Last revised on November 19, 2021
- You are not required by law to provide us with any Personal Data (as defined below). Sharing Personal Data with us is entirely voluntary.
- Our Services are intended for users over the age of 18 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to register to or use the Services. If you are under such age you should cease using the Website or Services immediately.
- We do not sell, trade, or rent users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Website or Services to our users, or other limited circumstances specified herein.
- You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Website or Services may be restricted or disabled.
What Is The Lawful Basis Under Which Saxum Processes Personal Data?
- Where a user uses our Website or Services, we process Personal Data of such user in order provide information and Services to such user or to accept donations from such user;
- We process Personal Data, as described below, under the lawful basis which relies on our legitimate interests. Such interest include, among others, processing Personal Data of our users: (i) as required for the provision of the Services in accordance with Recital 47 of the GDPR; (ii) as necessary for the purposes of preventing fraud or exploiting or abuse of the Website and any the Services ; (iii) as necessary for the performance direct marketing and communication purposes; (iv) as required to be shared among our affiliated corporate entities for the purpose of the provision of the Services; or (v) as required for the prevention of unauthorized access to electronic communications networks and malicious code distribution and stopping ‘denial of service’ attacks and damage to computer and electronic communication systems.
- Some of the Personal Data may be processed by our trusted third-party partners, as described below, under the lawful basis which relies on our legitimate interests, except where such interests are overridden by the fundamental rights of natural persons which require protection of Personal Data.
What Is Personal Data; Types of Data Saxum Collects About Users?
“Non-Personal Data” means non-identifiable information which may be made available or gathered through users’ use of the Website or Services. Please be aware that unlike Personal Data, Non-Personal Data is not identifiable to a specific individual and therefore, while processing Non-Personal Data Saxum is not aware of your identity as a result of such Non-Personal Data.
“Personal Data” means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.
- Non-Personal Data: We collect Non-Personal Data regarding users with respect to their use of the Website or Services, such as the scope, frequency, latency, pages accessed, what and when a user views or interacts with in connection to the content and materials displayed through our Website or Services, and other technical information regarding the device used to access the Services, such as model, operating system, etc.
- Personal Data:
- Account Registration. If you choose to register as a ‘friend of Saxum’ as part of the Services, you will be requested to provide us with certain Personal Data, such as: your full name, e-mail address, billing and credit card information (in case you make a donation), your address and country, etc.
- Newsletter. If you choose to use the “Subscribe” feature on our Website, you will be requested to provide certain Personal Data, such as full name, e-mail address, etc.
- Website. When you interact with our Website or Services, we may collect additional information, such as purchased products/services, session duration, page impressions, advertisements viewed or clicked on, and Internet protocol (IP) address. Saxum also collects certain data regarding your use of the Website or Services, such as the frequency and the extent of your use.
- Donations. If you choose to make a donation to us, you will be requested to provide us with certain Personal Data, such as: your full name, e-mail address, billing and credit card information or Paypal account, your address and country.
- Special Categories of Personal Data. We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Website or collected by us, please inform us immediately.
- We may also acquire information from other trusted sources to update or supplement the data that you voluntarily provide to us or that we collect automatically. Whenever required under applicable law, we will obtain consent prior to collection of Personal Data, and always offer the choice to opt-out.
Sharing Data with Third Parties
- Please note that we do not share any Personal Data collected from you with third parties or any of our partners except in the following events and solely to the extent needed:
- To provide users who make a donation with tax receipts as required by law;
- We may share IP addresses collected by us, for the purpose of detecting any fraud, illegality, security risks or other technical issues as related to the Website or Services or as required for the operation and improvement of the Website or Services;
- If Saxum is required or reasonably thinks that it is required by law or law enforcement agencies to share or disclose your information;
- In any case of conflict, dispute, or legal proceeding of any kind between users and Saxum with respect to, or in relation with the Website or Services;
- As required to prevent damage or breach to the rights or interests (including any legal rights) of third parties, including with respect to safety issues of us, our users or any applicable third party;
- If Saxum organizes the structure or business of the Website or Services within a different framework, or through another legal structure or entity, or in case of sale or merger of Saxum; and
- In certain cases we may disclose Personal Data to our trusted partners and service providers so that they can perform requested services on our behalf, such as for fraud detection, server and data storage providers or for security purposes etc.
- Right of erasure and restriction. You may be entitled to request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
- Reviewing and amending your Personal Data. You may send us a request in connection with reviewing your Personal Data to: firstname.lastname@example.org. In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the Site, where possible.
- Retention of Data. We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analysis and development of the Website or Services; and (iv) to comply with applicable laws, regulations or rules. Non-Personal Data and statistical anonymized data may be retained by us without limitation.
- Portability of Personal Data. To the extent relevant to you and to the Services, you may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
- Objection to processing of Personal Data and Profiling. You have the right to object, to or to request restriction, of the processing of your Personal Data and you have the right to object to profiling.
- Withdrawal of Consent. You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- Cross-Border Data Transfers. You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality.
- Complaints. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution by contacting us at: email@example.com.
Protection of Personal Data
- Although we strive to use our best efforts to protect Personal Data, please be aware that these security measures cannot fully eliminate security risks associated with Personal Data. Therefore, while Saxum strives to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security, and therefore, we shall not be liable for any damages caused by unauthorized access to your Personal Data, unless prohibited by applicable laws and regulations.
- Please note that in the event of a security incident, in which we discover that your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws and regulations).
Will I Receive Promotional Materials from Saxum?
- We do not send users any commercial or promotion information via direct mailing such as emails or SMS messaging without obtaining the users’ explicit prior consent or without such users having to willfully and actively subscribe. You may unsubscribe from receiving such communications at any time, by sending us a notification to: firstname.lastname@example.org, or following the instructions for unsubscribing included in such communications.
- You may manage your subscription to our newsletter, promotions or marketing materials by subscribing or unsubscribing at any time. Please note that if you have set your browser to block cookies, this may have an impact on your ability to unsubscribe. If you have any difficulties managing your email or other communication preferences with us, please contact us at email@example.com.
Will Saxum transfer my Personal Data Internationally?
Persons Under 18
Our Website and Services are intended for a general audience, which is not directed to persons under 18 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 18 years old. If we become aware that a person under 18 years old has provided us with Personal Data, we will delete such data from our databases. If you are aware that your child has provided us with Personal Data, please contact us at: firstname.lastname@example.org.
Links to Third Party Websites/Applications
Questions or Concerns Regarding Privacy
- If you have any questions or concerns regarding privacy issues, please send us a detailed message to: email@example.com and we will make every effort to resolve your concerns without delay.
- You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.