920 Solutions is fully committed to comply with applicable data protection laws, as we believe that ensuring data protection is the basis of trustworthy business relationships
We are always working to stay compliant – encourage audits, certifications, and provide industry-standard contractual protections.
This Data Protection Policy ensures the level of data protection prescribed by the European Union Data Protection Regulations and provides one of the necessary framework conditions for cross-border data transmission.
PRINCIPLES OF PERSONAL DATA PROCESSING
We have to collect and use (to process) certain types of information (Personal Data) that relates to the people (Data Subjects) who we come into contact with in order to carry out our business.
We are confident that when processing personal data, the individual rights must be protected what means that all personal data must be collected and processed in a legal and fair manner.
Therefore we presume and agree that Personal data shall be:
- (a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
- (b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’)
- (c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’);
- (d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
- (e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’);
- (f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).
LAWFULNESS OF PROCESSING
To make processing compliant, we should ensure it has at least one legitimate reason for processing (collecting, using, managing or disclosing) personal data. According to Article 6 (1) of EU Regulation No 2016/679 (General Data Protection Regulation or GDPR) such reasons could be:
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
Please note, that in some circumstances prior consent is not necessary. Article 6 (1) of EU Regulation No 2016/679 (General Data Protection Regulation)
HOW DO WE COLLECT YOUR PERSONAL INFORMATION
These are the main ways we collect your information:
- you contact us directly via our website to request information about our services.
- you reply to our direct marketing campaigns.
- we acquired your personal data from other sources, such as social media sites.
If you are under 16, please do not provide us with any of your information unless you have the permission of your parent or guardian.
Please help us to keep your information up to date by informing us of any changes to your contact details as we respect your right to obtain the rectification of inaccurate personal data and the right to have incomplete personal data completed. Also, please be noticed that you have the right to obtain from us the erasure of personal data («right to be forgotten») according to point (a) of the Article 17 (1). In order to use this right please contact us at: firstname.lastname@example.org
WHAT PERSONAL DATA MAY BE COLLECTED
The following types of personal information about you may be collected:
- phone numbers,
- e-mail address.
Also, when you visit our website, the web servers automatically recognize your domain name and IP address. The IP address of the site that directed you to our website, operating system version and your web browser would be disclosed too as a related information. Nevertheless, this information does not relate to you directly and could not identify your personality so it could not be treated as personal data.
HOW DO WE KEEP PERSONAL DATA SAFE
We believe that personal information must be collected and dealt with appropriately, thus there must be safeguards in place to ensure this. Although data transmission over the Internet cannot be guaranteed to be secure, we work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. We use technical and organizational security measures including encryption and authentication tools to protect your personal information, against manipulation, loss, destruction, and access by third parties. Our main security measures are:
- restricted access to your data on a “need to know” basis
- transfer of data only in encrypted form
- firewalled IT systems to prohibit unauthorized access
- permanently monitored access to IT systems to detect and stop any misuse.
Every data subject is guaranteed the following rights. Their assertion is to be handled immediately by the responsible unit and cannot pose any disadvantage to you.
- Right of Access by the Data Subject: You shall have the right to receive information from us regarding the processing of your personal data.
- Right to Rectification: You shall have the right to demand that we correct your personal data which are incorrect and/or incomplete.
- Right to Erasure: You shall have the right, in the event that the requirements specified in Art. 17 of the GDPR have been met, to demand the deletion of your data. Thus, in accordance with this Art. 17, for example, you may demand the deletion of your data insofar as these data are no longer required for the purposes for which they were collected. Furthermore, you may demand the deletion of these data if we process your data based upon the consent which you have granted and you then withdraw this consent.
- Right to Restriction of Processing: You shall have the right to demand the restriction of the processing of your data if the requirements specified in Art. 18 of the GDPR have been fulfilled. This is, for example, the case if you dispute the correctness of your data. For the duration of the verification of the correctness of the data, you may demand the restriction of the processing.
- Right to Object: If the processing is based upon an overriding interest or your data are used for the purposes of direct advertising, you shall have the right to object to the processing of your data.
- Right to Data Portability: Insofar as the data processing is undertaken based upon a consent or a fulfilment of a contractual agreement and this is also undertaken while using an automated processing system, you shall have the right to receive your data in a structured, commonplace and machine-readable format and to transfer these data to another data processing service provider.
- Right of Revocation: If the data processing is undertaken based upon a consent, you shall have the right to withdraw your consent for the data processing, with effectiveness for the future, at any time and upon a free-of-charge basis, by using the following address: email@example.com
- Right to Complain: You shall also have the right to complain to a government supervisory authority regarding our processing of your data.
920 Solutions has offices in many countries. You are consent that, if it was necessary, the processing of your Personal Data could be held on a server located in the country different from the country of your residence. These countries may have data protection laws that are different to the laws of your country.