1. General Provisions
- 1.1 Eclat Invest Ltd (referred to as “Company”), process your personal data as part of your use of NZBreader (“Products”, “Website”). We deal with your personal data in a confidential and responsible way. The processing of your personal data takes place in compliance with the General Data Protection Regulation („GDPR“).
- 1.3 We will only process data pursuant to purposes and means you determine. In these cases, we will provide you with separate data processing agreements.
3. Changes to this Policy
- 3.1 We reserve the right to modify this Policy at any time, and when required by law, we will notify you of changes to this Policy. If we make any material changes we will notify you via posting this information on your account.
4. Personal Data Management Principles
- 4.1 The Company undertakes to ensure your personal data is:
- 4.1.1 processed lawfully, fairly, and in a transparent manner in relation to you;
- 4.1.2 collected for specified, explicit and legitimate purposes (f. e. prevention of money laundering and terrorist financing, performance of Services, etc.), and not further processed in a manner that is incompatible with those purposes;
- 4.1.3 adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- 4.1.4 accurate and, where necessary, kept up to date;
- 4.1.5 kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed;
- 4.1.6 processed in a manner that ensures appropriate security of your personal data.
- 4.2 Website follows the above indicated principles strictly during the processing of your personal data and request the same from the data processors which it may use to process personal data on behalf of the Company.
5. What is “personally identifiable information?”
- 5.1 “Personally Identifiable Information” (hereinafter: “Personal Data”) is any information that can be directly associated with a specific person and can be used to identify that person. A prime example of identifiable information is a person’s name.
6. What kind of personal data do we collect?
- 6.1. General: We process such personal data that you as a user of the Website make available to us, for example upon registration or when using the Website (the „Data“).
- 6.2. Website Use: If you visit our website, we process only personal data that your browser communicates to our server. We collect the following data, which is necessary for us in order to display the website correctly and guarantee the necessary stability and security:
- 6.2.1 IP-address;
- 6.2.2 browser, operating system, interface, language and version of the browser software.
- 6.3. Registration Data: Upon registration we collect and process the following information:
- 6.3.1 registration details: date of registration, password; personal information: full name; email address; address, zip code, city, region, country;
- 6.3.2 payment information:
- 6.3.3 email address;
- 6.4. Product Use Data: Data processed when using the Services is processed by us only as a processor, not as a controller.
7. The reason we collect personal information
- 7.1. Purpose: The processing of Data pursues the following purposes (“Purposes”):
- 7.1.1 comply with applicable laws and regulations;
- 7.1.2 provide and improve the Services;
- 7.1.3 security and stability of the Services.
- 7.2. Lawfulness of Processing: The lawfulness of processing (Art. 6 GDPR) stems from:
- 7.2.1. your consent, where we have asked your explicit consent (para.1 subpara. a GDPR); and
- 7.2.2. the necessity for the performance of contract fulfillment, as your data is needed for a satisfactory use of the Services (para 1 subpara. b GDPR); and
- 7.2.3. the necessity for the purposes of the legitimate interests pursued by the Company or by a third party (para 1 subpara. f GDPR).
- 7.3. Legitimate Interests: The legitimate interests to analyze and improve the Website, to support you with any to protect the security, integrity, performance and functionality of the Services, and to provide you with advertisements.
8. How Your Personal Information is used
- 8.1 The primary purpose for collecting your Information is to provide you with the best possible user experience of using Website and to safeguard the security and stability of our systems. In general, we use Information to create, develop, operate, deliver, and improve our Website, to comply with our legal obligations, for anti-fraud purposes and for loss prevention. We may use your Information in the following ways
- 8.1.1 to provide, maintain, deliver or improve the Website;
- 8.1.2 for quality control to ensure we can provide you with the best user experience and accurate information;
- 8.1.3 to fulfil our legal or regulatory requirements;
- 8.1.4 to enforce the terms and conditions of our Service Agreement;
- 8.1.5 to ensure network and information security including processing your Information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations;
- 8.1.6 to provide you with the information or services that you have requested;
- 8.1.7 to provide you with service including, without limitation, answering your inquiry or responding to a communication from you;
- 8.1.8 to detect, investigate and prevent fraudulent transactions or unauthorized or illegal activities;
- 8.1.9 to facilitate corporate acquisitions, mergers, or transactions;
- 8.1.10 to carry out any other purpose or reason for which the Information was collected.
9. Sharing of Information
- 9.1 We will never sell or rent your personal information. We will only share your Information in the following circumstances:
- 9.1.1 with your consent or at your instruction;
- 9.1.2 in connection with offers on the Website;
- 9.1.3 certain information you may choose to share may be displayed publicly,
- 9.1.4 in order to prevent fraud or other illegal or unauthorized activities;
- 9.1.5 if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
- 9.1.6 with law enforcement officials, courts, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our Service Agreement or any other applicable policies;
- 9.1.8 with third parties where aggregate Information is disclosed which cannot be reasonably be used to identify you.
10. Retention Period of Data
- 10.1 We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, we may retain certain information for accounting and security purposes even after our business relationship with you has ceased.
11. Rights You Have with Respect to Your Personal Information
- 11.1 You have certain individual rights regarding the personal information that we collect and process about you through the Website. Most web browsers are set to accept cookies as a default. You may wish to opt out by turning off cookies (please refer to the help menu on your browser); however, switching off cookies may restrict your use of the Website. You have the right to:
- 11.1.1 access or receive certain data about the personal information we process about you;
- 11.1.2 have your personal information rectified;
- 11.1.3 object to the processing of your personal information or ask us to restrict processing or delete your personal information;
- 11.1.4 withdraw your consent to our processing of your personal information; and
- 11.1.5 not be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
- 13.1 You have the right to complain about our processing of your personal information to the relevant data protection authority. You can complain in the place where the alleged breach of data protection law has taken place.