Here’s where you can find more details on our cookie policy
LEGAL BASIS OF PROCESSING
The Owner may process Personal Data relating to Users if one of the following applies:
– Users have given their consent for one or more specific purposes.
– provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
– processing is necessary for compliance with a legal obligation to which the Owner is subject;
– processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
– processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
FURTHER INFORMATION ABOUT RETENTION TIME
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
– Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
– Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
THE RIGHTS OF USERS BASED ON THE GENERAL DATA PROTECTION REGULATION (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
– Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
– Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
– Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
– Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
– Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
– Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
– Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
– Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
HOW TO EXERCISE THESE RIGHTS
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
LEGAL ACTION
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Transform8 or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
ADDITIONAL INFORMATION ABOUT USER’S PERSONAL DATA
In addition to the information contained in this privacy policy, Transform8 may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
SYSTEM LOGS AND MAINTENANCE
For operation and maintenance purposes, Transform8 and any third-party services may collect files that record interaction with Transform8 (System logs) or use other Personal Data (such as the IP Address) for this purpose. Information not contained in this policy. More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
CHANGES TO THIS COOKIE POLICY
The Owner reserves the right to make changes to this cookie policy at any time by notifying its Users on this page and possibly within Transform8 and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
TECHNOLOGIES USED BY TRANSFORM8
This document informs Users about the technologies that help Transform8 to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with Transform8.
For simplicity, all such technologies are defined as “Trackers” within this document – unless there is a reason to differentiate. For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
Some of the purposes for which Trackers are used may also require the User’s consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document. Transform8 uses Trackers managed directly by the Owner (so-called “first party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information, such as the presence of other Trackers, in the linked privacy policies of the respective third-party providers or by contacting the Owner.
ACTIVITIES STRICTLY NECESSARY FOR THE OPERATION OF TRANSFORM8 AND DELIVERY OF THE SERVICE
Transform8 uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.
OTHER ACTIVITIES INVOLVING THE USE OF TRACKERS
FUNCTIONALITY
Transform8 uses Trackers to enable basic interactions and functionalities, allowing Users to access selected features of the Service and facilitating the User’s communication with the Owner.
– User database management (Measurement)
Transform8 uses Trackers to measure traffic and analyse User behaviour to improve the Service.
– Analytics
MARKETING
Transform8 uses Trackers to deliver personalised marketing content based on User behaviour and to operate, serve and track ads.
– Advertising
– Remarketing and behavioural targeting
HOW TO MANAGE PREFERENCES AND PROVIDE OR WITHDRAW CONSENT
There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:
– Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.
– Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences privacy widget, if available.
– It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent preferences.
– Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.
– With regard to any third-party Trackers, Users can manage their preferences via the related opt-out link (where provided), by using the means indicated in the third party’s privacy policy, or by contacting the third party.
LOCATING TRACKER SETTINGS
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:
– Brave
– Opera
Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices or tracking settings in general (Users may open the device settings and look for the relevant setting).
HOW TO OPT OUT OF INTEREST-BASED ADVERTISING
Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU and UK), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
CONSEQUENCES OF DENYING THE USE OF TRACKERS
Users are free to decide whether or not to allow the use of Trackers. However, please note that Trackers help Transform8 to provide a better experience and advanced functionalities to Users (in line with the purposes outlined in this document). Therefore, if the User chooses to block the use of Trackers, the Owner may be unable to provide related features.
Owner and Data Controller
Transform8 via Principals Consulting
73 The Broadway
Oadby
Leicester
Leicestershire
England
LE2 2HG
Owner contact email: help@transform8.me
Since the use of third-party Trackers through Transform8 cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document. Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by Transform8.