1. Introduction

1.1. We are committed to safeguarding the privacy of our website visitors, customers and service users
1.2. The policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; where we determine the purposes and means of the processing of that personal data
1.3. By using our website and/or our services you are agreeing to this policy, that you consent to our use of cookies in accordance with the terms of this policy
1.4. Our website incorporates privacy controls that affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications. You can access the privacy controls via the cookie banner at the bottom of the website.
1.5. In this policy, “we”, “us”, and “our” refer to Asmandes Ltd. For more information about us, see Section 11.
2. Why, and how we collect, process, and retain your data
2.1. We may collect, process, and retain;
2.1.1. The “usage data” about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services
2.1.2. The “account data” may include your name, email address, contact number and personal information provided in your contact with us. The source of the account data is you or your someone you have authorised. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you. The legal basis for this processing is consent
2.1.3. Your personal information is included in your personal profile on our website and internal IT systems as “profile data “. The profile data may include your name, address, telephone number, email address, profile pictures, educational details, and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent
2.1.4. “Service data”, that may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you. The legal basis for this processing is consent
2.1.5. Any information contained in any enquiry you submit to us regarding goods and/or services “enquiry data “. The enquiry data may be processed for the purposes of offering, marketing, and selling relevant goods and/or services to you. The legal basis for this processing is consent
2.1.6. Any information relating to transactions, including purchases of goods and services, that you enter with us and/or through our website “transaction data “. The transaction data may include your contact details, your card details and the transaction details which may include specific details on the transaction such as the information linked to the purchase. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract and our legitimate interests, namely our interest in the proper administration of our website and business
2.1.7. Any information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters “notification data “. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent
2.1.8. Any communication that you send to us “correspondence data “. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users
2.1.9. Any personal data identified in this policy where necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others
2.1.10. Any personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks
2.2. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also collect, process, and retain any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
2.3. Please do not supply any other person’s personal data to us unless we prompt you to do so.
3. Providing your personal data to others
3.1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy
3.2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure
3.3. We may disclose any of your personal data to our suppliers or subcontractors insofar as reasonably necessary for processing and providing our services requested by you, or for someone you have authorised
3.4. Financial transactions may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds. 
3.5. We may disclose your enquiry data to one or more selected third-party suppliers of goods and services for the purpose of enabling them to contact you so that they can offer, market, and sell to your relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data
3.6. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.2. We will retain your personal data as follows:
4.2.1. Transaction data will be retained for a minimum period of 2 years following the date the transaction was made, and for a maximum period of 5 years following the last transaction.
4.2.2. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
4.2.2.1. The period of retention of profile, service, notification, correspondence, and account data will be determined based on account inactivity and the overall maximum validity of 7 years
OR
4.2.2.2. Where Asmandes Ltd acts as Data Processor the retention of data will be determined by the Data Controller
4.3. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person
4.4. If you wish to update, or delete the personal information that we hold about you, please make your request with a valid reason, in writing using our contact form on our website.
5.  Security of personal data
5.1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse, or alteration of your personal data
5.2. We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems
5.3. The following personal data will be stored by us in encrypted form: password(s)
5.4. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology
5.5. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet
5.6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
6. Privacy Policy Amendments
6.1. We may update this policy from time to time by publishing a new version on our website
6.2. You should check this page occasionally to ensure you are happy with any changes to this policy
6.2.1. We are not entitled to notify you of changes to this policy by email or through the private messaging system on our website
7. Cookies and other tracking tools
7.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server
7.2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed
7.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies
7.4. We use cookies for the following purposes:
7.4.1. authentication – we use cookies to identify you when you visit our website and as you navigate our website
7.4.2. personalisation – we use cookies to store information about your preferences and to personalise our website for you
8. Your Rights
8.1. Your principal rights under data protection law are:
8.1.1.  the right to access
8.1.2. the right to rectification
8.1.3. the right to erasure
8.1.4. the right to restrict processing
8.1.5. the right to object to processing
8.1.6. the right to data portability
8.1.7. the right to complain to a supervisory authority; and
8.1.8. the right to withdraw consent
8.2. You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting your profile when logged into our website
8.3. You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed
8.4. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims
8.5. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are; you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment; exercise, or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.6. You have the right to object to our processing of your personal data on grounds relating to your situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise, or defence of legal claims
8.7. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose
8.8. To the extent that the legal basis for our processing of your personal data is:
8.8.1. consent; or
8.8.2. that the processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract,
8.8.3. and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others
8.9. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement
8.10. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal
8.11. You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section.
9. Withdrawing your consent
9.1. If you don’t want us to process your data anymore, please contact us using our website contact form.
10. Privacy policy updates
10.1. We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
11. Contact Information
11.1.    If you would like to: access, correct, amend or delete any personal information we have about you, you are invited to contact us using our website contact form.