Effective date: 15.9.2020
For any privacy related issues please feel free to contact us [email protected]
Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
I. What personal data is collected, how, for what purpose and on what legal basis
If you want to get in touch with us, you may contact us via contact forms available on our website or via an email address published on our website. In such case you will provide us with your personal data such as your name and email address (or any other personal data you decide to share with us). We process this personal data for the purpose of handling your request/question. The legal ground for processing this data is your consent.
We process personal data of our clients and prospects to provide them with our services. The data processed for such purpose may include full name, company email, phone number, company name, industry, and others. The legal ground for processing this data is contractual and pre-contractual relations.
We process your name and email address if you subscribe for our newsletter. The legal ground for processing of your personal data is your consent. You have the right to withdraw your consent at any time. In every email we will provide you with the opportunity to unsubscribe from any further marketing communications from us. You may unsubscribe by clicking on the “unsubscribe” link located at the bottom of our marketing emails.
Processing of job applications
If you apply for any job positions at Odeon Ventures LTD through our website or other means, we will process the personal data you provide us with for the purposes of evaluating your application and information contained therein to assess whether you are a suitable candidate for any of our open positions. The legal ground for processing this personal data is performance of contract or pre-contractual relations.
We may keep you CV in our internal database in order to consider you for future positions at Odeon Ventures LTD subject to your consent. You can withdraw your consent at any time by sending a message to [email protected] We keep your CV for 1 year after which time we delete it.
Compliance with legal obligations
In some instances, legal regulations impose obligations on us under which we are obliged to process your personal data (such as accounting and tax laws). Legal grounds for processing this personal data are legal obligations.
We may process your personal data as well in cases where it is in our legitimate interest to process data about you such as to assert or defend against legal claims. Legal grounds for processing personal data is legitimate interest.
When you visit our website, you are informed through a cookie banner that we collect cookies and you may manage the types of cookies that you allow to be dropped on your device. After choosing whether you consent to our cookies or not, you can change the settings and withdraw your consent at any time here. [cookies_revoke]
We use the following types of cookies: (i) essential cookies, which are essential for transmission of communication and for the provision of services explicitly requested by you; and (ii) analytical cookies and other technologies which help us to analyse how you navigate our websites and what content is relevant to our users. Essential cookies cannot be disabled as they are essential for the functioning of our website. If you do not consent to the use of analytical, the functionality of our website may be limited. When analytical cookies are collected we process personal data such as IP address, gender, time zone setting, operating system and platform, information about visits including the URL, the search terms, information about what you viewed or searched on our website, page response times, download errors, length of visits to certain pages, page interaction information, (such as scrolling, clicks, and mouse-overs) and the methods used to browse away from the page, activities of users, browsing web pages.
When we collect essential cookies the legal ground for processing is legitimate interest. When we collect analytical cookies, we do so once you have given us your consent hence the legal ground for such processing is consent. You can withdraw your consent to analytical cookies at any time here [cookies_revoke]
We use Google Analytics to help us understand how you interact with our website so that we can improve it and make it easier to navigate. If you for wish your website visits to not be subject to Google Analytics tracking you can use the their opt-out browser add-on that you can download here https://tools.google.com/dlpage/gaoptout. If you wish to opt out of all analytical cookies you can withdraw your consent here. [cookies_revoke]
Below you can find a list of cookies used.
III. Who has access to your data
Your personal data may be shared with third parties that that process personal data on behalf of our company and in line with our instructions, hence these third parties are processors under the GDPR.
Currently, we use the following categories of processors:
- Marketing tools
- Analytical tools
- Recruitment, job portals
- IT tools/providers, communication tools, business administration tools
- Legal services, tax, accounting, and audit services
- Governmental agencies
Subject to the previous paragraphs, your personal data shall not be shared or provided to any other third party without your consent except for the following cases: i) we are obliged to provide your personal data on the basis of law or upon order of a public authority, ii) it is allowed by applicable legal regulations.
Transfers to third countries
The organisation will transfer your data to countries outside the EU/European Economic Area unless only if such transfer is GDPR compliant, that means for instance the provider is seated in a country in regard of which the European commission issued a decision that it provides an adequate level of personal data protection, standard contractual clauses are in place or in case of USA the provider is certified within the Privacy Shield framework.
IV. For how long we keep your data
Generally personal data shall be kept for as long as necessary for the purpose for which it was processed. For how long the organisation will hold your personal data will as well depend on the legal basis on which your data is processed. Shall the processing be based on legitimate interest your data will be processed for as long as the given legitimate interest of our organisation is in place. For data kept based on legal obligations the data retention period is prescribed by applicable legal regulations. For data processed based on performance of a contract the data is processed for the duration of the contractual relationship and for an applicable limitation period. Shall the processing be based on your consent your personal data shall be erased after you withdraw your consent. Please bear in mind that the same data may as well be processed based on other legal basis in which case your withdrawal of consent might not mean a full erasure of your data.
V. Data Security
We are committed to processing and storing your data securely. Therefore, we have implemented technical and organizational measures in an effort to safeguard the personal information in our custody and control (which do not, however, deprive you of your duty to take proper steps to secure your data). The aim is to eliminate unauthorised or unlawful processing of your personal data or the accidental, unauthorised or unlawful accessing, use, transferring, processing, copying, transmitting, alteration, loss or damage of your data. We protect your data, including but not limited to, in the following ways: using passwords and other access management and restricting access to your data (i.e. access to your personal data is granted only to those of our employees or contractors for whom the access is necessary), using security IT tools such as firewalls and antivirus/antimalware software, implementing appropriate physical security of premises where personal data is stored, implementing controls on premise entry.
VI. Your rights
Where EU General Data Protection Regulation 2016/679 (“GDPR”) applies to the processing of your personal data you are entitled under the GDPR to the following rights:
Right of access
You are entitled to be informed inter alia about what personal data we process about you, for what purposes, who are the recipients of your personal data.
Right to rectification
You have a right for any of your incomplete, inaccurate, or out-of-date personal data to be rectified.
Right to erasure (‘right to be forgotten’)
You are entitled to erasure of personal data that we have collected and processed about you.
Right to restriction of processing
In given cases such as when we process inaccurate personal data about you, or you deem the processing as no longer necessary you may ask for a restriction of the processing.
Right to data portability
You have a right to receive personal data you provide us with in a structured, commonly used, and machine-readable format and have it transmitted to another controller where technically feasible.
Right to object
You are entitled to object, on grounds relating to your particular situation, at any time to processing of personal data that concerns you and is carried out in public interest or for the purposes of legitimate interests pursued by our organisation, including profiling.
The exercise of your rights may be limited shall we be obliged to keep any of your personal data for the purpose of compliance with legal obligations, for the establishment, exercise or defence of legal claims or any other compelling reasons as provided by the relevant data protection law.
Should you wish to exercise any of your rights you may contact us at [email protected]
If you feel that your data has been processed unlawfully, contact us and we will undertake to resolve the problem. Under GDPR you have the right to lodge a complaint with our supervisory authority, find the link here: European Data Protection Supervisor: https://edps.europa.eu/data-protection_en
VII. California Consumer Privacy Act of 2018 (“CCPA”) Notice
Consumers residing in California have some additional rights in respect to their personal information under the California Consumer Privacy Act or (“CCPA”). If you are a California resident, this section applies to you and supplements the above policy.
Sale of Personal information
Under CCPA, “selling” information occurs when personal information is shared in exchange for valuable consideration. This includes sharing data which identifies your device such as cookies. We use third party cookies and other technologies to better understand our users’ needs and to optimize our services and user experience.
To opt out of these “sales” please click the “Do Not Sell My Personal Information” link here.
Your Californian Consumer Rights
Where the California Consumer Privacy Act of 2018 Assembly Bill No. 375 (“CCPA”) applies to the processing of your data you are entitled to the following rights:
Right to notice
Right of access
Right to request deletion
You are entitled to the erasure of personal data that we have collected and processed about you.
Right to opt out of sales of personal information
You have the right to opt out of sales of personal information. To opt out of these “sales” please click the “Do Not Sell My Personal Information” link here.
Right to receive equal services
You have a right to not be discriminated against even if you exercise any of your CCPA rights.
VIII. Final Provisions