Posted: April 1, 2020
Effective: April 16, 2020
2. Our Processing Activities
To find out more please go to the sections of this policy that are relevant to you (at Exhibit A):
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure.
While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any passively-collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.
You may access your account information and our services only through the use of an individual username and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session.
Our information security policy is supported by a number of security standards, processes and procedures and we store information in access-controlled premises or in electronic databases requiring logins and passwords. We require our third-party data storage providers to comply with appropriate information security industry standards. All partners and staff and third-party providers with access to confidential information are subject to confidentiality obligations.
4. Location of Processing
We may store and process personal information and content in the United States and other countries or cities which include but are not limited to the United Kingdom, Australia, Hong Kong, Singapore and the Philippines.
As a result, your personal information may be transferred outside the country where you are located. This includes countries outside the European Economic Area (EEA), the UK and countries that do not have laws that provide specific protection for personal information. Where we collect your personal information within the EEA or the UK, transfer outside these locations will be only:
- to a recipient in a jurisdiction approved by the European Commission (for personal information collected within the EEA) or approved by the UK-ICO (for personal information collected within the UK post-Brexit) as offering an adequate level of protection for personal data (including the U.S. for personal information transferred to organisations in the U.S under the EU-U.S. Privacy Shield) or
- under an agreement which covers the EU requirements (for personal information collected within the EEA) or the UK requirements (for personal information collected within the UK post-Brexit) as the case may be, for the transfer of personal data to data processors or data controllers outside these locations.
We use resources and servers located in various countries around the world to process your personal information. Your personal information may also be transferred to third party service providers who process information on our behalf, including providers of IT and IT services such as website hosting and management, data back-up, security and storage services. Our third-party service providers may also use their own third parties (sub-processors). Our third-party service providers and their sub-processors are bound to maintain appropriate levels of security and confidentiality and to process personal information as instructed by us.
If you have any questions in relation to the transfer of your personal information outside the jurisdiction of origin please send an email to firstname.lastname@example.org.
5. Sharing Information with Third Parties
We may also disclose your personal information to third parties where:
- you have consented to us sharing your personal information in this way;
- we are under a legal, regulatory or professional obligation to do so (for example, in order to comply with anti-money laundering requirements) or in order to enforce or to protect the rights and interests, property, or safety of Azeus, our clients or others;
- if Azeus is involved in a merger, acquisition, or sale of all or a portion of its assets, or a bankruptcy proceeding, we may transfer your information to the acquiring company, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
- we may share aggregated or anonymized information with third parties that does not directly identify you.
6. Data Retention
We may retain your personal data for a period of time consistent with the original purpose of collection. We also may retain your personal data during the period of time needed for Azeus to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, enforce our agreements, if deemed necessary.
7. Your Rights
You have a right of access to personal data held by us as a data controller. We may charge for a request for access in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.
You have a right to have any inaccurate personal information corrected. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
Where we process personal data based on consent, individuals have a right to withdraw consent at any time.
You also have a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability.
If you wish to exercise any of these rights, please send an email to email@example.com.
In case you want to complain about our use of personal data, please send an email with the details of your complaint to firstname.lastname@example.org. We will look into and respond to any complaints we receive.
9. Contacting Us
You may also contact our EU/EEA and UK Representatives at the below addresses:
Convene Sociedad Limitada
Address: Calle Balmes, nú-mero 173, 4° 2a, 08006, Barcelona
Azeus UK Limited
Address: Azeus Convene, 2.014, 3 Waterhouse Square, 138-142 Holborn, London, EC1N 2SW