WEBSITE PRIVACY NOTICE OF
Nothing Else Matters Inc., a company with limited liability; updated: May 24, 2018
OUR PRIVACY PROMISE
We promise to collect, use and store your personal data in a safe and secure way. We promise to only use your personal data for the specific purposes stated. We promise to keep you informed about how we use your information and who we give it to.
INFORMATION ON PROCESSING OF PERSONAL DATA
Nothing Else Matters Inc., having its registered place of business at Avondale House, Bank Hall, St Michael, Barbados, registered under number 37114 (hereinafter referred to as “NEM”), is an operator of personal data according to Chapter I, Article 4 par. 7 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/ES (General Data Protection Regulation) (hereinafter referred to as “GDPR”).
Accurate and legal processing of your personal data is a priority for NEM. We adhere to our internal policies, which are aligned to industry standards to protect your personal data.
For this reason, we wish to provide you with information about the reasons for processing your personal data, why we process your personal data, as well as your legal rights related to processing of your personal data and further information we consider being important with regard to processing of personal data. In this document we would like to ask you to read the question and answer detailed below in order to enable you a better overview of how we will protect your data.
In case of any uncertainties or unclear points in this document, we will be happy to clarify any or all parts of this document. Please do not hesitate to contact us via e-mail: email@example.com.
WHO IS THE OPERATOR OF YOUR PERSONAL DATA?
The operator of your personal data is a company, which has been provided with personal data.
The operator of your personal data is a company Nothing Else Matters Inc., having its registered place of business at Avondale House, Bank Hall, St Michael, Barbados, registered under number 37114.
The company defines purposes and means of processing of personal data.
NEM obtains, collects, stores and operates your personal data, i.e. the company is accountable for processing of your personal data in compliance with the Law. You are entitled to exercise your rights with regard to processing of personal data against NEM. Details about your rights can be found under the title ”What are your rights in connection to processing of your personal dataʺ.
WHY YOUR PERSONAL DATA IS PROCESSED BY NEM?
Applying its strict observation of its duties arising from the Law und protecting the entitled interests of the company, NEM only processes the personal data necessary to provide you with the company´s services, products and customer support.
We do collect personal data of our clients, as well as potential clients, who are interested in services delivered by our company, or who have agreed to be provided with propositions on products and services of our company.
NEM processes the following categories of personal data:
Basic identification data – are given in each contract you have entered into with us. The data are, e.g. your name and surname, date of birth, address of residence, nationality, your picture and signature. If you are a free-lancer, your ID-No. and place of business.
Contact details – are your e-mail address, phone number and your postal address.
Information about utilisation of products and services of NEM – it is a note about products of our company you have (already) used, and on this basis, we can recommend you another suitable product or other suitable services provided by our company.
Information from telephone calls or other communications with you, e.g. via e-mail, SMS or social networks.
Geo localization data – come from your internet browser on the PC.
Transaction data – mean payment data.
TO WHAT PURPOSE ARE YOUR PERSONAL DATA PROCESSED BY NEM?
Processing based on the contract
Your personal data is processed by us for the purpose of contracts entered into by our company. In this regard, your personal data is processed by us during the negotiation on entering into or changing the contract. Your personal data is exclusively processed to the extent required to enter into and to fulfil the contract, whereby this especially covers consultancies, negotiations on contractual relationship and the process of contracting, as well as the administration of the contract and keeping records of participants of contractual relations. In this regard, we process all data given in the relevant contracts or order forms. We also wish to inform you that you provide us with your personal data for the above purpose in a fully voluntary manner; however, your personal data is necessary for entering into and fulfilling the contract. Should the personal data be absent, entering into and fulfilling the contract, as well as enforcement of rights and duties arising from such contract, would be disabled.
Processing based on the entitled rights of NEM
NEM is entitled to inform you about news and to present you services and products of NEM, as well as to defend possible legal claims of NEM.
Processing of personal data based on your consent
Processing for marketing purposes – If you grant your consent to our company, we process your personal data for marketing purposes as well. Marketing especially covers the proposition of products and services of NEM, as well as of partners of our company. Based on your consent, we can send you such propositions by e-mails and messages sent to your mobile appliances, as well as via possible mobile applications of our company, as well as per post or per telephone call. In this regard, we also use the automated processing of personal data with the aim to adapt our business proposition to your specific needs. Market surveys and satisfaction surveys are also covered by the marketing. In this regard, we wish to inform you, that it is your decision whether you agree to our processing of personal data for marketing purposes or not. Please note that we cannot send you individual propositions of products and services of NEM and business partners of our company without your consent. If you make a contract with our company, you agree to our processing of your personal data for marketing purposes during the whole period of duration of your contractual liability to our company and the following five (5) years after your contractual liability will have expired, or until your withdrawal of your consent. You are entitled to fully or partially withdraw your consent to our processing of personal data for marketing purposes. Details on withdrawing the consent to processing of personal data for marketing purposes are given in the Article of this Information, under the title of “How can you withdraw your consent to processing of your personal data for marketing purposes you´ve granted to NEM?ʺ.
HOW LONG ARE YOUR PERSONAL DATA STORED BY NEM?
Processing of personal data, NEM consequently applies the minimization principle. It means that after the processing and storage period of your personal data has expired, we anonymize your personal data in our information databases and in our information systems.
We store your personal data during the period of duration of your contractual relationship with our company in order to provide you with our services and to fulfil the commitments arising for us from the contract.
If you entered into a contract with NEM, you have granted us your consent to our processing of your personal data for marketing purposes. Your consent is valid during the period of duration of the contractual relationship with our company and the following five (5) years after the contractual relationship will have expired, or until the time when you withdraw your consent to our processing of your personal data for marketing purposes.
If you entered into no contract with NEM but you exclusively granted us your consent to our processing of your personal data for marketing purposes, your consent is valid for the next five (5) years after you have granted it, or until the time when you withdraw your consent to our processing of your personal data for marketing purposes.
WHERE DOES NEM GET YOUR PERSONAL DATA FROM?
NEM gets personal data from the following resources:
– Directly from you when entering into a contract and during the period of duration of the contractual relationship, as well as in the period of fulfilling the rights and duties arising from such contract;
– Publicly accessible registers, lists, records or websites (e.g. Commercial Registry, Trade Register, publicly available social networks, etc.);
– Third persons which are entitled to treat your personal data.
Your consent to processing of personal data for marketing purposes is voluntary and you can withdraw your consent anytime. If you prefer not to get news of products and services of NEM and our business partners, we fully accept and respect your decision.
HOW CAN YOU WITHDRAW YOUR CONSENT TO PROCESSING OF YOUR PERSONAL DATA FOR MARKETING PURPOSES YOU´VE GRANTED TO NEM?
Your consent to processing of personal data for marketing purposes is voluntary and you can withdraw your consent at anytime. If you prefer not to get news of products and services of NEM and our business partners, we fully accept and respect your decision, although we feel sorry about it.
What details and facts must be given in your consent for withdrawal? For consent withdrawal we need your identify.
How can I deliver my withdrawal of consent to your company? You can use opt-out directly in our distributed marketing materials (newsletters.
WHAT ARE YOUR RIGHTS IN CONNECTION TO PROCESSING OF PERSONAL DATA?
Legal processing of your personal data is for us absolutely secure. Protection of your personal data is of the upmost importance and a key concern of our company. With regard to processing of personal data, you can exert the following rights:
Information on processing of your personal data
The information contains identity and contact details of the operator, his/her proxy or even a person accountable for the protection of personal data if applicable, as well as purposes of processing of personal data, categories of personal data processed, recipients or categories of recipients of personal data, information about transfer of personal data to third parties, period of keeping personal data, entitled operators, the list of your rights as far as processing of personal data is considered, a possibility to turn to the Office For Personal Data Protection, resources of personal data processed, as well as whether automatized decision-making and profiling are made or not.
Right to access personal data
You have the right to be notified whether your personal data is processed or not. If they are processed, you have the right to access information and to learn the purpose of their processing, categories of personal data affected, their recipients or categories of recipients, the period of keeping your personal data, the information of your rights with regard to processing of personal data, whether or not automatized decision-making and profiling are made, as well as guarantees in the case that personal data is transferred to a third party or to an international organization. You also have the right to get a copy of personal data processed.
Right of correction
Should NEM process your personal data which are obsolete or incorrect (e.g. due to a change of your residence), kindly let us know and will amend your personal data.
Right to erasure (right to be forgotten)
According to the law, we are obliged in some cases to erase your personal data under your direction. Each application of this kind is a subject to an individual assessment, whether or not all conditions for erasure have been fulfilled, as NEM can have either a duty or an entitled interest of higher importance to keep your personal data.
Right to restrict processing
If you wish to have your data exclusively processed by us for legal reason, or if you wish us to block your personal data.
Right to transferability of data
If you wish to provide another operator, another company with your personal data, we will give your personal data and in the form you have determined to the entity, provided that no legal or any other significant obstacles will not preclude us from doing so.
Right to raise an objection and automatized individual decision-making
If you state or if you are of the opinion that our processing of your personal data is contrary to the protection of your private and personal life or contrary to generally valid legal rules and regulations, please contact our company and ask for an explanation or removal of the undesired status quo. You can also object to automatized decision-making.
Right to object or to lodge a complaint with the Office For Personal Data Protection
You can lodge your complaint or objection against processing of personal data to the supervisory body.
WHERE CAN YOU EXERCISE YOUR RIGHTS AND ARE THERE ANY CHARGES FOR ENFORCEMENT OF RIGHTS?
You can directly contact NEM by an e-mail addressed to: firstname.lastname@example.org. No information and explanations of rights exercised are charged by NEM. When can I get the answer from NEM? We will send you the statement of our company, as well as some information about measures adopted, as soon as possible but not later than within a month. We are entitled to prolong the period required for our statement by two months due to the complexity and number of claims. We will let you know any delay of the period, as well as the reason for doing so.