IstiZada Client Privacy Policy

 

IstiZada Client Privacy policy

  1. Introduction

1.1    We are committed to safeguarding the privacy of our clients and the data they entrust to us.

1.2    This policy applies where we are acting as a data processor with respect to the personal data of our clients; in other words, where we determine the purposes and means of the processing of that personal data.

1.4    Our client websites incorporate privacy controls which 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 and limit the publication of your information. You can access the privacy controls for the client website you are using by emailing [email protected] to ask about the privacy controls of the client website you are using.

1.5    In this policy, “we”, “us” and “our” refer to IstiZada, and it’s employees.[ For more information about us, see Section 13.]

  1. Credit

2.1    Due to the recency or some ambiguous articles in the GDPR law IstiZada consulted various sources to ensure our compliance with the law and this document was created using a GDPR template from SEQ Legal (https://seqlegal.com).

  1. How we use your personal data

3.1    In this Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain 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 data about your use of our clients’ websites and services (“usage data“). 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 clients’ data analytics platform, typically this is Google Analytics or their Email Service provider. 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 consent OR our legitimate interests, namely monitoring and improving our clients’ websites and services.

3.3    We may process your account data on our clients’ platform (“account data“).  The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our clients’ websites, providing our services to our clients, ensuring the security of our clients’ websites and services and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our clients’ websites and businesses.

3.4    We may process your information included in your personal profile on our clients’ websites (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of our clients’ websites and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our clients’ websites and businesses.

3.5    We may process your personal data that are provided in the course of the use of our clients’ services (“service data“). The service data may include a wide variety data related to the services our clients offer, for information about the exact service data we process for a specific client, contact us at [email protected]. The source of the service data is you and in some cases how you use our clients’ services. The service data may be processed for the purposes of operating our clients’ websites, providing our clients’ services, ensuring the security of our clients’ websites and services and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our clients’ websites and business.

3.6    We may process information contained in any enquiry you submit to our clients 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 OR our legitimate interests, namely the proper administration of our clients’ websites and business.

3.7    We may process information relating to transactions, including purchases of goods and services, that you enter into our with clients and/or through our clients’ websites (“transaction data“). The transaction data may include your contact details and the transaction details. We do not process credit card details and ask our clients to not provide us with this data. 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 our client and you, and/or our interest in the proper administration of our clients’ websites and business to provide users with an experience tailored to their needs.

3.8    We may process information that you provide to our clients for the purpose of subscribing to our clients’ 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.

3.9    We may process information contained in or relating to any communication that you send to us or our clients (“correspondence data“). The correspondence data may include [the communication content and metadata associated with the communication. Our clients’ websites 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 clients’ websites and business and communications with users.

3.10  We may process other personal data that our clients provide us with so long as our clients have given us permission to process this personal data and have received consent for us to process this data.  The legal basis for this processing is consent.

3.11  We may process any of your 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.

3.12  We may process any of your 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.

3.13  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing 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.

3.14  Please do not supply any other person’s personal data to us or our clients, unless we prompt you to do so.

  1. Providing your personal data to others

4.1    We may disclose your personal data to any member of our company insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. All employees who will process data will under go IstiZada GDPR training before processing data.

4.2    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.

4.3    We may disclose your personal data to our suppliers or subcontractors only by requesting and receiving permission from our clients who must also have received your permission to disclose your personal data first.

4.4    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure 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. 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.

  1. International transfers of your personal data

5.1    In this Section 5, we provide information about the circumstances in which your personal data may be transferred.

5.2    We IstiZada will keep personal data on our clients’ servers and will not transfer personal data internationally.

5.3    The hosting facilities for our clients’ websites are situated in their respective home countries. IstiZada will not transfer data outside of their existing home country environments.

5.4    You acknowledge that personal data that you submit for publication through our clients’ websites or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

  1. Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    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.

6.3    We will retain your personal data as follows:

(a)    IstiZada will not retain your personal data unless you have given permission to our clients for them to share your data with their contractors. IstiZada uses aggregate data that is not personally identifiable so there isn’t a need for us to have your personal data. As a result of this we ask our clients to avoid sharing personal data with us and we have no intention of retaining your data.

(b)    Personal data retained by our clients will be retained for only the period of time outlined in their privacy policy. For the privacy policies of a specific IstiZada clients please email [email protected] for more details about specific client privacy policies.

 

6.4    Notwithstanding the other provisions of this Section 6, 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.

  1. Amendments

7.1    We may update this policy from time to time by publishing a new version on our websites.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    We may notify you of changes to this policy by email or through the private messaging system on our clients’ websites.

  1. Your rights

8.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the payment of a fee (currently fixed at $15 USD); and

(b)    the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address)].

8.2    We may withhold personal information that you request to the extent permitted by law.

8.3    You may instruct us at any time not to process your personal information for marketing purposes.

8.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

OR

  1. Your rights

8.1    In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

8.3    You have the right to confirmation as to whether or not 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. To access your personal data that IstiZada has access to please email [email protected] to get access to this data.

8.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5    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; 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 defense of legal claims.

8.6    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.

8.7    You have the right to object to our processing of your personal data on grounds relating to your particular 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.

8.8    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 make such an objection, we will cease to process 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 on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public 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 party or in order 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 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.

8.11  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.

8.12  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.

8.13  You may exercise any of your rights in relation to your personal data by written notice to us by email at [email protected] or by mail at:

IstiZada L.L.C.

2533 Far Hills Ave.

Dayton, Ohio 45419

USA

  1. About cookies

9.1    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.

9.2    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.

9.3    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.

  1. Cookies that we use

10.1  For information about the cookies that one of our clients uses please email us at: [email protected].

11.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(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).

11.2  Blocking all cookies will have a negative impact upon the usability of many websites.

11.3  If you block cookies, you will not be able to use all the features on our website.

 

  1. Our details

12.1  This website is owned and operated by IstiZada L.L.C.

.

12.2  We are registered in the United States of American under registration number 81-0975324, and our registered office is at:

2533 Far Hills Ave.

Dayton, Ohio 45419

USA

 

12.3  Our principal place of business is at 2533 Far Hills Ave. , Dayton, Ohio 45419 USA and online at IstiZada.com.

12.4  You can contact us:

(a)    by post at 2533 Far Hills Ave. , Dayton, Ohio 45419;

(b)    On our website Istizada.com/contact-us/

(c)    By Phone at +1 858 633 3610

(d)    By email at [email protected]

 

  1. Data protection officer

13.1  Our data protection officer’s contact details are:

Jordan Boshers

Data Protection Officer

+1 858 633 3610 ext.146

[email protected]