1.1 We are committed to protecting the privacy of visitors to our website.
1.2 This policy applies where we act as a data controller with respect to the personal data of our website visitors, in other words, where we determine the purposes and means of processing that personal data.
1.4 Our website contains privacy controls that affect how we will process your personal data. By using the privacy controls, you can opt out of receiving direct marketing communications and restrict the publication of your information
2.1 This document was created using an example from SEQ Legal. https://seqlegal.com
3. How we use your personal information
3.1 In this section (3) we have set out the following:
(a) the general categories of personal data that we may process.
(b) in the case of personal data that we have not obtained directly from you, the source, and specific categories of that data.
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process the data about your use of our website (“usage data”). The Usage Data may include your IP address, geographic location, browser type and version, operating system, referral source, visit duration, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your website usage. The source of the usage data is our analytics tracking system. This usage data may be processed to analyze the use of the website and services. The legal basis for this processing is consent.
3.3 We may process information you provide to us to subscribe to our email notifications and/or newsletters (“Notification Data”). The notification data may be processed to send you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.4 We may process information contained in or related to any communication you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website generates the metadata associated with communication via the contact forms on the website. The correspondence data may be processed to communicate with you and to keep records. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business, and communication with users.
3.5 We may process any of your personal data identified in this policy as necessary for the establishment, exercise, or defense of legal claims, whether in judicial proceedings, administrative or out-of-court proceedings. The legal basis for this processing is our legitimate interests, namely the protection and enforcement of our legal rights, your legal rights, and the legal rights of others.
3.6 In addition to the specific purposes for which we may process your personal data as set out in this section 3, we may also process any of your personal data where such processing is necessary to comply with a legal obligation to which we are subject, to protect your vital interests or to protect the vital interests of another natural person.
3.7 Please do not give us anyone else’s personal information unless we ask you to.
4. Providing your personal information to others
4.1 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and any of its subsidiaries) to the extent reasonably necessary for the purposes and on the legal bases set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers to the extent reasonably necessary to obtain or maintain insurance coverage, manage risk, obtain professional advice or establish, exercise or defend legal claims, either in legal proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose usage data, including your IP address, geographic 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 website usage to Google Analytics as reasonably necessary for website analysis purposes.
4.4 In addition to the specific disclosures of personal information set out in this section 4, we may disclose your personal information where such disclosure is necessary to comply with a legal obligation to which we are subject, or to protect your vital or vital interests. interests of another natural person. We may also disclose your personal information where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court proceeding.
5. International transfer of your personal data
5.1 In this section 5 we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We have offices and facilities in Suriname and the Netherlands. The European Commission has made an “adequacy decision” regarding the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which may be obtained from: http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:32001D0497
5.3 The hosting facilities for our website located in the United States of America.
Google and Mailchimp located in the United States. The European Commission has made an “adequacy decision” regarding this country’s data protection laws. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection provisions adopted or approved by the European Commission, a copy of which may be obtained from:
5.5 You acknowledge that personal information that you submit for publication through our website may be available via the internet around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Keeping and Deleting Personal Information
6.1 This section 6 describes our data retention policies and procedure, which are designed to ensure that we comply with our legal obligations regarding retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes will not be kept for longer than is necessary for that purpose or those purposes.
6.3 We store your personal data as follows:
(a) Usage data is retained for a minimum period of 24 months from the date of collection and for a maximum period of 24 months from the date of submission.
(b) Correspondence records will be kept for a minimum of 24 months from the date of submission and a maximum of 5 years from the date of submission.
(c) Report Data will be retained for a minimum period of 24 months from the date of submission and for a maximum period of 5 years from the date of submission.
6.4 Notwithstanding the other provisions of this section 6, we may retain your personal data where such retention is necessary to comply with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
7.1 We may update this Policy from time to time by posting a new version on our website.
7.2 You should visit this page from time to time to ensure that you are happy with any changes to this policy.
7.3 We may notify you of material changes to this policy by email.
8. Your rights
8.1 In this section 8 we have summarized the rights you have under data protection law. Some rights are complex and not all details are included in our summaries. Therefore, you should read the relevant laws and guidelines of the regulatory authorities for a full explanation of these rights.
8.2 Your main rights under data protection law are:
(a) the right of access.
(b) the right to rectification.
(c) the right to delete.
(d) the right to restrict processing.
(e) the right to object to processing.
(f) the right to data portability.
(g) the right to lodge a complaint with a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirm whether we process your personal data or not, where we process your personal data, access your personal data, together with certain additional information. That additional information includes details about the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Provided that the rights and freedoms of others are not affected, we will provide you with a copy of your personal information. The first copy is provided free of charge, but additional copies may be subject to a reasonable fee. You can request a copy of your personal data by sending an e-mail with proof of identity (copy of international passport or national identity card) by sending an e-mail to firstname.lastname@example.org
8.4 You have the right to have any inaccurate personal data about you corrected and, considering the purposes of the processing, to have incomplete personal data about you completed.
8.5 In some circumstances you have the right to delete your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw your consent to consent-based processing; you object to processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions from the right to erasure. The general exclusions include where processing is necessary: for exercising the right to freedom of expression and information; to comply with a legal obligation; or for the establishment, exercise, or defense of legal claims.
8.6 In some circumstances you have the right to delete your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw your consent to consent-based processing; you object to processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions from the right to erasure. The general exclusions include where processing is necessary: for exercising the right to freedom of expression and information; to comply with a legal obligation; or for the establishment, exercise, or defense of legal claims.
8.7 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 performed in the public interest or in the exercise of 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 processing 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 defense of legal claims.
8.8 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 object, we will no longer use your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes for reasons related to your situation, unless the processing is necessary for the performance of a task performed for reasons of common interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to obtain your personal receive data from us in a structured, commonly used and machine-readable format. However, this right does not apply if it would harm the rights and freedoms of others.
8.11 If you believe that our processing of your personal data infringes data protection law, you have the legal right to lodge a complaint with a supervisory authority responsible for data protection. You can do this in the EU Member State of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of the processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by giving us written notice in addition to the other methods specified in this Section 8.
9. About cookies
9.1 A cookie is a file containing an ID (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies can be either “persistent” cookies or “session” cookies: a persistent cookie is stored by a web browser and remains valid until the set expiration date, unless deleted by the user before the expiration date; a session cookie, on the other hand, expires at the end of the user session, when the web browser is closed.
9.3 Cookies generally do not contain any information that would personally identify a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies we use
11. Cookies used by our service providers
12. Managing cookies
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies has a negative impact on the usability of many websites.
12.3 If you block cookies, you will not be able to use all functions of our website.
13. Our data
13.1 This website is owned by Round Enterprise.
13.2 We are registered in Suriname under registration number 52039, and our head office is located at Rossignollaan #18, Paramaribo, Suriname.
13.3 You can contact us:
(a) by post to the above postal address.
(b) via the contact form of our website.
(c) by telephone, at [the contact number published on our website during office hours; or
(d) by email, using the email address published on our website