This Privacy Policy is provided to you by Achip & Achair Guild Ventures Pte. Ltd., with its registered office at 183 Jln Pelikat, B2-02 THE PROMENADE@PELIKAT, Singapore 537643, and each of its affiliates (hereafter referred to as ("we", “us”, or “our”) and sets out the basis on which we collect Personal Data from you and how we process such data.

By using, visiting, accessing or registering to use, logging into the Saakuru Labs Platform found at https://saakuru.com/ or the Saakuru Cashback Platform found at our website at https://saakurucashback.com/ (our "Platforms")you accept the practices described in this policy. The Platform also includes the browser plug-in, mobile application, APIs, documentation, software, updates, features, tools, and any materials and services made available from time to time by us.

If you are located in the United Kingdom (“UK”) or the European Union (“EU”) your attention is drawn to the section below headed “Additional Information For Users In The UK / EU (If Applicable)”. If you are located in the United States of America (“USA”), your attention is draw to the section below headed “Additional Information For Users In The USA (If Applicable)”.

1. DEFINITIONS

• In this Privacy Policy, unless the context otherwise requires, “Personal Data” means (a) any data, in particular by reference to an identifier such as a name, address, email address, date of birth etc. of that natural person, whether true or not, about an individual who can be identified directly or indirectly (i) from that data; or (ii) from that data and other information to which we have or are likely to have access, and (b) any other similar definition under any applicable Personal Data protection laws.

2. COLLECTION OF PERSONAL DATA

• 2.1  We may collect and process the following Personal Data about you:
• Information you give us - information that you provide us (which may include but is not limited to your first and last name, picture, address, age, location, e-mail address, telephone number, wallet addresses, social media handles, social media or third party service provider usernames, and other personal descriptions as the case may be) by filling in forms or submitting your information on our Platforms, or by corresponding with us (by phone, email or otherwise), for example when you:
• register for an account with us on our Platform or otherwise sign up to use our services;
• report any problem to us;
• use certain features on our Platform;
• request any support from us;
• provide us with information via e-mail;
• complete any survey or questionnaire we send you;
• subscribe to our newsletters or mailing lists (if any);
• provide us with comments or suggestions;
• request for information about our Platform or services; or
• contact us via phone, email or other forms of communication.
• Information we collect about you - information automatically collected when you visit our Platform, for example:
• Profile or contact information, including email address, phone number, IP address, or device ID;
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone, regional and language settings, browser plug-in types and versions, operating system and Platforms;
• details of any transactions, purchases and payments you make on our Platform; and
• information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Platforms (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
• Information we obtain about you for other sources:
  Saakuru Labs does not obtain information about you from third party sources.
• 2.2  By visiting or using our Platform or our services, you acknowledge that we collect and process the above types of Personal Data and information.

3. COOKIES FOR OUR PLATFORM

• 3.1  Our Platform uses cookies to distinguish you from other users of the Platform. This helps us to provide you with a good experience when you browse our site and also allows us to improve our Platform.
• 3.2  A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer's hard drive.
• 3.3  We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Platform or a partner website that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).
• 3.4  We use the following cookies:
• Strictly necessary cookies - These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform.
• Analytical/performance cookies - They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies - These are used to recognise you when you return to our Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies - These cookies record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information to make our Platform and the information displayed on it or any part of our Platform or services more relevant to your interests.
• 3.5  Cookies may be erased when you exit the Platform or close the browser. Others are saved on your device for your next visit. You can delete all cookies placed by our Platform on your device at any time. You can also set your browser to prevent all cookies from being placed by our Platform or to provide you with a warning before a cookie is placed. However, please note that some functionalities of the Platform may not work if all cookies are rejected. Please check your browser’s instructions or help screen to learn more about these functions.
• 3.6  Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, which we do not have any control over. These cookies are likely to be analytical/performance cookies or targeting cookies.

4. USE OF YOUR INFORMATION

• 4.1  We may use your Personal Data for the following purposes:
• Business Purposes
• providing, operating and administering the Platform and/or services, which shall include the personalisation of your profile and/or account, maintenance, servicing and termination of any accounts registered with the Platform (if any);
• as required to allow you to access third party services through our Platform;
• processing applications for the use of the Platform and/or services, including the facilitation, execution, or administration of any transaction(s) requested and/or authorised by you (if any);
• improving, enhancing and developing our Platform and/or services;
• researching, designing and launching new features or products for our Platform;
• managing, administering or presenting content and information on our Platform and/or services in the most effective manner for you and for the device you use;
• providing you with alerts, updates, materials or information about our services, Platform or other types of information that you requested or signed up to;
• Enforcement of Legal Obligations
• carrying out our contractual obligations arising from contracts entered into between you and us and for the enforcement of our legal or contractual rights;
• to verify your identity so as to ensure the safety and integrity of the transactions made through our Platform (including through any payment processor);
• where applicable, for complying with applicable local and foreign laws and regulations applicable to us in or outside of Singapore that may include the conduct of due diligence procedures for opening of accounts and ongoing monitoring purposes;
• where applicable, for legal and compliance purposes under applicable local and foreign laws that include the monitoring and compliance procedures that is in line with the internal risk management procedures, audit/financial accounting and for management reporting purposes;
• to comply with any applicable legislation, law, regulations, codes of practice, rules, guidelines, including where information is to be disclosed to law enforcement agencies and other relevant authorities for investigations, crime prevention and detection purposes;
• to prevent and/or detect fraudulent behaviour or transactions or potential illegal or criminal activity as part of our efforts to keep our Platform safe and secure;
• responding or taking part in legal proceedings, including seeking professional advice;
• for direct marketing purposes (please see further details in Clause ‎4.2 below);
• communicating with you and responding to your questions or requests;
• for internal operations, including troubleshooting and data analysis to learn about and understand the behaviour and preferences of users, testing, research, statistical and survey purposes to identify products or services which we might offer to existing and future users; and
• purposes directly related or incidental to the above.
• 4.2  We may use your Personal Data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). In relation to direct marketing, where required by the law, we will obtain your consent before using your Personal Data for this purpose. If you prefer not to receive our direct marketing communications and/or not to have your Personal Data shared among the members of our group or any third party for the purpose of marketing, you can have your name deleted from our direct marketing and/or shared information lists by clicking ‘unsubscribe’ at the footer of our emails or submit a request to us at [email protected].
• 4.3  If we need to collect, use and/or disclose your Personal Data for additional purposes, unless excepted by law, we will inform you of the new purposes, and where necessary we will obtain your consent (or ensure that we have another lawful basis for such collection, use or disclosure) before such Personal Data will be collected, used and/or disclosed by us.

5. DISCLOSURE OF YOUR INFORMATION

• 5.1  We will take steps to keep your Personal Data we hold confidential but you agree we may provide your Personal Data to:
• personnel, agents, advisers, auditors, contractors, financial institutions, and third party service providers in connection with our operations or services (for example staff engaged in the fulfilment of your transaction, the processing of your payment and the provision of support services, where applicable);
• our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);
• persons to whom we are required to make disclosure under applicable laws and regulations in or outside of Singapore; or
• actual or proposed transferees of our operations (or a substantial part thereof) in or outside of Singapore.
• 5.2  We will also need to share your Personal Data if we are under a duty to disclosure or share it to comply with a legal obligations, in which case we will share your information with law enforcement agencies in connection with any investigation to help prevent unlawful activity.
• 5.3  We will also share your information with third parties in the event that:
• we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets (but only to the extent we need to, and always in accordance with data protection legislation); and/or
• if we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about our customers will be part of the assets transferred to such third party.
• 5.4  We process your Personal Data for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your Personal Data in this way, the relevant buyer of our business may not be able to provide services to you.
• 5.5  Where applicable, we will ensure that the Personal Data enjoys the same standards of protection as set out in this Privacy Policy.
• 5.6  If we transfer any of your Personal Data to a country or territory outside Singapore, to our group or affiliates companies located outside Singapore, or to a permitted third party located outside of Singapore, we will only do so if we ensure that the overseas receiving party is bound by legally enforceable obligations to afford the transferred data a standard of protection that is comparable to that under Singapore law. We will also ensure that any overseas recipient is able to provide appropriate technical and organisational measures to protect your Personal Data and its confidentiality.

6. SECURITY

• 6.1  We will use appropriate and adequate technical and organisational measures to safeguard your Personal Data, for example:
• all Personal Data you provide to us is stored on our secure servers;
• we restrict access to Personal Data to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations; and
• We review our Personal Data collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
• 6.2  While we will use reasonable efforts to safeguard your Personal Data, you acknowledge that the transmission of information via the Internet is not completely secure and for this reason we cannot guarantee the security or integrity of any Personal Data that is transferred from you or to you via the internet; any transmission is at your own risk.
• 6.3  In the event that there is a security breach involving your Personal Data, we will inform you of the incident in accordance with the relevant data protection laws.

7. WHERE WE STORE YOUR DATA

• 7.1  We may store the Personal Data that we collect from you on internal servers that belong to us and/or our affiliated companies, and/or with commercial cloud storage providers engaged by us and/or our affiliated companies. These servers may be located in or outside of Singapore. Therefore, your data may be transferred to and stored in different jurisdictions and may also be processed by staff operating within the various countries who work for us or for one of our contractors and/or our affiliated companies.
• 7.2  By submitting your Personal Data, you agree to such transfer, storage or processing of your data. In such a case, we will ensure that the receiving organisations will provide a minimum standard of protection to your data that is comparable to the required protection under Singapore law.
• 7.3  Unfortunately, the transmission of information via the internet is not completely secure. We will take commercially reasonable steps to ensure that your Personal Data is handled securely and in accordance with this Privacy Policy and the relevant privacy laws, but are unable to guarantee the secure transmission of information via the internet.

8. YOUR RIGHTS

• Depending on which Personal Data protection laws apply to the processing of your personal data, you may have one or more of the following rights in relation to the processing of your personal data:

• 8.1  You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided below. We will endeavour to process your request within forty-five (45) calendar days from the day of receipt of your request, otherwise, we will provide you with the estimated time frame for us to carry out your request.
• 8.2 If you have consented or signed up to receive marketing materials, you may withdraw your consent at any time and request us to stop sending you marketing materials or to stop using your Personal Data for any other marketing activities by submitting your request via email to our Data Protection Officer at the contact details provided below. We will endeavour to process your request within forty-five (45) calendar days from the day of receipt of your request.
• 8.3  Please note that depending on the nature and scope of your request for withdrawal of consent, we may not be in a position to continue providing the Platform or our services to you. In our acknowledgement email to you upon your request for withdrawal of consent, we will inform you of the likely consequences of withdrawing consent.
• 8.4  If you do withdraw your consent, we will work with all relevant stakeholders such as data intermediaries and agents who have been authorised to collect, process or use your Personal Data to ensure that such relevant stakeholders also cease to collect, process or use your Personal Data.
• 8.5  You may have additional rights if you are located in the UK or the EU (see the section below headed “Additional Information For Users In The UK / EU (If Applicable)”), or if you are located in the USA (see section below headed “Additional Information For Users In The USA (If Applicable)”).

9. ACCESS

• 9.1  You may send our Data Protection Officer requests for:
• access to Personal Data which we hold about you; and/or
• access to information about the ways in which we use or disclose or may have used or disclosed your Personal Data for the year immediately preceding the date of your request.
• 9.2  Access requests may be subject to a fee to meet our costs in providing you with details of the information we hold about you. Where such a fee is chargeable, we will let you have a written estimate of the fee before proceeding.
• 9.3  If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you within that time in writing the time by which we will be able to respond to the request.
• 9.4  You may have additional rights if you are located in the UK or the EU (see the section below headed “Additional Information For Users In The UK / EU (If Applicable)”), or if you are located in the USA (see section below headed “Additional Information For Users In The USA (If Applicable)”).

10. ACCURACY OF AND CORRECTION OF PERSONAL DATA

• 10.1  We will make reasonable efforts to ensure the accuracy and completeness of the Personal Data you provide to us and/or update your Personal Data associated with your account on the Platform. However, we also will require you to provide us with accurate, up-to-date and complete information. In order to ensure that the Personal Data that we maintain is accurate, you may send our Data Protection Officer at any time requests to update your information or for correction of errors or omissions in Personal Data which we hold about you.
• 10.2  We will generally not charge for correction requests, although we reserve the right to do so under unforeseen circumstances. If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to the request.

11. DATA PORTING REQUEST

• 11.1  To the extent applicable under the PDPA, as long as you have an existing direct contractual arrangement with us, you may send our Data Protection Officer a request for us to transmit your Personal Data, which was collected or created by us prior to the date of your request, which is in our possession or under our control, to another organisation in Singapore.
• 11.2  If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to the request.

12. RETENTION OBLIGATIONS

• 12.1  We will only retain and use Personal Data for as long as is required by law or for other legitimate business purposes including complying with our legal obligations, resolving disputes and enforcing our agreements.
• 12.2  We will ensure that your Personal Data is destroyed, remove them from our records, and/or ensure that it no longer contains personally identifiable information, as soon as it is reasonable to assume that:
• the purpose for which the Personal Data was collected is no longer relevant; and
• retention is no longer necessary for legal or business purposes.
• 12.3  To determine the appropriate retention period for the Personal Data we hold, we will consider the amount, nature and sensitivity of the Personal Data, the risk of harm from unauthorised use or disclosure of your Personal Data, the reasons why we handle your Personal Data, whether we can achieve those purposes through other means, and the applicable legal requirements.
• 12.4  We may also anonymise your Personal Data so that it can no longer be associated with you, in which case we may retain and use this information indefinitely without further notice to you.

13. THIRD-PARTY SITES

• 13.1  Our Platform or our communication with you may, from time to time, contain links to third-party websites and/or websites of our partner networks, advertisers, affiliates and third party service providers, over which we have no control.
• 13.2  If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites to understand your rights. We accept no responsibility or liability for your access of third-party websites.

14. CONTACT US

• We may amend this policy from time to time by posting the updated policy on our Platform. Any changes that we make will be posted on this page and, where appropriate, notified to you by e-mail or post. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you access the Platform. By continuing to use our Platform after the changes come into effect means that you agree to be bound by the revised policy.

15. CHANGES TO OUR PRIVACY POLICY

• If you have any questions, comments or requests regarding this Privacy Policy or your Personal Data, please address them to:
• Data Protection Officer, at [email protected]

Last updated: Mar. 26, 2024

Additional Information for Users in the USA (If Applicable)

YOUR RIGHTS UNDER UNITED STATES LAWS

Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Data with third parties for the purposes of third-party marketing to you without your prior consent.

Do Not Track Signals. Other than as disclosed in this Policy, the Platform does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Platform does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

WE DO NOT SELL OR SHARE YOUR PERSONAL DATA. If we ever decide to “sell” or “share” Personal Data, as those terms are defined under the California Consumer Privacy Act of 2018, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Data,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Data.

If you are a California, Colorado, or Virginia consumer, as defined by the California Consumer Privacy Act of 2018 (the “CCPA”), the Colorado Privacy Act (“CPA”) or the Virginia Consumer Data Protection Act (“VCDPA”), respectively, you may be afforded additional rights with respect to your “Personal Data” as that term is explicitly defined under the CCPA, CPA, and VCDPA. Any Personal Data we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. You may exercise each of your rights as identified below, subject to our verification of your identity.

Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Data over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Correction. You can correct what personal data our Platform database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.

Prohibit Data Sharing. When applicable, you may prohibit the sharing of your Personal Data. In your request, please explain how you wish us to prohibit the sharing of your Personal Data, and which categories of third parties you want to prohibit from receiving your Personal Data. When such prohibitions are not possible to provide our services to you, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.

Portability. Upon request and when possible, we can provide you with copies of your Personal Data. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy

Deletion. You have the right to request that we delete any of your Personal Data, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.

Opt-out of Processing. You have the right to request that we do not sell your Personal Data, use your Personal Data for Targeted Advertising, or use your Personal Data for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.

Non-Discrimination. If a California, Colorado, or Virginia data subject exercises his or her rights under applicable state law, including the CCPA, CPA, and VCDPA, we shall not discriminate against that resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.

Exercising your rights. If you are a California, Colorado, or Virginia resident who chooses to exercise the rights listed above, you can:

1.Submit a request via email at [email protected]; or 2.Call us at 1-866-998-0772 to submit your request.

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Data. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Data. In some instances, such as a request to delete Personal Data, we may first separately confirm that you would like for us to in fact delete your Personal Data before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Additional Information For Users In The UK / EU (If Applicable)

Controller. We are the data controller of the Personal Data we process about you.

If you are in the UK or EU, the relevant UK and EU Personal Data protection laws will apply to our use of your Personal Data, which means any applicable data protection and privacy laws relating to the processing of personal data and privacy including the General Data Protection Regulation (EU) 2016/679 (“EU GDPR”) and the EU GDPR as retained under the domestic law of the United Kingdom (collectively, “UK / EU Data Protection Laws”).

In the event of any conflict or inconsistency with the main body of this Privacy Policy and this section, this section shall prevail to the extent that the UK / EU Data Protection Laws apply to our use of your Personal Data.

Legal Basis for Processing Your Personal Data

We are entitled to process your Personal Data for the purposes set out in this Privacy Policy because:

• the use of your Personal Data is necessary for the performance of a contract to which you are subject or in order to take steps at your request prior to entering into a contract;
• we have legal and regulatory obligations that we have to discharge;
• we need to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
• you consent for us to process your Personal Data for a specific purpose; and/or
• the use of your Personal Data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), and these legitimate business interests do not cause undue prejudice to your data protection interests, such interests include:
• improving, enhancing and developing our Platform and/or services;
• researching, designing and launching new features or products for our Platform;
• managing, administering or presenting content and information on our Platform and/or services in the most effective manner for you and for the device you use;
• providing you with alerts, updates, materials or information about our services, Platform or other types of information that you requested or signed up to;
• to verify your identity so as to ensure the safety and integrity of the transactions made through our Platform (including through any payment processor);
• to prevent and/or detect fraudulent behaviour or transactions or potential illegal or criminal activity as part of our efforts to keep our Platform safe and secure; and
• for direct marketing purposes.

Cross-Border Data Transfers

As a global business, we may store, transfer and process your Personal Data within our affiliates and to our suppliers based in countries other than the country where you are located. We will take appropriate safeguards to ensure that any transfers of Personal Data are in accordance with UK / EU Data Protection Laws.

Where we transfer Personal Data outside of the UK and/or EU, we shall ensure that your Personal Data is protected in a manner that is consistent with UK / EU Data Protection Laws. This can be done in a number of ways, for instance:

• the country or jurisdiction that we transfer the Personal Data to is approved by the European Commission or UK Government (as appropriate) as providing a level of protection equivalent to that under UK / EU Data Protection Laws (i.e. an adequacy decision); or
• appropriate contractual safeguards will be put in place with the recipient, such as the “Standard Contractual Clauses” approved by the European Commission or UK Government (as appropriate), and by adopting appropriate supplementary measures necessary, to ensure a level of protection equivalent to that under UK / EU Data Protection Laws. You can request a copy of the measures applied to the transfer of Personal Data by using the contact information as stated below.

In other circumstances, the law may permit us to otherwise transfer your Personal Data outside the UK and/or EU.

Your Rights. If you are in the UK / EU, you have the following rights under the relevant Personal Data protection laws:

• Right to Access your Personal Data that we process and receive a copy of it;
• Right to Rectify inaccurate Personal Data we have concerning you and to have incomplete Personal Data completed;
• Right to Data Portability, that is, to receive the Personal Data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this Personal Data to another service provider. Where technically feasible, you have the right that your Personal Data be transmitted directly from us to the service provider you designate;
• Right to Withdraw Consent to processing your Personal Data, at any time, where the processing is based on consent. If you do that, we will still process certain information on a legal basis other than consent, as described in this Policy. Withdrawing your consent will not affect the lawfulness of the data processing we carried out based on your consent before such withdrawal;
• Right to Object, based on your particular situation, to using your Personal Data on the basis of our legitimate interests. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defense of legal claims. You may also object at any time to the use of your Personal Data for direct marketing purposes
• Right to Restrict processing your Personal Data (except for storing it) if you contest the accuracy of your Personal Data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the Personal Data and request instead to restrict its use; if we no longer need the Personal Data for the purposes outlined in this Policy, but you require them to establish, exercise or defend legal claims; or if you object to processing, pending the verification whether our legitimate grounds for processing overrides yours;
• Right to be Forgotten. Under certain circumstances, such as when your right to object overrides our legitimate interests, you have the right to ask us to erase your Personal Data. However, we may still process your Personal Data if it is necessary to comply with a legal obligation, we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims; and
• Right to lodge a complaint. If you think that any of your rights have been infringed by us, you have the right to lodge a complaint with the applicable data protection regulator (details of which are provided below).

If you desire to exercise any of these rights, contact us at [email protected]

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

We may 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 to ensure that personal data is not disclosed to any person who has no right to receive it.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.