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PRIVACY POLICY

Last updated: September 2022

1. Introduction

This statement sets out the Privacy Policy adopted by Lavandbit Summit (“us”, “we” or “our”) in relation to our products and services (the “Services”) and our website (the “Website”). Protecting your privacy and the confidentiality of your information is a core priority in the delivery of our Services and the operation of the Website.

Our Services and Website may contain links to third-party websites and services. We are not responsible for the privacy practices of such third parties, and we recommend reviewing their privacy policies before engaging with them.

All information collected in connection with our Services is treated as confidential. We apply appropriate technical, organisational and security measures to protect Personal Data (as defined below) against unauthorised access, accidental loss, destruction, damage, theft or disclosure.

When submitting information through our Website, you may be asked to provide personal details such as your name, email address, telephone number, date of birth and identification information. This data may be used to verify your identity, manage information, provide technical support and comply with contractual or legal obligations. Where permitted, we may also send important service notifications and, with your consent, information about products and services via email or SMS. You may manage your communication preferences or unsubscribe at any time.

2. Website Visitors and Users

2.1 General

This section describes how Personal Data is collected from Website visitors (“Visitors”), users (“Users”) and business partners (collectively, “Partners”). Personal Data may include IP address, name, contact details and information relating to your relationship with us, as defined under applicable data protection laws.

2.2 Collection and Use

By accessing the Website, you consent to the collection and use of your Personal Data as described in this Policy. If you do not agree, you should refrain from using the Website. We may collect information through page activity, IP addresses, cookies and data voluntarily submitted through forms and registrations.

2.3 Purpose of Processing Personal Data

Personal Data is processed to improve, personalise and operate our Website and Services. This includes enhancing accuracy, providing support, communicating service-related information, fulfilling contractual obligations and collaborating with partners. All processing is carried out based on a lawful ground, including consent or legitimate interest.

The table below outlines the purposes and legal bases for processing Personal Data:

Account registration Your consent; performance of contractual obligations
Provision and use of Services Performance of contractual obligations
Operational updates Performance of contractual obligations
Responding to enquiries and providing support Legitimate interests or contractual obligations
Personalised Services, advertising and marketing Legitimate interests or your consent
Improving and developing new Services Consent and legitimate interests
Sending marketing communications Your consent
Marketing performance analysis Legitimate interests or consent
Operational and technical support activities Legitimate interests or contractual obligations
Statistical and analytical purposes Legitimate interests
Protection of rights, interests and assets Legitimate interests or legal obligations

2.4 Sharing of Personal Data

We may share Personal Data with service providers, Partners and contractors where necessary. For Users within the European Economic Area, all data processing is carried out in compliance with GDPR and applicable data protection legislation.

3. Partners

3.1 General

In order to deliver Services and collaborate with Partners, certain data may be collected and processed. Partners remain responsible for their own data, although secure access may be granted where required.

3.2 Processing of Personal Data

Processing is carried out based on Partner consent or legitimate interests. Aggregated and anonymised data may be created to improve development and service quality.

3.3 Controller and Processor Roles

Depending on the context, Lavandbit Summit may act as:

  • Controller for Visitor and User data
  • Processor for Partner data
  • All data is securely hosted using industry-standard safeguards, including physical, technical and organisational measures.

3.4 Third-Party Data Processing

Where Services involve third-party platforms:

  • We act as a data processor
  • Processing follows documented instructions
  • Appropriate security measures are implemented
  • Data breaches are reported when required
  • No subcontracting occurs without consent
  • Data is not transferred outside the EEA without authorisation
  • Electronic marketing includes consent and opt-out options

4. Security

We apply administrative, technical and organisational safeguards to protect Personal Data from unauthorised access, loss or misuse. Where data is shared with third parties, contractual obligations ensure compliance with this Policy and applicable laws.

While we take reasonable steps to protect data, no system can be completely secure. Users acknowledge the inherent risks associated with online data transmission.

5. Cookies

Please refer to our Cookie Policy for information on the cookies and tracking technologies used, their purposes and how to manage your preferences.

6. External Links

The Website may contain links to third-party sites. We are not responsible for their content or privacy practices, and users are encouraged to review third-party policies before sharing Personal Data.

7. Data Retention and Deletion

Personal Data is retained only for as long as necessary. Users with active accounts are responsible for managing their data. Upon account termination, data is deleted in accordance with legal and regulatory requirements.

Withdrawal of consent may restrict access to certain Services without liability on our part.

8. Your Rights

Users have the following rights under applicable data protection laws:

8.1 Right of Access

  • Confirmation of whether Personal Data is processed
  • Access to Personal Data and related information
  • Details on processing purposes, recipients, retention and profiling

8.2 Right to Rectification

  • Correction of inaccurate data
  • Completion of incomplete data

8.3 Right to Erasure

  • Request deletion of Personal Data under certain conditions

8.4 Right to Restrict Processing

  • Request limitation of processing in specific cases

8.5 Right to Data Portability

  • Receive data in a structured, machine-readable format
  • Transfer data to another controller

8.6 Right to Object

  • Object to processing based on legitimate interests or marketing
  • Processing ceases unless overriding legal grounds apply

8.7 Right to Withdraw Consent

  • Withdraw consent at any time

9. Marketing Communications

Personal Data may be used for marketing purposes only with your consent. You may withdraw consent at any time by contacting us in writing.

10. Acceptance of this Policy

By using the Website or Services, you confirm that you have read and accepted this Policy. Continued use following updates constitutes acceptance of the revised Policy.

11. Legal Disclosure

Personal Data may be disclosed without prior notice where required by law or to protect rights, property or safety.

12. Data Protection Officer

For privacy-related enquiries, you may contact our Data Protection Officer at [email protected].

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