PRIVACY POLICY

 

 

 

1. Introduction

Atlantic Gold Seaweed Plant Ltd., MONARCHA FHEAMAINN ÓIR AN ATLANTAIGH TEORANTA, a company duly incorporated and registered under the Laws of Ireland Registration No. 741390, and having its principal place of business at Derroe, Ballinahown, Connemara, Co Galway, H91 YCK8, Ireland, which may be contacted at privacy. Sales@AtlanticGoldSeaweed.com (hereafter, “AGSP”), acting as data controller, hereby informs users (hereafter, the “Users”) of its website www.AtlanticGoldSeaweed.com (hereafter, the “Site”) that the data collected shall be used exclusively according to the modalities and for the purposes under this privacy policy, and according to the Regulation (EU) 679/2016 on Data Protection (hereafter, the “Privacy Regulation”).

2. Types of data processed

AGSP shall process, according to this privacy policy, the following personal data collected through the Site:

personal and identifying data and contact details provided by the User at the time of registering with the Site;

data provided in case of requests of information or assistance by the User; and

browsing data of the User on the Site, collected through cookies, according to the cookie policy provided

(hereafter the “Personal Data”).

3. Purposes of the processing

AGSP shall process the Personal Data of the Users for the following purposes:

allow the use of the services offered through the Site, including the registration with the Site through the creation of a personal account, necessary to access to Site’s restricted area;

answering requests of information or assistance sent by the Users, through access to the restricted area mentioned in the previous point, or through the direct contact with members of the staff, agents, distributors, or other subjects appointed by AGSP;

managing complaints and disputes;

for the purposes of compliance with the applicable domestic and European law and/or to answer the requests of public authorities;

(the purposes from point a) to point d) above shall be collectively referred to as “Contractual Purposes”);

performing a potential merger, transfer of assets, transfer of business or business unit, disclosing and transferring the Personal Data of the User to the third party/ies involved;

(the purpose under point e) shall be referred to as “Purposes of Legitimate Interest”)

subject to the prior consent of the User, for sending direct marketing communications through traditional and electronic means (including email, SMS, MMS, social media, instant message systems, mobile applications, banners, faxes, post, and telephone), for the promotion and/or sale of AGSP’s products and/or services, as well as for market surveys or other studies useful for the improvement of its products and/or services

(the purposes under point f) shall be referred to as “Marketing Purposes”)

4. Legal basis of the processing

The processing of Personal Data of the User is necessary with reference to the Contractual Purposes and is carried out, pursuant to Article 6(1)(b) and (c) of the Privacy Regulation, for the purposes of:

using the services of the Site with reference to the cases under Section 3, points a) to c);

complying with the provisions of the applicable laws and regulations as provided for by Section 3, point d).

If the Users do not intend to disclose their Personal Data for such Contractual Purposes, they may not be able to use the services and functionalities of the Site.

The processing of Personal Data of the User for the Purposes of Legitimate Interest shall be carried out pursuant to Article 6, paragraph 1, point f) of Privacy Regulation and therefore for the pursuance of AGSP’s legitimate interests, which is equally balanced with the interests of the Users, since processing of Personal Data is limited to what is strictly necessary for the performance of the activities specified above. The processing for the Purposes of Legitimate Interest is not mandatory and the User may object to the said processing subject to the modalities under this information; in case of objection, User Personal Data may not be used for the Purposes of Legitimate Interest.

Finally, the processing for Marketing Purposes is optional. Should the User deny his consent, he may not receive the commercial communications under Section 3, point f). The Users may at any time withdraw their consents according to the modalities specified in this privacy policy.

5. Modalities to process the data

The Personal Data of the Users may be processed with paper and/or computer means, and they shall be protected through adequate security measures capable of guaranteeing their confidentiality and security.

6. Disclosure of the data

For the Contractual Purposes, the Personal Data of the Users may be transferred to the following categories of intended recipients, located in the European Economic Area: (a) third party service providers that assist and advice AGSP with reference to the activities of the following sectors (by way of mere example): technological, administrative, legal, insurance, and IT; (b) subsidiary/parent or associated companies of the data controller and their suppliers; (c) subjects and authorities whose right to access the Personal Data of the Users is expressly granted by the law, by regulations or other measures issued by the competent authorities. Such intended recipients, depending on the case, will process the Personal Data acting as data controllers, data processors, or other persons in charge of the processing.

For the Purposes of Legitimate Interest specified above, the Personal Data of the Users may be transferred to the following categories of intended recipients, located in the European Economic Area: (a) third party service providers that assist and advice AGSP; (b) subsidiary/parent or associated companies of the data controller and their suppliers; (c) potential buyers of AGSP and entities resulting from the merger or any other form of transformation regarding AGSP; and (d) competent authorities.

For the Marketing Purposes specified above, the Personal Data of the Users may be transferred to the following categories of intended recipients, located in the European Union: (a) third party service providers that assist and advice AGSP with reference to the activities involving the sending of commercial communications; and (b) subsidiary/parent or associated companies of the data controller and their suppliers.

A complete list of data processors appointed by AGSP is available upon request through the modalities specified in this information.

7. Transfer of data abroad

The Personal Data may be freely transferred outside the domestic territory to countries located in the European Economic Area. Any transfer of the Personal Data of the User to Countries located outside the European Economic Area shall take place, in any case, in compliance with the appropriate and adequate guarantees for the purposes of the transfer pursuant to the applicable rules and regulations and in particular pursuant to Articles 45 and 46 of the European Privacy Regulation.

8. Rights of the Users

The Users may exercise the following rights at any time, free of charge, by sending an email at privacy.AGSP@AtlanticGoldSeaweed.com:

obtain from AGSP confirmation as to whether the Personal Data concerning them exist, and receive information about the contents and source of the Personal Data, verify the accuracy thereof and request the Personal Data be integrated, updated, or rectified;

obtain the erasure, anonymization or the blocking of the Personal Data that have been processed in breach of the applicable law, if any;

object in whole or in part to the processing on legitimate grounds; and

withdraw at any time the consent to the processing of Personal Data (in relation to the processing operations for which such consent is possibly necessary) without prejudice to the lawfulness of the processing based on the consent given prior to withdrawal.

In addition to such rights, the Users shall also have the right, which may be exercised at any time, to:

ask AGSP to limit the processing of their Personal Data in the case that: (i) the Users contest the accuracy of their Personal Data for a period enabling AGSP to verify their accuracy; (ii) the processing is unlawful and the Users oppose the erasure of their Personal Data and requests the restriction of their use instead; (iii) although AGSP no longer needs the Personal Data for the purposes of the processing, the Personal Data are necessary to the Users for the establishment, exercise or defence of legal claims; (iv) the Users have objected to the processing pursuant to Article 21(1) of the European Privacy Regulation pending the verification as to whether or not AGSP has compelling legitimate grounds to continue the processing which override those of the data subject;

object to the processing of Personal Data;

request the erasure of the Personal Data concerning them without undue delay;

obtain the portability of the Personal Data; and

lodge a complaint with the competent data protection authority where the necessary requirements for that are met.

9. Retention periods

The Personal Data of the User shall be stored if it is necessary to pursue the specific purposes for which they have been collected, as stated in this privacy policy, and in any case:

for the Contractual Purposes and Purposes of Legitimate Interest, the Personal Data shall be stored for a period equal to the period of use of the services offered through the Site and for the 10 years following the termination thereof, save for the cases in which the storage for a subsequent period is required in the context of a legal proceeding, or by a request of the competent authorities or pursuant to the applicable laws and regulations;

for Marketing Purposes, the Personal Data shall be stored for the time of the registration of the User with the Site, and thereafter for 24 months following deactivation or cancellation of the account;

Once the above-mentioned terms have expired, the Personal Data of the User may be erased, anonymised, and/or aggregated.

10. How can the controller be contacted?

Should the User have any doubts or concerns regarding this privacy policy, or should the User intend to exercise the rights under paragraph 8 above, he/she may contact AGSP at privacy.AGSP@AtlanticGoldSeaweed.com.

11.Updates

This privacy policy shall be valid from the effective date. AGSP, however, may modify and/or update this privacy policy, also because of modifications to and/or updates of the applicable laws and regulations. In any case, the Users shall be informed in advance of any modifications and/or updates, and the text of the updated policy shall be available at Company’s website.

PRIVACY POLICY ON THE PROCESSING OF PERSONAL DATA (CUSTOMERS)

1. Introduction

AGSP (hereinafter referred to as the “Company”) hereby informs that the personal data of the Data subjects (where the latter is a physical person or an individual company), his/her shareholders, employees or appointees which data have been shared in order to carry out the preliminary assessment pertaining to the contract, to which this policy is attached (hereinafter referred to as the “Contract”), between the Company and the other party to the Contract (hereinafter referred to as the “Other Party”), and also during the performance of the contract – and all activities connected thereto – will be processed in accordance with this privacy policy (hereinafter referred to as the “Personal Data”; the individuals to whom the Personal Data refers are hereinafter referred to as the “Data Subjects”).

2. Who is the data controller?

Atlantic Gold Seaweed Plant Ltd., MONARCHA FHEAMAINN ÓIR AN ATLANTAIGH TEORANTA, a company duly incorporated and registered under the Laws of Ireland Registration No. 741390 is the Data controller about the processing of Personal Data. The Company has appointed several data processors. A complete list of all the data processors appointed by the Company is available by contacting the Company at the address indicated in paragraph 10 of this Policy.

3. What types of Personal Data are processed by the Company?

The Company collects and processes Personal Data provided by the Other Party and/or by the Data Subjects, for example data relating to its employees and shareholders, such as, including but not limited to, name, surname, VAT number, email address and phone number.

4. Which are the purposes of the processing?

The Company processes the Data Subjects’ Personal Data using paper or electronic means to:

carry out negotiations and to perform the Contract between the Company and the Other Party;

exercise or defend its rights, including in the context of credit reporting;

comply with obligations arising from applicable laws, including sharing information with competent authorities and supervisory authorities and to comply with their requests;

carry out activities pertaining to the sale of the company or a branch of the company, acquisitions, mergers, divisions, and other transformations, and to carry out these operations; and

with the Other Party’s prior consent – also on behalf of the Data Subjects – to promote products and services offered by the Company, including sending advertising materials and marketing communications, carrying out market research and direct sales activities, either via traditional communication means – such as regular post – or at a distance, for example through email, chat, telephone, SMS, video calls, automated calls, and instant messaging.

5. What is the legal basis for the processing?

Processing of Personal Data is necessary and is carried out pursuant to Article 6(1)(b) and (c) of the Privacy Regulation:

for the performance of the Contract, in accordance with the purposes set out in paragraph 4 a) and b);

to comply with legal obligations in relation to the purposes set out in paragraph 4 c);

The processing of Personal Data for the purposes referred to in paragraph 4(d) is carried out pursuant to Article 6(1)(f) of the Privacy Regulation and, therefore, for the pursuit of a legitimate interest of the Company and its counterparties in the conclusion of the envisaged agreements, which is adequately balanced with the needs of the Data Subjects in that the processing is carried out within the limits of what is strictly necessary for the performance of the operations mentioned in relation to such purposes.

A refusal to provide Personal Data for the purposes set out above would make it impossible for the Company to conclude the Contract or – where already concluded – to continue with its performance.

Processing of Personal Data for the purposes set out in paragraph 4 e) is not mandatory. If the Data Subject refuses to give his consent however, the promotional activities set out here above cannot be performed. At any time, the data subject may revoke any consent given in the manner set out in this privacy policy.

6. How are the Data processed?

Processing will be carried out for the purposes mentioned above, either using IT, automated, or paper means. In any case, the means used will be appropriate to guarantee the safety and confidentiality of the Personal Data.

7. Who has access to these Personal Data?

The Company may share the Personal Data with third-party service providers, persons in charge of carrying out processing activities, organisations, consortia and associations designated to assess credit value, insurance companies, factoring companies and third-party companies that carry out credit collection, marketing and promotional activities on behalf of the Company, or activities that are functionally linked to the management of the Contract, subsidiaries/parent companies or affiliates of the data controller and their suppliers, service providers that are essential to the Company’s activities, such as cloud of IT service providers, experts, consultants or lawyers.

8. Will the Personal Data be transferred abroad?

The Personal Data may be transferred to countries outside the European Economic Area. In this case, the Company will ensure that adequate technical and organisational measures are put in place in accordance with regulations regarding the transfer of Personal Data.

In any case, the Data Subject has the right to obtain a copy of data kept abroad and to obtain information regarding the place where data is kept. To exercise these rights, he/she should contact the Company at the address mentioned in paragraph 10 of this privacy policy.

 

9. For how long is the Personal Data stored?

Personal Data collected for the purposes set out in paragraph 4 a) to d) will be retained for the entire duration of the working relationship and for ten years after it has come to an end, except where it must be retained for a longer period to legal disputes, requests from competent authorities or to comply with applicable laws. Personal Data collected for the purposes set out in paragraph 4 e) will be kept for the entire duration of the Contract and thereafter for a period of 24 months after the Contract has been terminated, for any reason. 

10. Which are the Data Subjects’ rights?

In relation to his/her Personal Data, the Data Subject may – at any time and free of charge – exercise his/her right to (a) obtain the confirmation of the existence or non-existence of Personal Data concerning him/her, as well as copies of the Personal Data; (b) know the origin of the Personal Data, the purposes of the processing, and the methods used, as well as the logic behind processing carried out through automated means; (c) request that the Personal Data be updated, corrected or – if he/she wishes to – integrated; (d) obtain the erasure, transformation into anonymous format or blocking of data processed in violation of the law, as well as object to the processing on legitimate grounds; (e) withdraw his/her consent to the processing of his/her Personal Data, without prejudice to the legality of the processing which occurred before consent was withdrawn.

At any time, the Data Subject may also:

ask the Company to restrict the processing where (i) the Data Subject challenges the accuracy of the Personal Data, for the period required in order to allow the Company to assess the accuracy of the Personal Data; (ii) the processing is unlawful and the Data Subject opposes to the erasure, requesting instead that use thereof be limited; (iii) although the Company does not need to process the Personal Data anymore, the Data Subject needs it in order to establish, exercise or defend a right in court; (iv) the Data Subject has objected to his/her Personal Data being processed pursuant to article 21, paragraph 1 of the Privacy Regulation, pending an assessment of whether the Data Controller’s legitimate grounds for the processing override those of the Data Subject;

object to his/her Personal Data being processed;

request that his/her Personal Data are erased, without undue delay;

obtain the portability of his/her Personal Data; and

if the conditions are met, file a complaint with the competent authority.

Relevant requests may be sent in writing to the Data Controller, at the following email address: privacy.AGSP@AtlanticGoldSeaweed.com.

11. Modifications and updates

This policy will be valid from its entry into force. However, the Company may make changes and/or additions to the policy, also because of possible future legal modifications and/or additions to Privacy Regulation. The text of the updated policy will be published on Company website so that Data Subjects can view it at any time.