Last Updated January 1, 2023
Welcome to the Grand Colonial Bed and Breakfast Privacy Statement (the “Policy”). Grand Colonial Bed and Breakfast is owned and operated by E2W, LLC. For the purposes of this Policy, the terms (“Grand Colonial Bed and Breakfast,” “our,” “we” or “us”) refer to E2W, LLC. except for the purposes of this paragraph and as explicitly referred to elsewhere in the Policy. “You” or “your” refers to you, as a user of our services, including any use of our websites, whether operated by us or on our behalf (“Services”). This Policy explains to you our practices in relation to our own business regarding your Personal Information, including how we collect, use, and share your Personal Information, and your rights regarding the Personal Information we collect. By using our Services, you indicate your acceptance of this Policy.
This Policy describes:
Personal Information We Collect;
How We Collect Your Personal Information;
How We Use Your Personal Information;
How We Disclose Your Personal Information;
How We Protect Your Personal Information;
Ability to Update and Correct Personal Information;
California Privacy Rights;
EEA and United Kingdom Privacy Rights;
Changes to the Policy; and
Questions About This Policy
Glossary
INFORMATION WE COLLECT
E2W, LLC collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household (“Personal Information”). E2W, LLC also collects non-Personal Information that cannot be linked or associated with any individual person or household. When non-Personal Information is combined with other information so that it does identify an individual person, we treat that combination as Personal Information. We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:
Identifiers such as your first name, last name, alias, username or similar unique personal identifier, account name, online identifier, and/or date of birth.
Contact Information such as your billing address, delivery address, email address and telephone numbers.
Financial Information such as bank account and routing numbers, credit or debit card information, or payment details.
Professional or Employment Information such as your company name.
Profile Data such as details about the products you have purchased, payments you have made, and/or other details of products and services you have purchased from us in the past, purchase or product preferences, feedback and survey responses.
Internet and Other Electronic Network Activity Information such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
Usage Data includes information about how you use our Services.
Marketing and Communications Information such as marketing campaign data, click throughs, your preferences and consent in receiving marketing from us and our third parties, and your communication preferences.
Inference Data including inferences drawn from the Personal Information identified above.
How Long Will You Use My Personal Information For?
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
If You Fail to Provide Personal Information.
Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Information You Provide to A Third Party.
The Services may include links and plug-ins to websites operated by third parties such as Facebook (“Third-Party Sites”). E2W, LLC does not control any Third-Party Sites and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by its privacy policy. It is your choice to enter any Third-Party Site. We recommend that you read its privacy policy if you choose to do so.
Children’s Privacy.
The Services are intended for adult use only and is not directed towards children, minors, or anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any Personal Information. If the parent or guardian of a child under 13 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us at the email address below and to have this Personal Information deleted from our files.
HOW WE COLLECT YOUR PERSONAL INFORMATION
Information You Provide to Us:
E2W, LLC may collect Personal Information from you that you voluntarily provide to us in various ways, including, but not limited to:
Book a stay or event with us
Place an order or purchase products from us or otherwise use our Services
Submit a Contact Us form
Use an interactive tool on our website
Call, email, or otherwise communicate with us
Otherwise interact with the Services
Information We Collect When You Use Our Services
Automated technologies or interactions.
As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our Services from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
Cookies and Tracking Technologies.
Cookies are small files that we or our service provider transfers to your computer’s hard drive through your web browser that enables us or our service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Services. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. Please read our Cookie Policy for more information. If you turn off your cookies, some of the features of the Services may not function properly.
Information We Collect
We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used, and disclosed by these third parties.
Third Party Service Providers.
We collect Personal Information from service providers including where we operate accounts on third-party platforms, such as email platforms and social media platforms.
Third Party Advertising Partners.
We collect Personal Information received from third-party advertising partners, including partners who host and manage various online advertisements.
Google Analytics.
We use third-party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on Google Analytics, visit https://support.google.com/analytics.
Third Party Cookies.
We may engage third-party service providers, including Google and Facebook, to serve ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities and purchases in order to deliver targeted advertising based on your interests. Please read our Cookie Policy here.
Your ‘Do Not Track’ Browser Setting.
Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our website does not respond to DNT signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
HOW WE USE YOUR PERSONAL INFORMATION
We will only use your Personal Information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes For Which We Will Use Your Personal Information
Our primary purpose in collecting Personal Information is to provide you with a safe, smooth, efficient, and customized experience.
We have set out below, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information. Please contact us if you need details about the specific lawful ground we are relying on to process your Personal Information.
Purpose/Activity:
Collect and process payments and complete transactions
Provide the products, services, and customer support you request
Verify your identity in connection with products or services you request
Provide you with recommendations for products and services that we believe would be of interest to you
Assist you with making or managing a booking with us
Troubleshoot problems, data analysis, testing, system maintenance, support, reporting and hosting data
Enforce our Terms and Conditions and the terms of this Policy
Customize, measure, and improve our services, content, and advertising
Inform you about our products, services, updates and promotional offers
To protect our interests, including establishing, exercising and defending legal rights and claims
Comply with legal requirements, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities
Type of personal data:
(a) Identifiers
(b) Contact
(c) Financial
(d) Employment
(e) Marketing and Communications
(f) Usage
(g) Internet
(h) Inference
Lawful basis for processing including basis of legitimate interest:
Performance of a contract with you
Marketing and Communications
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use/purchase our products/services, to develop our products/services and E2W, LLC, to inform our marketing strategy, to provide you with our newsletter if you have subscribed to it, for running Grand Colonial Bed and Breakfast, provision of administration and IT services, and network security)
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We disclose your Personal Information with third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to provide you with our Services and perform any contract we enter into with them or you.
Information You Instruct Us to Share.
You may be presented with an option on our Service to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
Service Providers.
We may use third-party service providers to perform certain business services and may disclose Personal Information to such service providers as needed for them to perform these business services. Service providers are only allowed to use, disclose, or retain the Personal Information to provide these services and are prohibited from selling Personal Information. Business services provided include, but are not limited to, hosting services, software as a service, document management services, communications services such as email, text, and chat services, software and website development services, collection services, payment processing services, accounting and audit services, compliance services, quality control services, analytics services, and marketing services.
Internal Third Parties.
We may disclose Personal Information to our parent company, subsidiaries, successors, assigns, licensees, affiliates, or business partners and others, including where disclosure of your Personal Information is needed to protect the employees, independent contractors, officers, directors, members, users, or shareholders of E2W, LLC who may use the Personal Information for the purposes described above.
Categories of Personal Information that have been disclosed for a business purpose in the past twelve months include:
Identifiers
Contact Information
Financial Information
Professional or Employment Information
Profile Data
Internet and Other Electronic Network Activity Information
Usage Data
Marketing and Communications Information
Inference Data
Business Transactions.
We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy.
Legal Process.
Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
Personal Information Sold or Shares.
We have not sold any Personal Information in the past twelve months. We have not shared Personal Information in the past twelve months with our third-party advertising partners to serve ads to you about our products and services as you browse the Internet. “Sharing” is defined under California privacy law as “renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.” This sharing means that these third-party service providers may use their own cookies or tags to track your online activities and purchases in order to deliver targeted advertising based on your interests. You can opt of sharing through the Do Not Share My Personal Information link. Additionally, if your browser supports it, you can turn on the Global Privacy Control (GPC) to opt-out of the “sharing” of your Personal Information. Learn more at the Global Privacy Control website. E2W, LLC has no actual knowledge of any sales or sharing of Personal Information of minors under 16 years of age.
The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.
COMMUNICATIONS AND OPT OUT
By booking a stay, event, or service, or making a purchase, or registering to receive the Grand Colonial Bed and Breakfast Newsletter, you consent to receive periodic commercial/promotional email communications from us. You may opt-out of receiving such promotional communications at any time by following the unsubscribe instructions contained in each email, or by contacting us by phone or email. This opt-out will not apply to operational or informational emails related to your use of our Services. You may continue to receive promotional email messages for a short period while we process your request.
For individuals in the European Economic Area (“EEA”) or the United Kingdom, please see the Section entitled EEA and United Kingdom Privacy Rights in particular the Marketing paragraph of that Section for information relevant to them.
HOW WE PROTECT YOUR PERSONAL INFORMATION
E2W, LLC transmits information via industry-standard secure server (SSL). This SSL creates the secure and encrypted https:// website address for our important pages. When you see the https:// website address, you know the information you are in-putting is protected and secure. We also comply with payment card industry data security standards that require merchants to implement security measures for credit card information.
We have implemented and maintain generally accepted industry standards to protect against the unauthorized access, use, modification, destruction or disclosure of your Personal Information both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.
ABILITY TO UPDATE AND CORRECT PERSONAL INFORMATION
E2W, LLC wants your Personal Information to be complete and accurate. By using the Services, you represent and warrant that all information you provide on any registration or booking form or otherwise in connection with your use of the Services will be complete and accurate, and that you will update that information as necessary to maintain its completeness and accuracy. To confirm the completeness and accuracy of, or make changes to, your Personal Information, please contact us at [email protected].
CALIFORNIA PRIVACY RIGHTS
California Consumer Privacy Act. The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Upon verification of your identity, you may:
No more than twice in any 12-month period, request disclosure of the following information:
Categories of Personal Information we collect.
Categories of sources from which Personal Information is collected.
Categories of Personal Information sold or disclosed to third parties.
Categories of third parties with whom such Personal Information is sold or disclosed.
Business or commercial purpose for collecting or sharing Personal Information.
Specific pieces of Personal Information we collect.
Request deletion of your Personal Information, subject to the exceptions provided by law.
Request to correct inaccurate Personal Information.
Opt-out from having your Personal Information sold to or shared with third parties, if applicable.
Limit use and disclosure of Sensitive Personal Information for any purpose other than the pre-approved business purposes identified in the privacy law.
Requests can be submitted by emailing us at [email protected]. You can opt out of having your Personal Information sold to third parties by emailing us at [email protected]. You can learn more about the GPC and how to enable it in your browser from the Global Privacy Control website.
Please note that these rights apply only to California consumers and business contacts. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. Except where you have provided an agent with a Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code, when using an authorized agent you must: (1) provide the agent with signed permission clearly describing their authority to make a request on your behalf; (ii) verify your own identity; and (iii) directly confirm that you have provided the authorized agent permission to submit the request. That agent must also be able to verify their identity with us and provide us with their authority to act on your behalf.
The verifiable consumer request initiated by you or your authorized agent must:
Include your full legal name, email, and phone number, which we will need to contact you in order to verify that you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to make a booking or purchase with us. We will contact you in order to verify your identity. You may need to provide additional information in order to verify your request. Depending on the nature of the request, we may require additional verification actions be taken, including but not limited to providing a signed declaration under penalty of perjury that you are the consumer whose Personal Data is the subject of the request. We will only use this information to verify the requestor’s identity or authority to make the request.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
The CCPA provides the right to be free from discrimination if you choose to exercise your rights under the statute, and we will not discriminate by:
Denying you goods or services.
Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Providing you a different level or quality of goods or services.
Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights. California residents have the right to receive information that identifies any third party companies or individuals that E2W, LLC has shared your Personal Information within the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting us at the address below.
EEA AND UNITED KINGDOM PRIVACY RIGHTS
This Section is relevant to you if you are located in the EEA or in the United Kingdom. In so far as this Section is inconsistent with or conflicts with any other part of this Policy the terms of this Section will apply if you are located in the EEA or in the United Kingdom. This Section does not apply if you are not located in the EEA or in the United Kingdom.
Marketing.
We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising.
Promotional offers from us.
We may use your Identifiers, Employment and Contact Information and, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
Third-party marketing.
We will get your express opt-in consent before we share your Personal Information with any third party for marketing purposes.
Opting out.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving marketing messages, this will not apply to emails of a non-promotional nature and which relate to a product/service subscribed for, product/service experience or other transactions.
Change of Purpose
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
International Transfers
Many of our external third parties are based outside the EEA and the United Kingdom so their processing of your Personal Information will involve a transfer of data outside the EEA.
Whenever we transfer your Personal Information to a third party that is based outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries
Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Providing you a different level or quality of goods or services.
Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.
Summary of Your Legal Rights and How to Exercise Them
E2W, LLC is responsible for your Personal Information. This means that E2W, LLC determines the means and purposes of processing Personal Information for the purposes of our business. Except in this paragraph, any reference in this Policy to “Grand Colonial Bed and Breakfast”, “our”, “we” or “us” also refers to E2W, LLC as the controller of your Personal Information. E2W, LLC is responsible for ensuring compliance of all our obligations under the applicable privacy laws of the EEA and the United Kingdom, and if you are located in the EEA or the United Kingdom E2W, LLC will have responsibility for dealing with any exercise by you of the rights set out below. The contact details set out below under “Questions About this Policy” apply to E2W, LLC.
Under certain circumstances, you have rights under data protection/privacy laws in relation to your Personal Information. Those rights include:
Requesting access to your Personal Information.
Requesting correction of your Personal Information.
Requesting erasure of your Personal Information.
Objecting to processing of your Personal Information.
Requesting restriction of processing your Personal Information.
Requesting transfer of your Personal Information.
Exercising your right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your Personal Information (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 could 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 Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information 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 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.
CHANGES TO PRIVACY THE POLICY
E2W, LLC may update this Policy at any time by posting additions or modifications on the Grand Colonial Bed and Breakfast website. In the event E2W, LLC changes, modifies, amends, or replaces this privacy policy, the effective date, located above, will change. Where changes to this Privacy will have a fundamental impact on the nature of how we collect, use, or share your data, we will give advance notice of such changes.
QUESTIONS ABOUT THIS POLICY
You may contact Grand Colonial Bed and Breakfast directly if you have any questions about this Policy. Our address is 112 W German Street, Herkimer, NY 13350. You may email us at [email protected].
If you are in the EEA or in the United Kingdom, you have the right to make a complaint at any time to your national supervisory authority for data protection/privacy issues. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.
GLOSSARY
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Information.
External Third Parties
Service providers acting as processors who provide website hosting, website testing, IT and system administration services.
Professional advisers acting as processors or joint controllers.
Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
Lawful Basis
Legitimate interest which means the interest of the foundations in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of contract which means processing your Personal Information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
To comply with a legal obligation which means processing your Personal Information where it is necessary for compliance with a legal obligation that we are subject to.
Processing means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Processor means a natural or legal person, public authority, agency or other body which processes Personal Information on behalf of the controller.
LEGAL RIGHTS OF INDIVIDUALS IN THE EEA AND THE UNITED KINGDOM
You have the right to:
Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information data unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.
Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your Personal Information but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your Personal Information to you or to a third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.