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DEALS TERMS AND CONDITIONS

  1. Definitions

The following terms, when used in TOGETHER Terms of Service or any document referred to herein shall have the following meaning:

“Agreement” means these TOGETHER deals Terms of Service.

"TOGETHER" means TOGETHER E-Promotion Co WLL, a corporation organized under the laws of the Kingdom Of Bahrain, located at Office 1716, Business Bay Building, Juffair 340.

“TOGETHER Website” refers to any of the websites operated by TOGETHER for the provision of the Service, including, but not limited to www.togetherinbahrain.com and any websites of business affiliates of TOGETHER on where TOGETHER Coupons are offered.

“Merchant” means a merchant offering to sell goods and/or services at a discounted rate via the Service.

“Order” means customer offer to purchase a Coupon via the Service.

“Restaurant” means a Merchant that offers food and/or beverages for sale in the course of its business and is making such food and/or beverages available to purchasers of Coupons.

“Service” means TOGETHER, the online discount coupon service operated by “TOGETHER” through the TOGETHER Website, consisting of information and advertising services, content and transaction capabilities provided by TOGETHER, affiliates of TOGETHER and other third parties. Where applicable in this Agreement any reference to usage, receipt or provision of the Services shall be deemed to include any access to and/or usage of the TOGETHER Website and entry and participation in giveaways and sweepstakes offered from time to time on the TOGETHER Website.

“Coupon” means a coupon issued by TOGETHER to you on behalf of a Merchant which entitles you to purchase the Merchant’s products and/or services at a discounted rate.

“Web” means the public internet.

“You” means you, the end user of the Service. “Your” shall be construed accordingly.

  2. General

This Agreement sets out the terms and conditions that apply to the provision of the Service by TOGETHER and to any Order placed on the TOGETHER Website in connection with the Service. By using the Service you agree to comply fully with it. You may only use this Service if you are 18 years of age or older. If you do not wish to agree to these terms and conditions (the “Terms of Use” or “Agreement”), or if you are under the age of 18, please refrain from using the Site.

  3. Service Availability

You acknowledge that interruptions in the Service and/or other events may occur that are beyond the control of TOGETHER, and that TOGETHER shall not be responsible for any data lost while transmitting information on the Web or otherwise. While TOGETHER aims to make the Service accessible at all times it may be unavailable from time to time for any reason including, without limitation, routine maintenance. You understand and acknowledge that due to circumstances both within and outside of the control of TOGETHER, access to the Service may be interrupted, suspended or terminated from time to time.

  4. Equipment, Account Management and Security

You are responsible for obtaining and maintaining all telephone, computer hardware and other equipment needed for access to and use of this Site and all charges related thereto. TOGETHER shall not be liable for any damages to the End User’s equipment resulting from the use of this Site.

You are required to create an account in order to use the Service. This is required so we can provide you with easy access to print your orders, view your past purchases, modify your preferences, and to ensure permissible use of the Service.

You are responsible for protecting the confidentiality of your password(s), if applicable.

  5. Your Use of the Service

You agree that your use of the Service will, at all times, be lawful. You agree not to post or transmit through the TOGETHER Website any material which violates or infringes in any way upon the rights of others, or any material which is unlawful, threatening, abusive, defamatory, invasive of privacy or publicity rights, vulgar, obscene, profane or otherwise objectionable, which encourages conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any law, or which, without TOGETHER's express prior, written approval, contains advertising or any solicitation with respect to products or services. Any conduct by you that in TOGETHER's sole discretion restricts or inhibits any other end user of the Service from using or enjoying the Service is strictly prohibited. You agree not to use the TOGETHER Website to advertise or perform any commercial, religious, political or non-commercial solicitation, including, but not limited to, the solicitation of other end users of the Service to become users of other online or offline services directly or indirectly, competitive or potentially competitive with TOGETHER. For your protection, TOGETHER reserves the right, in its sole discretion, to void or reverse any transaction that TOGETHER suspects may be fraudulent.

The foregoing provisions of this Section 5 apply equally to and are for the benefit of TOGETHER, its subsidiaries, affiliates and its third party content providers and licensors, and each shall have the right to assert and enforce such provisions directly or on its own behalf.

  6. Intellectual Property

All content located on or in the TOGETHER Website is the exclusive property of TOGETHER or is used with the express permission of the copyright and/or trademark owner. ANY COPYING, DISTRIBUTING, TRANSMITTING, POSTING, LINKING, DEEP LINKING, OR OTHERWISE MODIFYING OF THE TOGETHER WEBSITE WITHOUT THE EXPRESS WRITTEN PERMISSION OF TOGETHER IS STRICTLY PROHIBITED. Any violation of this policy may result in a copyright, trademark or other intellectual property right infringement that may subject you to civil and / or criminal penalties.

The TOGETHER Website contains copyrighted material, trademarks and other proprietary information, including, but not limited to, text, software, photos, video, graphics, music, sound, and other content of TOGETHER protected by copyright as a collective work under the Kingdom of Bahrain copyright laws. TOGETHER owns a copyright in the selection, coordination, arrangement and enhancement of all such content, as well as in the content original to it. You may not modify, publish, transmit, participate in the transfer or sale, create derivative works, or in any way exploit, any of the content, in whole or in part. You may download / print / save copyrighted material for your personal use only. Except as otherwise expressly stated under copyright law, no copying, redistribution, retransmission, publication or commercial exploitation of downloaded material without the express permission of TOGETHER and the copyright owner is permitted. If copying, redistribution or publication of copyrighted material is permitted, no changes in or deletion of author attribution, trademark legend or copyright notice shall be made. You acknowledge that you do not acquire any ownership rights by downloading copyrighted material. Trademarks that are located within or on the TOGETHER Website shall not be deemed to be in the public domain but rather the exclusive property of TOGETHER, unless such site is under license from the trademark owner thereof in which case such license is for the exclusive benefit and use of TOGETHER, unless otherwise stated.

You shall not upload; post or otherwise make available on the TOGETHER Website any material protected by copyright, trademark or other proprietary right without the express permission of the owner of the copyright, trademark or other proprietary right. TOGETHER does not have any express burden or responsibility to provide you with indications, markings or anything else that may aid you in determining whether the material in question is copyrighted or trademarked. You shall be solely liable for any damage resulting from any infringement of copyrights, trademarks, proprietary rights or any other harm resulting from such a submission. By submitting material to any public area of the TOGETHER Website, you warrant that the owner of such material has expressly granted TOGETHER the royalty-free, perpetual, irrevocable, non-exclusive right and license to use, reproduce, modify, adapt, publish, translate and distribute such material (in whole or in part) worldwide and/or to incorporate it in other works in any form, media or technology now known or hereafter developed for the full term of any copyright that may exist in such material. You also permit any other end user to access, view, store or reproduce the material for that end user's personal use. You hereby grant TOGETHER the right to edit, copy, publish and distribute any material made available on the TOGETHER Website by you.

The foregoing provisions of Section 6 apply equally to and are for the benefit of TOGETHER, its subsidiaries, affiliates and its third party content providers and licensors and each shall have the right to assert and enforce such provisions directly or on its own behalf.

Unless otherwise indicated, all other trademarks appearing on the TOGETHER Website are the property of their respective owners.

  7. No Warranties

YOU EXPRESSLY AGREE THAT USE OF THE SERVICE IS AT YOUR SOLE RISK. NEITHER TOGETHER, ITS AFFILIATES NOR ANY OF THEIR RESPECTIVE EMPLOYEES, AGENTS, THIRD PARTY CONTENT PROVIDERS OR LICENSORS WARRANT THAT USE OF THE SERVICE WILL BE UNINTERRUPTED OR ERROR FREE; NOR DO THEY MAKE ANY WARRANTY AS TO (I) THE RESULTS THAT MAY BE OBTAINED FROM USE OF THE SERVICE, OR (II) THE ACCURACY, RELIABILITY OR CONTENT OF ANY INFORMATION, SERVICE OR MERCHANDISE PROVIDED THROUGH SERVICE.

THE SERVICE IS PROVIDED ON AN "AS IS" BASIS WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF TITLE OR IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, OTHER THAN THOSE WARRANTIES WHICH ARE IMPLIED BY AND INCAPABLE OF EXCLUSION, RESTRICTION OR MODIFICATION UNDER THE LAWS APPLICABLE TO THIS AGREEMENT.

SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF CERTAIN WARRANTIES, THEREFORE, THE ABOVE EXCLUSIONS MAY NOT BE APPLICABLE TO YOU.

  8. Liability

THIS DISCLAIMER OF LIABILITY APPLIES TO ANY DAMAGES OR INJURY CAUSED BY ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DELETION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS, COMMUNICATION LINE FAILURE, THEFT OR DESTRUCTION OR UNAUTHORIZED ACCESS TO, ALTERATION OF, OR USE OF RECORD, WHETHER FOR BREACH OF CONTRACT, TORTIOUS BEHAVIOR, NEGLIGENCE, OR UNDER ANY OTHER CAUSE OF ACTION. YOU SPECIFICALLY ACKNOWLEDGE THAT TOGETHER IS NOT LIABLE FOR THE DEFAMATORY, OFFENSIVE OR ILLEGAL CONDUCT OF OTHER USERS OR THIRD-PARTIES AND THAT THE RISK OF INJURY FROM THE FOREGOING RESTS ENTIRELY WITH YOU.

IN NO EVENT SHALL TOGETHER, OR ANY PERSON OR ENTITY INVOLVED IN PROVIDING THE SERVICE, BE LIABLE FOR ANY DAMAGES, INCLUDING, WITHOUT LIMITATION, DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES ARISING OUT OF THE USE OF OR INABILITY TO USE THE SERVICE. YOU HEREBY ACKNOWLEDGE THAT THE PROVISIONS OF THIS SECTION SHALL, WITHOUT LIMITATION, APPLY TO ALL CONTENT ON THE TOGETHER WEBSITE.

IN ADDITION TO THE TERMS SET FORTH ABOVE, NEITHER TOGETHER, NOR ITS AFFILIATES, INFORMATION PROVIDERS OR CONTENT PARTNERS SHALL BE LIABLE REGARDLESS OF THE CAUSE OR DURATION, FOR ANY ERRORS, INACCURACIES, OMISSIONS, OR OTHER DEFECTS IN, OR UNTIMELINESS OR UNAUTHENTICITY OF, THE INFORMATION PROVIDED IN CONNECTION WITH THE SERVICE, OR FOR ANY DELAY OR INTERRUPTION IN THE TRANSMISSION THEREOF TO YOU, OR FOR ANY CLAIMS OR LOSSES ARISING THEREFROM OR OCCASIONED THEREBY. NONE OF THE FOREGOING PARTIES SHALL BE LIABLE FOR ANY THIRD-PARTY CLAIMS OR LOSSES OF ANY NATURE, INCLUDING WITHOUT LIMITATION, LOST PROFITS, PUNITIVE OR CONSEQUENTIAL DAMAGES.

TOGETHER IS NOT RESPONSIBLE FOR ANY CONTENT THAT YOU, ANOTHER USER, SUBSCRIBER, OR AN UNAUTHORIZED USER MAY POST ON THE TOGETHER WEBSITE. ANY CONTENT THAT IS POSTED OR UPLOADED THAT IS OR MAY BE DEEMED UNSUITABLE CAN AND MAY BE TAKEN DOWN BY TOGETHER. FURTHERMORE, TOGETHER RESERVES THE RIGHT TO EDIT, CHANGE, ALTER, DELETE AND PROHIBIT ANY AND ALL CONTENT THAT IT DEEMS UNSUITABLE IN ITS SOLE DISCRETION.

SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTIAL OR CONSEQUENTIAL DAMAGES, THEREFORE, THIS SECTION 8 MAY NOT BE APPLICABLE TO YOU. IN SUCH JURISDICTIONS, TOGETHER’S LIABILITY IS LIMITED TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.

  9. Indemnity

You agree to defend, indemnify and hold harmless TOGETHER, its affiliates and their respective directors, officers, employees and agents from and against all claims and expenses, including attorney’s fees, arising out of your use of the Service.

  10. Changes

TOGETHER shall have the right at any time to change or discontinue any aspect or feature of the Service including, but not limited to, Merchant deals, content, hours of availability and equipment needed for access or use. Furthermore, TOGETHER may discontinue disseminating any portion of information or category of information, may change or eliminate any transmission method and may change transmission speeds or other signal characteristics.

TOGETHER reserves the right at all times to discontinue or modify this Agreement as we deem necessary or desirable without prior notification to you. Such changes may include, among other things, the adding of certain fees or charges. We suggest to you, therefore, that you re-read this Agreement from time to time in order to stay informed as to any such changes. If we make changes to this Agreement and you continue to use the Service, you will be deemed to have agreed to any such changes. Any deletions or modifications to this Agreement shall be effective immediately upon TOGETHER posting them on the TOGETHER Website. Any use by you of the Service after such notice shall be deemed to constitute acceptance by you of such modifications.

  11. Monitoring

TOGETHER shall have the right, but not the obligation, to monitor the content of the TOGETHER Website at all times to determine compliance with this Agreement and any operating rules established by TOGETHER, as well as to satisfy any applicable law, regulation or authorized government request. Without limiting the foregoing, TOGETHER shall have the right to remove any material that TOGETHER, in its sole discretion, finds to be in violation of the provisions hereof or otherwise objectionable.

  12. Termination

TOGETHER may terminate this Agreement and/or the provision of the Service at any time. Without limiting the foregoing, TOGETHER shall have the right to immediately terminate any of your passwords or accounts in the event of any conduct by you which TOGETHER, in its sole discretion, considers to be unacceptable, or in the event of any breach by you of this Agreement.

  13. Survival

The provisions of this Section 13 as well as Sections 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 14, 15, 16 and 17 will survive termination of this Agreement.

  14. Third Party Content

TOGETHER, similar to any Web service provider, is a distributor (and not a publisher) of content supplied by third parties and end users. Accordingly, TOGETHER has no more editorial control over such content than does a public library, bookstore or newsstand. Any opinions, advice, statements, services, offers, or other information or content expressed or made available by third parties, including information providers, or any other end users are those of the respective author(s) or distributor(s) and not of TOGETHER. Neither TOGETHER nor any third-party provider of information guarantees the accuracy, completeness, or usefulness of any content, nor its merchantability or fitness for any particular purpose.

In many instances, the content available through the Service represents the opinions and judgments of the respective information provider, end user, or other user not under contract with TOGETHER. TOGETHER neither endorses nor is responsible for the accuracy or reliability of any opinion, advice, or statement made on TOGETHER by anyone other than authorized TOGETHER employee spokespersons while acting in official capacities. Under no circumstances will TOGETHER be liable for any loss or damage caused by your reliance on information obtained through TOGETHER. It is your responsibility to evaluate the accuracy, completeness, or usefulness of any information, opinion, advice, etc., or other content available through TOGETHER.

The TOGETHER Website may contain links to third party Web sites maintained by other content providers. These links are provided solely as a convenience to you and not as an endorsement by TOGETHER of the contents on such third-party sites and TOGETHER hereby expressly disclaims any representations regarding the content or accuracy of materials on such third-party Web sites. If you decide to access linked third-party Web sites, you do so at your own risk. Unless you have executed a written agreement with TOGETHER expressly permitting you to do so, you may not provide a hyperlink to the TOGETHER Website from any other website. TOGETHER reserves the right to revoke its consent to any link at any time in its sole discretion.

  15. Miscellaneous

This Agreement, along with the terms and conditions set forth on the Coupon and the terms and conditions set forth on the face of the offer, constitute the entire agreement of the parties with respect to the subject matter hereof. No waiver by either party of any breach or default hereunder is a waiver of any preceding or subsequent breach or default. The section headings used herein are for convenience only and shall be of no legal force or effect. If any provision of this Agreement is held invalid by a court of competent jurisdiction, such invalidity shall not affect the enforceability of any other provisions contained in this Agreement and the remaining portions of this Agreement shall continue in full force and effect. The failure of either party to exercise any of its rights under this Agreement shall not be deemed a waiver or forfeiture of such rights or any other rights provided hereunder.

TOGETHER's headquarters are in Bahrain. Legal issues arising out of, but not exclusive to your usage of the Service shall be governed by and in accordance with the laws of the Kingdom of Bahrain. By using the Service you agree that any dispute or claim arising out of or in connection with this Agreement or the performance, breach or termination thereof, or the TOGETHER Website shall be finally settled by arbitration in Bahrain.

  16. Applicability

By placing an Order, you make an offer to purchase the Coupons you have selected on the terms and conditions described in this agreement and on the deal.

  17. Coupons

The Coupon you purchase via the Service is redeemable for the goods and/or services of a specific Merchant. You acknowledge and accept that the Merchant, not TOGETHER, is the seller of the goods and/or services and is solely responsible for redeeming any Coupon you purchase.

Your usage of Coupons purchased by you via the Service shall be subject to the terms and conditions set forth on the TOGETHER Website that are specific to the deal being offered, the terms and conditions set forth on the Coupon, and to the following additional terms and conditions (unless otherwise prohibited by applicable law):

(i) Terms and Conditions for All Coupons

  • All Coupons printed from the TOGETHER Website or any website associated with TOGETHER are promotional Coupons that are offered to you below their face value and are subject to the terms and conditions of TOGETHER and the participating Merchant.
  • This Agreement incorporates by reference the general legal terms and conditions described here, as well as the specific terms and conditions defined for the concerned deal. In the event of any conflict between these Terms of Service and any terms and conditions set on the Deal itself, these Terms of Service shall prevail.
  • The holder and issuer of a Coupon is the Merchant. As a holder and issuer of the Coupon, the Merchant is fully responsible for any and all injuries, illnesses, damages, claims, liabilities and costs suffered by or in respect to you, whether caused in whole or in part by the Merchant, as well as for any unclaimed property liability arising from unredeemed Coupons.
  • Coupons are not redeemable for cash and have no cash value.
  • Coupons are redeemable in their entirety only and may not be redeemed incrementally. You are not eligible for cash back or a credit for partial redemption of a Coupon.
  • The issuing of credit is at the sole discretion of the Merchant unless otherwise required by law.
  • Neither the TOGETHER nor the Merchant is responsible for lost or stolen Coupons or a Coupon's reference number.
  • Reproduction, sale or trade of a Coupon is strictly forbidden.
  • Any attempted redemption not consistent with these Terms of Service will render the Coupon null and void.
  • If you have not yet redeemed your Coupon at the time of the expiration date and you request to utilize the credit with the Merchant and the Merchant refuses to honor such credit, TOGETHER will not honor this credit.
  • COUPONS ARE NOT REFUNDABLE
  • ORDERS ARE ONLY CONFIRMED UPON PAYMENT
  • You acknowledge that TOGETHER does not collect taxes for remittance to applicable taxing authorities. The Merchant is responsible for paying all applicable taxes to the relevant jurisdictions, including, but not limited to, sales and use tax and occupancy and room tax for any hotel Coupons.

(ii) Terms and Conditions for Restaurant-Specific Coupons

  • Redemption frequency is determined by Restaurants, and shall be contained in the Coupon offer.
  • It is at the discretion of the Restaurant to determine whether Coupons can be combined with any other restaurant certificates, third party certificates, coupons, or promotions.
  • Restaurant-Specific Coupons cannot be used for taxes, tips or prior balances, unless permitted by the Restaurant.
  • Valid for dine-in only unless otherwise stated.
  • Use of Restaurant-Specific Coupons for alcoholic beverages is at the sole discretion of the Restaurant and is subject to compliance with applicable law. Compliance with state statutes is the responsibility of the Restaurant.
  • TOGETHER’s sole role in the transaction is as a marketing agent for the Restaurant-Specific Coupon, and the applicability and compliance with any relevant statute or code is solely determined and consummated by the Restaurant, and TOGETHER has no role in such determination or action on the part of the Restaurant.

(iii) Terms and Conditions for Non-Restaurant Merchant Coupons

  • Coupon may be applied only to goods and/or services sold by Merchant, and may not be applied to shipping or handling charges (unless otherwise specified). Deliveries outside Bahrain will be at extra-charge for the customer
  • Limit one (1) Coupon per redemption. Only one Coupon can be used per Order unless otherwise specified by Merchant.
  • Coupons cannot be combined with any other gift certificates, third party certificates, coupons, or promotions, unless otherwise specified by Merchant.

(iv) Terms and Conditions for Travel Coupons

  • Based on the terms and conditions applicable to the sale of any travel Coupon, you may be eligible to cancel or change your reservations, but some travel Merchants do not offer the right to make cancellations or changes (even with a fee). Any fees related to such cancellation or change will be at the discretion of the Merchant and may vary greatly among the Merchants, depending on the Merchant’s internal policies, the type of deal offered and the location of the deal (among other things). You agree to pay any change or cancellation fees charged to you and you acknowledge that TOGETHER has no liability with respect to these fees.
  • TOGETHER’s sole role in the transaction is as a marketing agent for the Merchant Coupon, and the applicability and compliance with any relevant statute or code is solely determined and consummated by the Merchant, and TOGETHER has no role in such determination or action on the part of the Merchants.

Data protection policy

This policy sets out how TOGETHER E PROMOTION handles the personal data of its employees, customers, suppliers and other third parties. This policy is intended to ensure that we: Protecting the confidentiality and integrity of personal data is a critical responsibility that we take seriously at all times. This policy is therefore intended to apply to the personal data that we process about you. It also applies to you in situations where your role involves you processing data on our behalf. This policy does not form part of any employee’s contract of employment, and we may amend it at any time. It does not override any applicable national data privacy laws and regulations in countries where we operate. We adhere to the principles relating to the processing of personal data, as set out in the GDPR. These require personal data to be: This policy applies to all personal data that we process regardless of the media on which that data is stored, or whether it relates to past or present employees, workers, customers, suppliers, or any other data subject. Anyone who works for the Company, whether or not they are employees, must read, understand and comply with this document when processing personal data. Any breach of the rules contained within this policy may result in disciplinary action. • Comply with data protection law and follow good practice; • Protect the rights of team members, customers and partners; • Are transparent about how we store and process individuals’ data; • Are protected from the risks of a data breach. • Processed lawfully, fairly and in a transparent manner; • Collected only for specified, explicit and legitimate purposes (“purpose limitation”); • Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (“data minimisation”); • Accurate, and where necessary, kept up to date (“accuracy”); • Not kept in a form which permits identification of data subjects for longer than is necessary (“storage limitation”); • Processed in a way which ensures its security, using appropriate technical and organisational measures to protect against unauthorised or unlawful processing, and against accidental loss, destruction or damage (“integrity and confidentiality”); Data protection principles Scope We must process your personal data lawfully, fairly and in a transparent manner. What this means is that we can only process your data fairly and lawfully and for one of the specified purposes (or legal bases) set out in the GDPR. These include the following: We can only process personal data on the basis of one or more of the lawful bases set out in the GDPR, and listed above - these include with the consent of the data subject. Consent can be difficult to obtain under the GDPR. It must freely given, specific, informed and unambiguous. In order to consent to the processing of their personal data, a data subject should indicate their agreement either by a statement or by positive action. You cannot assume that consent has been given in the absence of any express agreement. Data subjects must be easily able to withdraw their consent at any time. We will keep records of all consents, so that we can demonstrate our compliance with this data protection requirement. When we collect personal data about you, whether directly from you or from a third party, then we are obliged to provide you with certain information about that personal data including what we will do with it, who we will share it with and what our legal basis for processing is. That information will be set out in a Privacy Notice (or similar). Fair, lawful and transparent processing

In addition to these 6 core principles there are a number of other obligations on us (as the controller of your data) and rights that you have in relation to your data (as data subject). These include requirements that your personal data is: • Not transferred to another country without appropriate safeguards in place; • Made available to data subjects, who must be allowed to exercise certain rights in relation to their personal data.; • 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 compliance with a legal obligation to which the controller is subject; • Processing is necessary in order to protect the vital interests of the data subject or of another natural person; • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or • 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. We are the Data Controller (or simply Controller) for your data. As the Controller we are responsible for implementing appropriate technical and organisational measures to ensure compliance with the data protection principles detailed above. As part of that responsibility we will appoint a person(s) to be responsible for data protection and we may appoint a suitably qualified Data Protection Officer. We will also take a number of other steps, including to: When we collect personal data it must be only for explicit and legitimate purposes that are clear up front. We may not process the data in any manner that is incompatible with these purposes. If the purposes for data collection and processing change, then we must inform the data subject of these new purposes, and if necessary, we must gain their renewed consent. The data that we collect and process must be limited to what is strictly necessary and relevant for the intended purposes. When any data is no longer needed for these purposes, we must then either delete or anonymise it. We must check the accuracy of any personal data at the point of collection, and at regular intervals afterwards, and either delete or correct inaccurate or out-of-date personal data. Personal data must not be kept in an identifiable form for any longer than is necessary for the stated purposes for which the data is processed. Therefore, we must ensure that when personal data is no longer needed, it is deleted or anonymised. We will require third parties to also delete or anonymise data where and when applicable. We must secure personal data by taking technical and organisational measures against unauthorised or unlawful processing, and against accidental loss, destruction or damage. Such safeguards may include the use of encryption and pseudonymisation. We will exercise particular care in protecting special categories of personal data and criminal convictions data. Should a breach of personal data occur, we will usually notify the appropriate regulator (unless it is assessed that the breach is unlikely to result in a risk to the rights and freedoms of individuals) and, in certain instances, the data subject. We are also obliged to keep a record of all personal data breaches. Accountability Purpose Limitation Data Minimisation Accuracy Storage Limitation Integrity and Confidentiality Personal Data Breaches • Ensure and document GDPR compliance; • Train Company personnel on the GDPR and on our associated policies and procedures. The people whose data we hold (data subjects) have many rights regarding the processing of their personal data. These include, but are not limited to, the following rights to: We are required by law to keep full and accurate records of all our data processing activities. These records include: Data subjects’ rights Record keeping • Withdraw consent to the processing of their personal data; • Request access to their personal data that the company holds; • Prevent our use of their personal data for direct marketing purposes; • Ask us to erase any personal data that is no longer necessary for us to hold; • Ask us to correct any inaccurate or out-of-date data; • Prevent processing of data that is likely to cause damage or distress to the data subject or to anyone else; • Be notified of a data breach which is likely to result in high risk to their rights and freedoms. • Data subjects’ consents to the processing of their personal data; • The name and contact details of our Data Protection Officer, if applicable; • Clear descriptions of the types of data that we hold, and of the types of data subjects whose data we hold; • The purposes of our data processing; • The categories of recipients to whom the personal data has or will be disclosed; • Details of any third-party recipients of personal data; • Where possible the envisaged time limits for erasure of the different categories of data; • Where possible, a description of the security measures in place. • The third party needs to hold the data in order to provide the contracted services; • The privacy notice given to the data subject has made it clear that their data will be given to third parties for express purposes; We are subject to certain rules and privacy laws when marketing to our customers. Customers generally need to give us their consent for us to send them electronic direct marketing communications, for example via emails, texts or automated calls. If a customer opts out of receiving direct marketing communications, we must honour their request promptly.

 

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