Privacy Policy
 
Janita Falschlunger, (“the Company”, “us”, “we”, or “our”), operates the website https://janitafalschlunger.com/ We may change or add to this privacy notice, so we encourage you to come back and read it periodically. Janita Falschlunger is the data controller that resides in Str. Der Jugend 8, Groß Leuthen, 15913, Germany This privacy notice governs the website Janita Falschlunger informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. Your privacy is very important to us. We use your data to provide and improve our site. By using the site, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

DATA WE COLLECT
While using our site, we may ask you to provide us with certain personal data that can be used to contact or identify you (“Personal Data”). Personal Data may include, but is not limited to: · Email address · First name and last name · Phone number · Address, State, Province, ZIP/Postal code, City For clients who work with the company, we may also collect further, voluntary information to enable us to provide our service in an optimized manner. Some data collected from clients may include: · Sensitive Information · Goals and Aspirations · Business Details · Health Related Information

Information Collected Automatically
Like many websites, we and our service providers, such as Facebook, use cookies, web beacons and other technologies to receive and store certain types of information when you interact with us through your computer or mobile device. Using these technologies helps us recognize you, customize your experience and make relevant marketing messages. Here are some of the types of information we collect: · Log & Device data. When you visit our site, we may automatically record information (“log data”), including information that your browser sends whenever you visit our site. This log data may include your web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location. · Cookie data. We may use “cookies” (a small text file sent by your computer each time you visit our site) or similar technologies to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you or your browser delete them). To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails from us. Please see the Your Choices section below.

HOW WE USE YOUR INFORMATION
We may use information that we collect about you to: · Provide our Products and Services. We will use your information to provide our products and services to you. · Understand and improve our products and Services. We will perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others. We do this to help make our products better and to develop new products. · Communicate with you. We may send you emails about new product features or other news about us or on topics we think would be relevant to you. You may opt out of these at any time. Visit the Your Choices section below. · Responding to your requests. We will also use your information to respond to your questions or comments. We may contact you to inform you about changes in our services, our service offering and other important service related notices such as changes to the privacy policy or about security or fraud notices. We may develop and display content and advertising tailored to your interests on our products and services on our site and on other sites; We also may use your information to manage our business or perform functions as otherwise described to you at the time of collection.

Sharing and Disclosure
We do not share your personal information with others except as indicated within this policy or when we inform you and give you an opportunity to opt out of having your personal information shared. We will share your information in the following ways . · With third party service providers, agents, or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, to collect debts, and to analyse and enhance data (including data about users’ interactions with our service).

These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We do not authorize them to use or disclose your personal information except in connection with providing their services. Analytics: Specifically for analytics providers, we use Google Analytics Google Analytics which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/ Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

Advertising: We may use third-party Service Providers to show advertisements, which may include targeted advertisements on a third party site after you have visited our website. We and the third party service providers use cookies to inform, optimize, measure performance serve ads based on your previous visits to our site. Please note at this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions. We work with Google AdSense & DoubleClick Cookie Google, as a third party vendor, uses cookies to serve ads on our site. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/ Facebook: You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266/ To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 To see more about Facebook’s participation in the Digital Advertising Alliance please visit the Choices section of this notice.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation Payment Providers: We may provide paid products and/or services within the site. When we do, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own privacy notice. The payment processors we work with adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are: Stripe – Please view their privacy policy here Paypal – Please view their privacy policy here ·

To comply with legal process or to protect Janita Falschlunger. If we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to enforce applicable terms of use, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or Janita Falschlunger as required by law; or to detect, prevent, or otherwise address, security or technical issues or illegal or suspected illegal activities (including fraud). · Business Transfers. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy. In such transitions, customer information is typically one of the business assets that is transferred or acquired by a third party. In the unlikely event that we or substantially all of our assets are acquired or enter a court proceeding, you acknowledge that such transfers may occur and that your personal information can continue to be used as set forth in this privacy policy.

Links to Other Sites We may have links on our site to other sites that we do not operate. If you click on a third party link, you will be taken directly to that site which is governed by its own privacy notice. We strongly encourage you to read that privacy notice. We do not control that site and assume no responsibility for the content, policies or its practices.

Retention
Janita Falschlunger will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Janita Falschlunger will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Choices and Individual Rights: We aim to take reasonable steps so you can correct, amend, delete or limit the use of your Personal Data. You have the following choices: · E-mail. As described above, if you do not wish to receive promotional e-mails from us, you may opt out at any time. · Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time. · You can opt out of online targeted advertising by opting out within the advertisement itself or by visiting Digital Advertising Alliance, http://www.aboutads.info/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/. You can also opt out of the Digital Advertising Alliance using your mobile device settings. Your rights under certain circumstances: To access and receive a copy of the Personal Data we hold about you. To rectify any Personal Data held about you that is inaccurate To request the deletion of Personal Data held about you You have the right to data portability for the information you have provided to us. You can request to obtain a copy of this information in a commonly used electronic format so that you can manage and move it. We will need to verify your identity before being able to respond to such requests. Please contact us at info@janitafalschlunger.com Security We believe we use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information. Our policy on children’s information Our site is not directed to children under 16. If you learn that your minor child has provided us with personal information without your consent, please contact us.

Changes to the Policy We may change this policy from time to time, and if we do make changes, we’ll post any changes on this page. If you continue to visit our site after those changes are in effect, you agree to the revised policy. If the changes are significant, we may provide more prominent notice or get your consent on the new policy.

 Contacting Us If you have any questions or comments about this policy, please contact us at info@janitafalschlunger.com

Cookies Policy
Janita Falschlunger (“us”, “we”, or “our”) uses cookies on the Website https://janitafalschlunger.com/ (the “Service”). By using the Service, you consent to the use of cookies. Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies. What are cookies Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you. Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

How Janita Falschlunger uses cookies When you use and access the Service, we may place a number of cookies files in your web browser. We use cookies for the following purposes: · To enable certain functions of the Service · To provide analytics We use both session and persistent cookies on the Service and we use different types of cookies to run the Service: · Essential cookies. We may use cookies to remember information that changes the way the Service behaves or looks, such as a user’s language preference on the Service. · Analytics cookies. We may use analytics cookies to track information how the Service is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our users react to them. Third-party cookies In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on. What are your choices regarding cookies If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly. · For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050 · For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835 · For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored · For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US · For any other web browser, please visit your web browser’s official web pages. Where can you find more information about cookies You can learn more about cookies and the following third-party websites: · AllAboutCookies: http://www.allaboutcookies.org/ · Network Advertising Initiative: http://www.networkadvertising.org/


Disclaimer: This policy may be changed at any time at Janita Falschlunger discretion. If we should update this policy, we will post the updates to this page on our Website. This policy was last updated: 19.01.2022 If you have any questions or concerns regarding our privacy policy please direct them to info@janitafalschlunger.com

Disclaimer for Janita Falschlunger Janita Falschlunger’s Services Are Not Medical Advice The advice you receive from Janita Falschlunger is for informational purposes only and is intended for use with common sleep, potty training and parenting issues that are wholly unrelated to medical conditions. The advice is NOT intended to be a substitute for medical advice or treatment. Always seek the advice of your doctor or other qualified health practitioner regarding any matters that may require medical attention or diagnosis, and before following the advice and using the techniques described by Janita Falschlunger. Reliance on any information provided by Janita Falschlunger is solely at your own risk. The services that Janita Falschlunger provides are not intended to replace or supplement the medical advice that you receive before, during, and after the pregnancy, or any other phase of your life. You agree that none of the advice that Janita Falschlunger provides shall be considered medical advice nor should the advice be relied upon you as medical advice. You should always seek the advice of your medical practitioner. Therefore, you should consult with your personal physician or other health-care professional if you have any healthcare related questions or before embarking on a new sleep, potty training, parenting or wellness program for you or your child. If a medical problem appears or persists, do not disregard or delay seeking medical advice from your personal physician or other qualified healthcare provider. Accordingly, Janita Falschlunger expressly disclaims any liability, loss, damage, or injury caused by information provided to the client.

Exclusion/Limitation Of Liability Janita Falschlunger
does not make any representations or warranties, express or implied, regarding services provided. Janita Falschlunger’s liability (if any) is limited to the consulting fee paid by you to Janita Falschlunger, and in no event, will Janita Falschlunger be liable to you for any other claim, losses, or damages. I understand that the services, programs, courses, and classes offered by Janita Falschlunger are voluntary. I acknowledge that injuries, accidents, or other complications associated with products or services may result from my participation. I will consult my physician if I am concerned about any of the risks to my or my child’s health or well-being that may result from my participation of services or products with Janita Falschlunger. I acknowledge that it is my responsibility to follow instructions for any service provided or purchase I make, and to seek help from Janita Falschlunger, if I have any questions. I knowingly and voluntarily agree to waive and release Janita Falschlunger, its employees and representatives from any and all claims of liability or demands for compensation that I may acquire during my time working with Janita Falschlunger.

Non-Disclosure Agreement
(Keeping information between us confidential)
1.For purposes of this Agreement, "Confidential Information" shall mean any and all non-public information Janita Falschlunger has disclosed or may disclose to the Recipient, including but not limited to information related to: your plan, contact information, business or software architecture, logs, workshops, clients or prospective clients, internal communications, events, or meetings, or any other research, development, operations, marketing, transactions, regulatory affairs, discoveries, inventions, methods, processes, articles, materials, algorithms, formulas, specifications, designs, drawings, data, strategies, plans, prospects, know-how and ideas, whether tangible or intangible, and including all copies, analyses and other derivatives thereof. 2. The Recipient agrees (i) not to disclose any Confidential Information or any information derived therefrom to any third person, (ii) to keep Janita Falschlunger’s Confidential Information confidential and take all the reasonable precautions to protect the confidentiality of such Confidential Information with the same degree of care with which it protects the confidentiality of its own confidential information, but in no event with less than a reasonable degree of care, and (iii) not to use any Confidential Information for any purpose whatsoever except to advance the legitimate business interests of Janita Falschlunger under written or oral instruction of Janita Falschlunger’s authorized officers. 3.All right, title, and interest in and to the Confidential Information shall remain with Janita Falschlunger or its licensors. Nothing in this Agreement is intended to grant any rights to Recipient under any patents, copyrights, trademarks, or trade secrets of Janita Falschlunger. 4.The validity, construction and enforceability of this Agreement shall be governed in all respects by the law. This Agreement may not be amended except in writing signed by a duly authorized representative of the respective Parties. This Agreement shall control in the event of a conflict with any other agreement between the Parties with respect to the subject matter hereof. The failure of either party to enforce its rights under this Agreement at any time for any period shall not be construed as a waiver of such rights.

Privacy Policy

We understand that privacy and the security of your personal information is extremely important. This policy sets out what we do with your information and what we do to keep it secure. It also explains where and how we collect your personal information, as well as your rights over any personal information we hold about you. This Policy explains how we do this and tells you about your privacy rights and how the law protects you.

Introduction

This privacy notice applies to this website and other interactions (e.g, when you create an account with the Website, purchase or sign up for our product or service, sign up to our newsletter, signup to updates, open a support ticket, when you contact us by email or phone or contact us via social media ) you may have with us. If you do not agree with the terms, do not access or Websites or any other aspect of this website.

If you have any questions about privacy practices, please contact the us using the support/contact us form on the Website. You can use the contact link on your online site or email support@zenler.com to get the contact information of the Website instructors and administrator(s).

What Data Do We Collect About you

Personal data means any information capable of identifying an individual. It does not include anonymised data. We may collect and process your personal data in a different ways:

Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us.

Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. This may include product, content, files, courses, quizzes, surveys or any other content you upload to or create on the Website.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system.

Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you.

Other Information Collected

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this : Cookie Policy.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment such as Stripe and Paypal and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources such as European Commision EU VAT database.

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources as set out below. When a Third Party Service is enabled, we are authorized to connect and access Other Information made available to us in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services. Third party integrations may include

• Zapier.com
• MailChimp.com
• Google.com
• Facebook.com
• Segment.io

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don't provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

How we use your Personal Data

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us.
• Where we need to process data in accordance with Customer's instructions.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact us form on the Website or using the privacy settings in your profile.

Purpose and Legitimate Basis for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.

Communication Data : We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data: We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data:We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data: We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data: We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Marketing communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations(PECR), we may send you marketing communications from us if

you made a purchase or asked for information from us about our goods or services or you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.

Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing us via the contact us form at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc

Disclosures of your Personal Data

We may have to share your personal data with the parties set out below:

Online Course platform provider Zenler.com who will be data processor of your data. We have entered into a data processing addendum with Zenler to process your data. Other companies in our group who provide IT and system administration services and undertake leadership reporting. Service providers who provide cloud infrastructure, video hosting, live video platforms, email provider, IT and system administration services.

• - Amazon
• - Sendgrid
• - FileStack
• - Vimeo
• - Zoom

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. Government bodies that require us to report processing activities. require reporting of processing activities in certain circumstances. Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

Our Online course platform Zenler provider based in the UK is our data processor and we have entered into data processing agreement for the processor to protect your personal data. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. Where we use providers based in the United States (for example Amazon, Sendgrid) we may transfer data to them where we have signed data processing addendums for the provider to provide protection of data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at support@zenler.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please reach us via the contact us form on the Website.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Third Party Links

We may include links to third-party websites, addons and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

Age Limitations

By providing us with your data, you warrant to us that you are over 13 years of age.

How to contact us

You can contact Zenler at any time if you have any questions about this Privacy Policy or our practices, or if you are seeking to exercise any of your statutory rights.

You may contact us via the support/contact us form on the Website.

Data protection Authority

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us by email on support@zenler.com first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us via the support/contact us form OR update your profile in your account.