a) What law applies?
We recognize the current lack of privacy legislation in Grenada and have as such voluntarily adopted the current gold standards deriving from the EU. As such the provision of information about our use of your Personal Data is required and set out in the General Data Protection Regulation (“GDPR”). Whilst it is expected that current legislative uncertainty is to be resolved in due course, we would like to ask you to regularly check this policy for any changes.
b) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.
c) What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to explicitly consent to the processing.
d) What is processing?
"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
e) What are the legal bases of processing?
In accordance with the GDPR, we have to have at least one of the following legal bases to process your Personal Data:
Data we collect automatically
a) Log data
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.
b) Content Delivery Network
We use a Content Delivery Network (CDN) to distribute our online content. Our CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymized and then transmitted without any personal reference. Server log files include, in particular, i) details of the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, as well as v) the date, time of all page views including the amount of data transmitted. The legal basis for processing is our legitimate interest.
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
To provide our website, we use the services of GoDaddy.com, LLC, who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.
Data we collect directly
a) Contacting us
In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and contract.
For the Chat, we use of course our own technology. We usually collect the context of your chats which may also include certain Personal Data, Pictures and Locations and other information you may submit. The Personal Data collected when using our chat is to handle your request and the legal basis is both your consent and contract.
We are present on social media on the basis of our legitimate interest (Facebook, LinkedIn and Instagram). If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.
b) Booking a Demo
For booking a Demo Meeting in an easy and convenient way, we use FreeBusy. Your data from the form will be transferred to our appointment account at FreeBusy after you press the "Book appointment" button. You will then receive a confirmation email with a link to the event. Your data will be kept at FreeBusy until the purpose for storing the data no longer applies (appointment made) or you request us to delete it. FreeBusy undertakes not to pass on your data to third parties. The legal basis is your consent as well as our legitimate interest.
c) Account Registration
If you register on our website, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form. The entry of your data is encrypted so that third parties cannot read your data when it is entered. The basis for this storage is our legitimate interest in communicating with registered users and, in the case of contracts, also the storage of contract data.
d) When using our services
When using our services, you become the data controller and we become the data processor in accordance with Chapter 4 of the GDPR. Where we process your Personal Data as data processor or in other words on behalf of you, we will process the Personal Data involved in your use of our chat services in accordance with your instructions and shall use it only for the purposes agreed between you and us. For further information please refer to our Data Processing Agreement.
We process the Personal Data involved in your use of our chat services in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfillment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations.
We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.
e) Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
f) Online Payments
If you pay through our website your payment data will be processed via our payment service providers Visa and Mastercard. Payment data will solely be processed through Visa or Mastercard and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.
g) Service Notifications
By using our services, you are giving your consent to receiving notifications and messages per email. Those typically include general, profile and content information in relation to your use of our Services. Our system notifications are designed to enhance your experience. You can of course opt out from receiving notifications by following the unsubscribe instructions at the bottom of every notification e-mail sent by MailMunch on our behalf. The legal bases are to provide you with our services and your consent as well as our legitimate interest.
If you have consented to receive our newsletter, we will use your e-mail address and, if applicable, your name to send you information about promotions, services, and news, as well as for customer satisfaction surveys. You can revoke your consent to receive the newsletter or to the creation of personalized user profiles at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. Same as with the Service Notifications mentioned above, our newsletters are sent by MailMunch on our behalf.
j) When you watch our videos
On our website, we implement videos of the video portal "YouTube" of the company Google LLC. Doing so, we use the "extended data protection mode" option provided by Google. When you call up a page that has an embedded video, a connection is established to Google's servers and in the process the content is displayed on the website by notifying your browser. According to Google's information, in "extended data protection mode" your data - in particular which of our Internet pages you have visited as well as device-specific information including the IP address - is only transmitted to the YouTube server in the USA when you watch the video. By clicking on the video, you consent to this transmission.
If you are logged in to Google at the same time, this information will be assigned to your YouTube member account. You can prevent this by logging out of your YouTube account before visiting our website.
We use Google Analytics of Google LLC which means that the data collected can in principle be transmitted to a Google server in the USA, whereby the IP addresses are anonymized by means of IP anonymization so that an allocation is not possible. Google analytics places cookies. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can object to the collection and processing of this data by Google Analytics by setting an opt-out cookie that prevents the future collection of your data when you visit this website: http://tools.google.com/dlpage/gaoptout?hl=en. The legal basis for the use of Google Analytics is based on your consent.
Data processing through integration of third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services ("content").
This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.
The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:
Principles of processing Personal Data
a) Storage and Retention
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
c) Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
e) Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
f) Do Not Sell
We do not sell your Personal Data.
g) Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services including our fulfillment partners and overseas shipping forwards and , ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.
h) International Transfer
Your Rights and Privileges
a) Privacy rights
Under the GDPR, you can exercise the following rights:
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
b) Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
c) Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
d) Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection.
Changes and Questions
Wednesday, 05 April 2023