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Date : 20200918
Status : enacted
Owner : Homsy Legal
Doc-ID : DP20200918
This Policy is to inform all data subject the process of their personal data.
At any time, data subjects can address their request regarding data protection at the following address: email@example.com
Homsy Legal is the operator of its Website www.homsylegal.com. For this reason, we collect and process personal data from any individual (“you” or “data subject(s)”) using our Website and its services as described herein.
We are strongly committed to protect your data privacy and this policy seeks to ensure compliance with the EU General Data Protection Regulations (“GDPR”) and similar laws.
It describes how your personal data may be used by us and the scope and breadth of our commitment to privacy.
By registering to our Website or related sites if any (together the “Sites”), by exploring and using the Sites, by submitting information to us, by uploading or downloading data on the Sites, by interacting with us by e-mail or in context of a membership your data will be processed.
As such, you agree that we processe and use such personal data as described herein.
2 Scope of Application
This policy is applicable to:
Any user/visitor of our Website;
Any external contractors, consultants, advisors, agents, suppliers or other service providers;
External audit- and other functions, commissioned by us;
Any staff members on all levels including management, such as officers, directors, employees and affiliates, if any.
3 General Information regarding the processing of Personal Data
3.1 Your data privacy with us
We care about your privacy and want you to be confident in the way we use your personal data and other data.
We only process personal data if this is necessary to ensure proper functioning of our Sites or to provide our contents and services. The processing of our members and/or users' personal data is normally only carried out with your prior consent, except those cases where prior consent cannot be obtained for factual reasons and the processing of personal data is permitted by law.
The personal data we collect about you helps us provide the best service possible to you. It also helps us keep your personal data safe and comply with laws and regulations.
As mentioned earlier, your data may be provided and processed by registering to our Sites, by exploring and using them, by submitting information, by uploading or downloading data on these Sites, by interacting with us by e-mail.
3.3 Purpose and use
We process the personal data you provided us with for services you’d like to use and for the purpose of using the Sites.
We may use these data (i.e. any personal data that you provide, such as your name, address, email address, phone number) to tailor the visitor’s experience at our Sites. We may also use these data to inform you about updates to the services and to notify you about other services offered that may be of interest to you. We will not sell, share, or rent or otherwise make available any of that personal data to other parties, except that we may disclose the personal data to third parties who perform services on our behalf and have a need to access the personal data in connection with the performance of those services.
We may share your information with selected third parties (list available upon request) and use your data for our internal marketing analytics purposes to allow us to assess service performance, members’ behavior and trends. This is to allow us to monitor and continuously improve our offering, provided that you have not objected to the use of your data. We don’t sell or make available your data to any third parties for marketing, advertising or related purposes.
3.4 Scope of data processing
We collects data when users seek information regarding our services, or register for conferences and other events. Some of our forms used for registration and other purposes may ask members to provide contact information, and/or demographic information.
Depending on what you may want to use, we will ask you for specific personal data. This could be your email address or contact number so we can communicate with you or be some advanced identification information related to the verification process (e.g. proof of identity such as an I.D. card, driving license or passport). To assist us get to know you and comply with applicable laws and regulations - such as anti-money laundering, fraud or sanctions - we may require additional supporting information and documents.
3.5 Duration and location of storage
The personal data of you will be erased or blocked as soon as it is no longer necessary in relation of the purpose of storage. Furthermore, personal data may be stored if this has been required by regulations, laws or other provisions to which our company is subject. The personal data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.
All our data and your information is held in secure servers located in the EEA. We do use a number of different operating systems. In each case the data we store, how we store it and third party applications we use are subject to strict security measures and legal obligations.
3.6 Data security
We use a number of technical and procedural measures to ensure appropriate security of your personal data. These include encrypting data, only storing and transferring it where appropriate security measures had been taken and restricting access to who can see or use the data.
3.7 Access to personal data
Only those people within Homsy Legal that need to see it in order to assist to the proper functioning of the Sites. This will include our Board members. We may pass your personal data to selected third parties for the purposes set above such as complying with applicable laws and regulations - such as anti-money laundering, fraud or sanctions
You have rights related to your personal data such as the right to ask us what personal data we hold about you, ask us to correct or delete personal data about you or to restrict our processing of it. You have the right to revoke your declaration of consent for the processing of your personal data. You also have the right to request us to export or transfer data to other companies (data transferability).
In addition, you have the right to complain about our processing of your personal data, assert your claim in court or file a complaint within the relevant data protection authority.
If you have any questions, comments or complaints regarding how we process personal data about you, please send an e-mail to firstname.lastname@example.org
4 Services with Homsy Legal
4.1 Description and scope of processing of personal data
We collect data from clients, users and prospects when they seek information regarding our services, or register for conferences and other events. Therefore, Homsy Legal processes personal data i.e. name, address, domicile, e-mail address, phone number, date of birth. Some of the forms for Homsy Legal use for registration and other purposes may ask members to give us contact information, and/or demographic information.
In addition we may receive personal data from third parties included, but not limited to, data from public registers (debt collection registers, commercial registers, land registers); data from public proceedings, information from business partners or related to your professional functions and activities.
4.2 Legal basis for processing
By registering to our Website or community forum (together the “Sites”), by exploring and using the Sites, by submitting information to us, by uploading or downloading data on the Sites, by interacting with us by e-mail or in context of a membership your data will be processed. As such, you agree that we processes and use such personal data as described herein. This consent fall under the processing of personal data (art. 6 (1) (a) EU General Data Protection Regulation (GDPR) which serves as the legal basis for the processing).
In addition, the processing of personal data is necessary to be able to provide our services to you (for instance, performance of a contract where you are party). As such art. 6 (1) (b) GDPR serves as the legal basis for the processing. This also applies to processing operations that are necessary to carry out pre-contractual measures.
The processing of personal data may also be necessary to protect the vital interests of you or another natural person, article 6 (1) (d) GDPR serves as the legal basis for the processing. The processing of personal data may also be necessary for the purposes of the legitimate interests pursued by us a third party and where such interests are not overridden by the interests, fundamental rights and freedoms of you which require protection of personal data, art. 6 (1) (f) GDPR serves as the legal basis for the processing.
Finally, the processing of personal data is also necessary for compliance with legal obligation to which Homsy Legal is subject. As such art. 6 (1) (c) GDPR serves as the legal basis for the processing.
4.3 Purposes of processing
We may use your personal data to assess to provide services and to tailor the member’s experience at our Sites.
You agree that we may use any personal data that you provide, such as your name, address, email address, phone number to inform you about updates to the service and to notify you about other products and services offered by Homsy Legal that may be of interest to you. We will not sell, share, or rent or otherwise make available any of that data to other parties, except that we may disclose the data to third parties who perform services on our behalf (for the purposes set above, where appropriate) and have a need to access the data in connection with the performance of those services.
We may process the email addresses at the point of subscription of members who wish to receive email notification of publications and press releases in identified subject areas of interest, and of those who send us email messages or express interest regarding our services or employment opportunities, or register for conferences and other sponsored events. We will not, however, share any email addresses with any third party or send unsolicited email to any of the addresses we process, except in very limited circumstances as set forth in this policy.
4.4 Period of storage
The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. The personal data will therefore be stored for as long as the membership or subscription to a service in connection with the Homsy Legal is active or any other purposes pursued with the processing and/or a legal obligation to store and document or a predominant private or public interest exists.
As soon as the personal data collected by us are no longer required for the above-mentioned purposes, they will be deleted.
4.5 Possibility of objection and erasure
The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. Further you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If the personal data is necessary to perform a contract (e.g. membership) or to carry out pre-contractual measures, an early erasure of the personal data is only possible if neither contractual nor legal obligations prevent a deletion.
Individuals that subscribe to email newsletters are given the opportunity to opt out of promotions, news, and information at the time of signup. Homsy Legal also provides users the opportunity to opt out of receiving communications from us at the points where we request information. You may also feel free to contact us as indicated below if you wish to opt out of communications received from us at a later point, or access your account settings to make changes to the information we hold or you provide.
If you opted in to receive information about our product, updates, and offers, we will use your name and email address to send this information to you. If you no longer wish to receive these communications, you can unsubscribe by following the instructions contained in the emails you receive or on our Sites. Please note that we may send you transactional and relationship messages, even if you have unsubscribed from our marketing communications. For instance, if our service is going to be temporarily suspended for maintenance, we might send you an email to update you.
You may access, correct, update, and/or delete, as the case may be, any personal data that you submit to us through the Sites or through other means. To do so, please either follow instructions on the page of the Sites on which you have provided such information or subscribed or registered or contact us.
5 The Use of the Sites and creation of log files
5.1 Description and scope of processing of personal data
Every time you visit the Sites, our system automatically collects following data and information from the computer system of the calling computer:
Information relating to the browser type and version used
The user's operating system
The user’s Internet Service Provider
The user’s IP address
Date and time of access
Websites/the Sites from which the user's system reaches our website/Sites
Websites/the Sites accessed by the user's system via our website/Sites
The data is also stored in the log files of our system but is not stored together with other personal data of the user.
5.2 Legal basis for processing
The legal basis for the temporary storage of personal data and log files is art. 6 (1) (f) GDPR.
5.3 Purposes of processing
The temporary storage of the IP address by the system is necessary to enable the Sites to be delivered to the user's computer. For this, the IP address must remain stored for the duration of the session.
The personal data is stored in log files to ensure the functionality of the Sites. In addition, the data serves us to optimize the Sites and to ensure the security of our information technology systems. The data is not evaluated for marketing purposes in this context.
These purposes represent also our legitimate interest in data processing within the meaning of art. 6 (1) (f) GDPR.
5.4 Period of storage
The personal data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the Sites, the data will be deleted when the respective session has ended.
If the personal data is stored in log files, it will be deleted after seven days at the latest. Further storage is possible. In this case, the IP addresses of the users are deleted or alienated so that the calling client can no longer be assigned.
5.5 Possibility of objection and erasure
The collection of personal data for the provision of the Sites and the storage of personal data in log files is absolutely necessary for the operation of the Sites. Consequently, there is no possibility of objection.
Cookies are small files that contain data and are stored on your computer, iPad or mobile device. They contain information that lets the website you are accessing remember you on the site and let us know what your preferences when using the site (e.g. the Sites).
6.2 Description and scope of processing of personal data
Items in a shopping basket
Entered search terms
Frequency of page views
Use of website functions
6.3 Legal basis for processing
The legal basis for the processing of personal data using technically necessary cookies with the user’s prior consent is art. 6 (1) (a) GDPR.
6.4 Purpose of processing
a. Types of cookie
We use ‘Session Cookies’, ‘Persistent Cookies’ and ‘Third Party Cookies’ on our Sites.
Session Cookies are temporary files on your computer that allow a website to identify your actions and choices during a browsing session. They expire when you leave the site and close your web browser.
Persistent Cookies are stored on your computer and remain there after you close your browser or switch off your computer. They are then used next time you log on to our Sites to help us identify you and your preferences. They do not contain any data that would allow us to identify you to another user.
b. Storage of cookies and erasure
Should our Website use flash cookies at a certain point, the transmission of Flash cookies cannot be prevented by the browser settings, but by changes to the Flash Player settings.
7 Registration and use the Sites
7.1 Description and scope of processing of personal data
On our Sites, we offer members and users the opportunity to register by providing personal data. The data entered into the input mask is transmitted to us and stored by us. The following data is collected during the registration process:
At the time of registration, the following data is notably stored:
The IP address of the user
Date and time of registration
In the course of the registration process, the user's consent to the processing of the data is obtained.
By using the Sites further personal data may be processed, such as:
Your e-mail address
Any personal data you provide (uploading documents, participate within the discussion board, sending/providing data to other participants, share knowledge, etc.) or by using our services on the Sides that may contain personal data.
7.2 Legal basis of processing
The legal basis for the processing of personal data is art. 6 (1) (a) GDPR if the user has given its consent.
7.3 Purpose of processing
The registration of the user is necessary for the provision of certain contents and services on our Sites.
7.4 Period of storage
The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected.
Consequently, the personal data collected during the registration process will be erased as soon as the registration on our Sites is cancelled or changed and no longer required to perform a contract, membership or services. It may still be necessary to store personal data of the contractual partner in order to meet contractual or legal obligations.
7.5 Possibility of objection and erasure
As a user you have the possibility to cancel the registration and to change the data stored about you at any time.
If the personal data is necessary to perform a contract (e.g. membership) or to carry out pre-contractual measures, an early erasure of the data is only possible if neither contractual nor legal obligations prevent a deletion.
8 International transfer of personal data
In addition, you agree that Homsy Legal may disclose your personal data in response to inquiries by bona-fide rights owners in connection with allegations of infringement of copyright or other proprietary rights arising from information that you have posted on the Sites or otherwise provided to Homsy Legal, or that has been provided to regulators, law enforcement agencies or courts.
9 Security Process
Homsy Legal has in place technological and operational security processes designed to protect personal data from loss, misuse, alteration, or destruction. Only authorised employees and contractors will have access to any personal data provided by you, and that access is limited by need. Each employee or contractor having access to any personal data is obligated to maintain its confidentiality. Although we take steps that are generally accepted as industry standard to protect your personal data, Homsy Legal cannot guarantee that your personal data will not become accessible to unauthorised persons.
10 Links to other websites
11 Compliance with law
Homsy Legal complies with all applicable data privacy laws and regulations. Homsy Legal may be compelled to surrender personal data to legal authorities without express consent of the person (data subject) involved if presented with a court subpoena or similar legal or administrative order, or as required or permitted by the laws, rules, and regulations of any nation, state, or other applicable jurisdiction. Also, in the event of a violation of the terms and conditions of use of the Sites or a violation of any restrictions on use of materials provided in or through the Sites, we may disclose personal data to our affected business partners or legal authorities.
12 Policy amendments
15 Contact us
This document is property of Homsy Legal. The reproduction in whole or in part in any way including the reproduction in summary form, the reissue in a different manner and any changes in the original manual or any translated version is strictly forbidden and is only allowed with the prior written consent.
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