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August 2022
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Data Protection

Right To Basic Information

Data subjects have the right to understand who the Company and its affiliates are, and why and how it or they process personal data. The right to basic information includes, without limitations, the right to know the identity of the data controller, the reasons and grounds for processing personal data, and any other information necessary to ensure the fair and transparent processing of personal data.

Right Of Access To Personal Data

Data subjects have a right to obtain confirmation from the Company that it processes certain personal data related to a data subject and a right to obtain a copy of that information, along with other details about how and why the Company uses the data subject’s information. Once the veracity and appropriateness of an access request is affirmatively determined by the Company, we will, within the period required by the law, provide you with: confirmation of processing, the copy of the personal data or a description of the personal data and categories of data processed, the purpose for which such data is being held and processed, and details about the source of the personal data if not provided by the data subject.

Right To Rectification

The data subject has the right to obtain from us the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of processing, the data subject has the right to have incomplete personal data completed including by means of providing supplementary statement. In addition, if the Company has passed on incorrect information about a data subject to a third party, the data subject also has a right to oblige the Company to inform those third parties that this information should be updated.

Right To Erasure

Data subjects have a right to require the Company to erase certain personal data if particular conditions are satisfied. The Company is legally obligated to comply with a request to delete personal data if:

  • the data is no longer needed for the original purpose and no new lawful purpose exists for continued processing;
  • the lawful basis for processing is consent of the data subject and such consent is withdrawn;
  • the data subject exercises his or her right to object to the Company’s processing of his or her personal data, and the Company has no overriding grounds for processing the data;
  • the personal data is processed unlawfully; or erasure of the data is necessary to comply with applicable laws.

In addition, if the Company has passed on personal data to a third party, a data subject also has a right to oblige the Company to tell those third parties that the information should be erased. The right to erasure is not absolute. Even if a data subject falls into one of the categories described above, the Company is entitled to reject the data subject’s request and continue processing data if such processing is:

  • necessary to comply with legal obligations;
  • necessary to establish, exercise or defend legal claims; or
  • is necessary for scientific, etc. all subject to applicable laws.

Right To Restriction of Processing

In the event the Company processes personal data on the basis that it is in its legitimate interests to do so (i.e., direct marketing), a data subject has the right to object to our processing on such grounds. Notwithstanding the receipt of such an objection, the Company shall be permitted to continue processing a data subject’s personal data if:

  • the Company has compelling legitimate grounds for processing the information which overrides the rights, interests and freedoms of the data subject; or
  • the data is necessary to establish, exercise or defend a legal claim or right, etc. all subject to applicable laws and regulations.

Right To Notification

We shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with GDPR to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We shall inform the data subject about those recipients if the data subject requests such information.

Right To Data Portability

A data subject can request that we transmit its personal data to another entity. Portability rights only apply if the data in question was provided by the data subject to the Company, processed automatically, and is processed on the legal bases of either consent or fulfilment of a contract. That right shall not apply to processing necessary for the performance of a task carried in the public interest or in the exercise of official authority.

Right To Object

We may send you marketing communications via e-mail or other electronic methods. Where we process personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.