GDPR Data Privacy Notice

Based on REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (General Data Protection Regulation/GDPR)

 

I. Scope

This Policy applies to the collection and processing of personal data of users and customers on our website: http://www.squaretalk.com/ (hereinafter referred to as the “website”). 

II. What information we collect for you on the website? 

In the process of using / visiting our website, we collect and process various types of technical data (this information does not personally identify you), such as the IP address used to connect your computer to the Internet, the information from the browser / website you visited before visiting our website or the website you are going to when you leave our website, type and version of the browser, type and version of browser plug-in, log-in information, operating system, device type, brand of computer / mobile device. We can also keep the pages of the website you are visiting and how much time you spend on each page. This data may be collected and processed on our behalf from third-party cookies. We may also use Webbita cookies. “Cookies” are small pieces / pieces of information written on our hard disk by our web server. Many internet browsers are automatically set to accept cookies. You can change your browser settings to reject cookies or let you know when a cookie will be placed on your computer. Rejecting cookies while using the website, however, may result in malfunctions of certain parts of the website or not as effectively as they are permitted.

Every time you visit our website, we also automatically collect the following data: data about your visits, URL, information about activities performed through and from the website (including date and time), information you have viewed or searched (including most visited content and categories, page response time, loading errors, visit duration of certain pages, including average duration of time spent on specific pages, viewing specific content or type), page activity information (such as review, click, move the cursor), methods used to divulge page entry, user behavior data. This includes information provided by you when registering on the website, using a service / functionality on the website, completing any form of participation, comments or other activity on the website, participating in a promotion or answering a question (s), etc. ., and when reporting a problem with our website. The information you provide us may include name, address, email address, phone number, photo, age. In some cases, we receive your personal information from third parties, for example from a social network, if you voluntarily opted in to access our website via the appropriate social networking platform.

 

Personal data collected when registering on the website:

SQUARETALK collects different types of personal data from clients and visitors who register on the website, such as names, phone numbers, addresses, and email addresses. This information is required to verify your identity, to set up your account and to set up your service. By registering on the website, you allow us to communicate with you about your account using the personal information you provide.

We do not collect and process “sensitive” personal information related to you, such as religion or ethnicity, political opinions, health, sexual orientation, etc.

When you voluntarily and without our request using our website voluntarily provided us with personal data, including “sensitive” personal data, for example by commenting on our website, we will delete that data from our systems if we consider that processing them do not meet the purposes for which data is being processed or there is not a legitimate purpose.

We do not collect and process customer credit card information. Credit card processing is performed by non-affiliated (third party) credit card processing companies. These unrelated credit card processing companies may or may not store your credit card information for your convenience. Please see the relevant privacy policy or general terms for these companies for more details.

 

III. On what legal basis and how we process your data

We process your data in order to effectively use our website to provide the services you require (for different technical, administrative and operational reasons); to comply with and fulfill our statutory or contractual obligation under a contract that you, as a user of the website, are a party to; when it is necessary for our (or third party) legitimate interest (e.g, to detect and prevent fraud or to provide IT security) unless your interests and fundamental rights and freedoms take precedence over such interests; when it is necessary to protect your vital interests (or the vital interests of another); and / or when this is necessary in the public interest or for the exercise of official authority.

We process your personal information to ensure that its content is presented in the most effective way for you and your device; to improve the website, including its functionality; to administer the website; for internal operations, including troubleshooting and technical problems, data analysis, tests, research, statistical purposes and studies; for advertising and marketing to provide content that may be of greater interest to you; and as part of our efforts to keep our website safe and secure.

In cases where, when using the website, we process your data on your explicit and specifically informed consent, you can also withdraw it by sending a message to our email address: privacy@squaretalk.com However, the withdrawal of consent will not affect the lawfulness of data processing based on previously agreed consent.

 

IV. To whom do we disclose your personal data?

We do not sell or distribute your personal data to third parties without your explicit consent.

Your personal data may be disclosed to third parties such as: 

(a) providers providing us with administrative, professional and / or technical services to provide information technology (IT), security and business resource support;

(b) business partners, suppliers and sub-contractors we use to perform a contract with you, incl. subscription to our services, e.g. lawyers, accountants, auditors;

(c) advertisers and advertising networks that require information about you to choose and offer you an appropriate advertising. We do not disclose to our advertisers any personally identifiable information, but we provide aggregate information to our users. We can also use such aggregated information to help advertisers reach a particular audience. To that end, we can use the information you collect to be able to show our advertisers’ advertising to the target audience they want;

(d) analytical service providers and search engines that help us improve and optimize our website.

When selecting third-party service providers, we perform due diligence and require these suppliers to maintain adequate technical and organizational measures to protect personal data and process personal data only in accordance with the instructions of SQUARETALK. Service providers may use subcontractors in the provision of services only provided that SQUARETALK. has given prior written consent to this and subcontractors comply with the same data protection obligations as the supplier.

Your personal data may also be provided to government and / or law enforcement authorities if required by applicable law or if necessary for the exercise of our rights and / or the protection of our legitimate interests, in accordance with applicable law. 

In some cases and subject to the “need to know” principle, we may disclose your personal data to affiliated persons (including our subsidiaries, SquareTalk Ltd. and its subsidiaries). With these affiliated persons, we apply and comply with appropriate privacy policies to ensure the security of personal data.

With our affiliates and with third parties, we may share your personal data on a particular type of transaction, such as transactions that result in a change in company control, business restructuring, etc., including the transfer, merger, or conversion of a portion or all our assets from the company.

Within our organization, subject to the need-to-know principle, each employee has authorized access to your personal information. These employees have a duty to keep personal data confidential. Appropriate technical and organizational measures for the protection of personal data have also been taken. The members of our team handle personal data whenever necessary in connection with the execution of their tasks and according to the instructions of the Controller SQUARETALK.

We do not transfer / transfer to third parties (outside the European Union (“EU”) and the European Economic Area (“EEA”) your personal data. However, information collected through cookies (e.g., through the advertising serving platform) is typically provided by a data center closest to where the traffic is generated. This means that such information, incl. advertising traffic may be managed by servers located in the EEA and can be transmitted outside the EEA.

VI. Term of storage of your personal data

We store the information about your personal data only to the extent necessary to achieve the objectives listed in this Policy and / or the requirements of the applicable legislation in this area.

When processing your personal data by consent, such personal data will be processed only for the period for which your consent was given unless you have withdrawn or restricted your consent before the expiration of that period. In such cases, we will discontinue the processing of the personal data concerned for the purposes in question, subject to legal obligations regarding the processing of personal data and / or obligations arising from the need to process such personal data in order to fulfill our legitimate rights.

VII. Data security

We use appropriate technical and organizational measures to store your data on our servers, which aim to protect your personal data and prevent unauthorized access to them. 

However, the responsibility for the confidentiality of all authentication tools you use to access our website (such as sign-in and passwords) is yours. We are not responsible for unauthorized access to such information by third parties. If you have a website account, it is your responsibility to protect your login information and password.

Although we will do our best to protect your data, data transmission over the Internet is not completely secure, every data transfer is at your own risk. Once we receive your data, we will apply strict security procedures and functionality to prevent unauthorized access.

VIII. Links to other websites

Our website may contain links to other websites that are subject to different privacy policies. If you visit any of these websites, you should review their privacy policy. This Policy does not apply to the use of other websites. SQUARETALK does not exercise control and is not responsible for the use of other websites or for the practices of collecting and using data from other websites.

IX. Cookies and social networks

Our website may use cookies to distinguish you from other users of the website. This helps us provide you with a nice look at our website and also allows us to improve our website. The processing is based on your consent expressed on our website or through your browser settings.

Our website may include social media and networking features such as button for Facebook, LinkedIn or Youtube. These functionalities can collect information about you, such as. IP addresses and websites you visit, and activate a cookie to properly set up the functionality. The processing of information through the interaction with these functionalities is governed by the privacy policy of the company providing the functionality.

X. Your rights 

You may request a confirmation from us that your personal data is processed by us or not, and what personal data is processed (right to information), request a copy of your personal data (access right) and / or request corrections. Under certain circumstances, you have the right to require us to delete your personal data or, on the basis of the portability right, to request that we transmit some of your personal data to you or others. In addition, you have the right to object to the processing of your personal data (for example, when using and processing for direct marketing purposes, or in the event that some solutions are made only by automatic processing (including profiling).) When we ask for your consent to processing personal You have the right to object also when processing your personal data on our legitimate interest (as explained above). Also, you are entitled, under certain circumstances, to withdraw this consent without undue impact. You have the right to complain to the relevant data protection authorities. You can file a complaint in the Member State where you reside, where you work or where an alleged breach of a defense law has occurred of the data.

If you wish to exercise these rights, you may contact us at our email. 

We may update this Privacy Policy, to which we will notify you by posting the new website policies. If you have provided us with your contact details and have given us the right to contact you, we may notify you of a substantial change to the Policy. Please review these policies periodically for future changes.

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