee.

Right to Withdraw Consent

Data subjects have the right to withdraw their consent to personal data processing at any time. Contact any employee to withdraw consent.

Legal Basis for Processing

- Article 6(1)(a): Consent-based processing.

- Article 6(1)(b): Contractual necessity.

- Article 6(1)(c): Legal obligations.

- Article 6(1)(d): Vital interests (e.g., medical emergencies).

- Article 6(1)(f): Legitimate interests not overridden by data subject rights (e.g., client relationships).

Data Retention and Deletion

Personal data will be stored only as long as necessary for the intended purpose or required by law. When the purpose or legal retention period ends, the data will be blocked or deleted.

Legitimate Interests

Our legitimate interest, when processing under Article 6(1)(f), is to conduct business in a way that benefits our employees and shareholders.

Data Storage Period

The retention period is based on statutory requirements. After this period, data is deleted unless needed for contract performance or initiation.

Data Provision Requirements

Providing personal data may be a legal or contractual requirement, or necessary to enter into a contract. Failure to provide required data may prevent contract completion.

Employees are available to clarify whether data provision is required, and the consequences of non-provision.

PayPal Payment Processing

We use PayPal as a payment processor. When a user selects PayPal, necessary personal data (e.g., name, address, email, phone number) is transmitted to PayPal for payment and fraud prevention.

PayPal may transmit data to credit agencies for identity and creditworthiness checks and may share data with affiliates or service providers to fulfill its duties.

Consent to this processing can be revoked with PayPal at any time. However, revocation does not affect data required for contractual processing.

PayPal’s privacy policy: https://www.paypal.com/us/webapps/mpp/ua/privacy-full

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