Table of Contents
Under the GDPR, the controller is the subject that, alone or jointly with others, determines the purposes and means of the processing of personal information.
The controller for the data processing related to the activities on our Website and projects organized by us is Login5 Foundation incorporated and registered in Liechtenstein, with a registered office at Kirchstrasse 1, 9490 Vaduz.
For any clarification, question or requirement related to your privacy and the processing of your personal data, please contact firstname.lastname@example.org.
- Contact information (such as your name, birthday, nationality, email address, postal address, telephone number and any other personal data) that you provide by completing application forms including if you subscribe to our newsletter
- Details of any transactions made by you (in the event we enter into partnership with you);
- Personal data that may be contained in communications you send to us.
You are under no obligation to provide any such information. Providing your personal data to us is necessary for processing your application in order to consider whether Login5 Foundation wishes to support your idea within our projects.
The refusal to provide us with any personal data necessary for performing our purposes may consequently prevent us from processing your application and/or providing you with other services you may wish to use (such as receiving our newsletter). Therefore, failure to provide personal data may constitute, in some cases, a legitimate and justified reason for not processing your application and/or other requests. Disclosure of personal data is obligatory only if such disclosure is required by law.
We will inform you at every step whether disclosing your personal data to us is required (by law or to enable us to execute services for you) or optional by marking with an appropriate symbol (*). Please note that we mark information with symbol (*) in two events: when the information is required (by law) or needed (for us) for the provision of requested services. You are under no obligation to provide us with data we need for the provision of requested services, however if you fail to provide these data we will not be able to execute services you requested.
Protecting the safety and privacy of children is very important to us. We do not accept registrations or orders submitted by, and will not knowingly collect or use personal data from anyone under the age of sixteen (16) years, or any other age limit set out by the law of his/her country of residence. By registering or submitting an application, you confirm that you have reached the age of majority in your country of residence.
1.4 Use Made of Your Personal Data
Whenever we process your personal data, we do so on the basis of a lawful “justification” (or legal basis) for processing. In the majority of cases, the processing of your personal data will be justified on one of the following bases:
- processing is necessary to perform a contract with you or take steps that you have requested in order to enter into a contract;
- processing is necessary for us to comply with a legal obligation;
- processing is in our legitimate interests as a Foundation, and our interests are not overridden by your interests, fundamental rights or freedoms. Our legitimate interests may include our interest in using user’s personal data to conduct and develop our activities and in establishing, exercising or defending legal claims; or
- processing is based on your prior explicit consent.
|The purposes for which we process your personal data are the following:||The processing of your personal data is justified by the following legal basis:||Retention period|
|I. Processing purposes connected with project applications|
|Communicating with you considering your queries about our Foundation and its projects||Our legitimate interest to ensure quality information to applicants and potential applicants||6 month or until the end of communication|
|Processing your application||Our legitimate interest in order to assess whether application is suitable for cooperation||For the period necessary to examine the application. In the event an agreement is concluded we will store the data for as long as the agreement shall be in force and for additional period in which either party can make any legal claims arising out of this agreement|
|Transferring your application to third persons||Our legitimate interest in order to assess whether application is suitable for cooperation||For the period necessary to examine the application. In the event an agreement is concluded we will store the data for as long as the agreement shall be in force and for additional period in which either party can make any legal claims arising out of this agreement|
|Communication with you considering potential cooperation and conclusion of the agreement||Contractual relationship||6 month until the end of communication in the event an agreement is concluded we will store the data for as long as the agreement shall be in force and for additional period in which either party can make any legal claims arising out of this agreement|
|II. Processing purposes connected with commercial activities and data analytics|
|Send you our e-newsletter containing news, information and updates about our Foundation, projects and activities||Your prior explicit consent||Until withdrawal of consent|
|Improve and customise our Website by tracking your interactions with our Website||Your prior explicit consent||Until withdrawal of consent|
On our Website users can opt-in to receive e-newsletters.
In order to send e-newsletters we shall process your personal data for purposes specified under point II (Processing purposes connected with data analytics and commercial activities).
We always collect the explicit, free and unambiguous consent of users prior to submitting newsletters.
Users can always easily withdraw their consent from receiving e-newsletters and commercial communications in the following ways:
- By clicking on the ‘unsubscribe’ link in any of such email;
- By contacting us via email@example.com.
Our Website collects non-sensitive browsing data by automatic means in order to enable and improve user navigation (e.g., IP address, date/time of the visit and its length, any referring URL, the pages visited on the Site, the device used and other information).
We process Browsing Data for purposes of carrying out data analytics and market research.
The processing of such information allows users to access the Site and fully enjoy its features and services. Furthermore, browsing data may be used to verify that our Website is functioning properly.
We will process Browsing data solely upon your prior explicit consent.
From time to time, browsing data are processed anonymously for statistical purposes.
We may disclose your personal data to any of our affiliate companies, or to our service providers who assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analysing data, providing support services or in performing other tasks, from time to time.
Your personal data will be accessible by authorized personnel of Login5 Foundation and affiliated companies, and service providers acting on our behalf on a need-to-know basis. Transfer of your personal data from your country of residence to third countries (notably to countries where we operate) will be involved; some of these countries are subject to a data protection adequacy decision of the European Commission, whereas others are not, such as the US. To ensure the protection of your personal data is consistent with applicable law, such transfers outside your country of residence or the EEA will be made pursuant to the EU Model Clauses, the EU-US or CH-US Privacy Shield certification, Binding Corporate Rules or other acceptable legal mechanisms.
We may also share your personal data with third parties in connection with potential or actual restructuring of our Foundation or any of our assets, or those of any associated company, in which case personal data held by us about our users may be one of the transferred assets.
We will also respond to requests for personal data where required to do so by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.
We place great importance on the security of all personal data associated with our users. We have adopted security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. For the best possible protection of your personal data outside the limits of our control, your device should be protected (such as by updated antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
While we take reasonable steps to protect your personal data, we cannot guarantee that the personal data you disclose to us will be 100% secure, nor that any data breach will not occur.
You accept the inherent security implications of dealing on-line over the Internet and will not hold Login5 Foundation or their processors responsible for any data breach unless it is due to our negligence.
Our general approach is to retain your personal data only for as long as required to fulfil the purposes for which it was collected. We generally retain your personal data for three years from the end of our relationship or from the last contact from you, unless local law requires otherwise. However, in some circumstances we may retain personal data for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements.
In specific circumstances we may also retain your personal data for longer periods of time corresponding to the applicable statute of limitations so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
1.10 Your Rights
You have the following rights with respect to your personal data:
- Right to withdraw consent – where applicable, you have the right to withdraw your consent at any time. For example, if you wish to opt-out of receiving e-newsletters, you can use the ‘unsubscribe’ link provided in our emails or contact us directly via firstname.lastname@example.org and we will stop sending you communications.
- Right of access, rectification and erasure – you have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances.
- Right of data portability – Under certain conditions, you have the right to receive all such personal data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to restriction of processing – you have the right to restrict our processing of your personal data where:
o you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
o the processing is unlawful but you do not want us to erase the data;
o we no longer need your personal data for the purposes of the processing, but you require such data for the establishment, exercise or defence of legal claims; or
o you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have overriding compelling legitimate grounds to continue processing.
Where personal data is subject to restriction in this way, we will only process it with your consent or for the establishment, exercise or defence of legal claims.
- Right to object to processing justified on legitimate interest grounds – where we are relying upon legitimate interest to process personal data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a justification for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law. You can find your Supervisory authority here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
For further information regarding your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data please contact us via email@example.com.
Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will endeavour to respond to your request as soon as possible and in any case within the applicable timeframes.
Last update – November 2018