PRIVACY POLICY

We treat the personal data you provide when using our website and offers confidentially and in accordance with the statutory data protection regulations and this data protection declaration. In the following, we would like to inform you in detail about which of your personal data we collect, for which purposes they are used, with whom they are shared and which control and information rights you may have.

1. Responsible person and contact

Responsible for this website is Circu Li-Ion S.A., 5 Rue de l'Industrie, L-1811 Luxembourg, Grand Duchy of Luxembourg  (hereinafter "Circu Li-Ion" or "we"). If you have any questions about this privacy policy or about the collection, processing or use of your personal data, please feel free to contact us - under the keyword "data protection" - by email at info@circuli-ion.com.

2. Definitions

  • Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to that person, such as a name, an identification number, location data or an online identifier.

  • Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as the collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • Controller is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

  • Third party means any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who are authorized to process the personal data under the direct responsibility of the controller or processor; this also includes other group-affiliated legal entities.

  • A processor is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller, in particular in accordance with the controller's instructions (e.g. IT service provider). In particular, a processor is not a third party in the sense of the data protection law.

  • Consent of the data subject shall mean any freely given specific, informed and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

​​

3. Processing of your data when using our website for information purposes only

If you visit our website for informational purposes only, without providing personal data via registration or in any other way, only the Internet connection data that your browser transmits to our server will be processed. This information contains personal data only to a limited extent. The processed data includes information on:

  • your IP address

  • your device (type, name, ID)

  • your browser (type/version)

  • your operating system (including language settings)

  • the date and time of your requests

  • the content of your requests

  • your screen resolution

  • your Internet service provider

  • websites from which your system accesses our website (referrer URL)

  • web pages that are accessed by your system via our website.

This information is processed to enable you to use our website (for example, by adapting our website to the needs of your device) and to gather broad demographic information to create anonymized statistics about the use of our website. This data is not merged with other data sources.

The legal basis for this data processing is Art. 6 (1) p. 1 lit. b DSGVO, as we need the automatically collected data for the effective provision of our website, as well as Art. 6 (1) p. 1 lit. f DSGVO, as the storage serves our legitimate interest in ensuring the stability and security of the website. For more information on the collection of personal data when visiting our website, please refer to the section "Cookies".

4. Data processing during the use of our services

We offer further tools or services on our website (e.g. contact and newsletter), when using which we request personal data from you, such as name or e-mail address and, if applicable, further personal information. Correspondingly required information is always marked as mandatory fields. Without this information, we may not be able to provide you with the requested service or answer any inquiries you may have. In the following, we provide you with an overview of the related processing operations and legal basis.

4.1 Contact

If you contact us - e.g. by contact form or by email - your personal data will be stored and processed by us. This is usually your name and email address, as well as the information you have otherwise provided. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration and is not passed on to third parties without your consent.

The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. b DSGVO, insofar as it is carried out for the fulfillment of a contract or pre-contractual measures, as well as Art. 6 para. 1 p. 1 lit. f DSGVO, as the processing of these requests is in the interest of both parties.

4.2 Newsletter

If you register for our newsletter, which informs you about our latest products and services, the personal data you provide in this context (such as name, address and email address) will be processed by us for sending the newsletter.

You can object to the sending of such newsletters at any time in the future without giving reasons by unsubscribing via the unsubscribe link at the end of each newsletter or by contacting us otherwise. At the same time, your consent to the use of the newsletter shipping platform MailChimp and the statistical analyses by MailChimp will expire.

a) Dispatch via MailChimp

The newsletter is sent using MailChimp, a newsletter sending platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.

The email addresses of our newsletter recipients, as well as their other data described in the context of this notice, are stored on MailChimp's servers in the US. MailChimp uses this information to send and evaluate the newsletter on our behalf. Furthermore, according to its own information, MailChimp may use this data to optimize or improve its own services, e.g. to technically optimize the dispatch and display of the newsletters or for economic purposes to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them itself or to pass them on to third parties.

You can view the privacy policy of MailChimp here https://mailchimp.com/legal/privacy/.

The legal basis for the processing of your user data for the newsletter dispatch is your consent according to Art. 6 para. 1 p. 1 lit. a DSGVO.

b) Statistical evaluation of the newsletter via "web-beacons".

The newsletters contain a so-called "web-beacon", (invisible graphics), i.e. a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. As part of this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of the call are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on the retrieval locations (which can be determined with the help of the IP address) or the access times.

The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked on. This information can be assigned to individual newsletter recipients for technical reasons. However, it is not our endeavor, nor the endeavor of MailChimp, to observe individual users. Rather, the evaluations serve to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The legal basis for the performance of statistical surveys and analyses as well as the logging of the registration process is your consent pursuant to Art. 6 (1) p. 1 lit. a DSGVO.

4.3 ​ Online advertising and analysis tools

a) Cookies

This website uses cookies. Cookies are small text files that are stored on your personal device. These text files can be read by these websites and help to identify you when you visit a website again. Some cookies are used to store preferences and are deleted after the end of the browser session, i.e. after closing the browser, so-called session cookies. Other cookies are used to better adapt the website to user needs and remain on the customers device, so-called permanent or persistent cookies. Below, we explain which cookies we use and how you can object to the use of cookies.

We use our own cookies that enable the customer-friendly use of our website, for example by storing your settings. At the end of a browser session, these cookies are automatically deleted. The legal basis for the use of such cookies is the fulfillment of the contract (Art. 6 para. 1 p. 1 lit. b DSGVO). In addition, we use our own cookies to evaluate the use of our website. We base this data processing on our legitimate interest according to Art. 6 para. 1 p. 1 lit. f DSGVO.

We also work with other service providers who help us improve our website or offer additional features. Such service providers may use their own cookies. You can find more information about this in the following sections.

You can configure your browser such that you are informed about the settings of cookies, allow cookies only in individual cases, limit the acceptance of cookies to certain cases or generally exclude them, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

Any use of cookies that is not absolutely technically necessary constitutes data processing that only takes place with your explicit and active consent pursuant to Art. 6 (1) p. 1 lit. a DSGVO.

b) Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called cookies. The information generated by the cookie about your use of this website is transmitted to a Google server and stored there. We have activated the IP anonymization function on this website. This means that your IP address is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

The storage of Google Analytics cookies is based on your consent, Art. 6 para. 1 p. 1 lit. a DSVGO.

This website uses the "Demographics" function of Google Analytics. This allows reports to be generated that contain statements about the age, gender and interests of website visitors. This data comes from interest-based advertising from Google as well as visitor data from third-party providers. This data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account.

You can prevent the use of Google Analytics, including the "Demographics" function, at any time, either by installing the Google browser plugin, which sets an opt-out cookie, or by selecting the appropriate setting in your browser software. We would like to point out that in this case you may not be able to use all functions of this website to their full extent.

 

For more information, please visit https://tools.google.com/dlpage/gaoptout?hl=de and https://www.google.com/analytics/terms/de.htm.

 

For more information on how Google Analytics handles user data, please see Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

c) Google Ads and Google Conversion Tracking

This website uses Google Ads. Google Ads is an online advertising program of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Within the scope of Google Ads, we use the so-called conversion tracking. When you click on an ad placed by Google, a cookie (see above) is set for conversion tracking. This cookie loses its validity after 30 days and is not used to personally identify users. If the user visits certain pages of this website and the cookie's validity period of 30 days has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this website.

Each Google Ads customer receives a different cookie. The cookies cannot be tracked through Google Ads customers' websites. The information collected using the conversion cookie is used to create conversion statistics for Ads customers who have opted in to conversion tracking. We learn the total number of users who clicked on our ad and were redirected to a web page tagged with a conversion tracking tag. However, we do not receive any information that personally identifies users. If you do not wish to participate in the tracking, you can object to this use by simply deactivating the Google conversion tracking cookie via your internet browser under user settings. You will then not be included in the conversion tracking statistics. You can find more information on this at https://support.google.com/ads/answer/7395996.

The legal basis is your consent in accordance with Art. 6 para. 1 p. 1 lit. a DSGVO.

You can find more information about Google Ads and Google Conversion Tracking in Google's privacy policy: https://www.google.de/policies/privacy/.

d) Facebook Ads, Customs Audience

We use online marketing services of the provider Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").

FFacebook Ads, Facebook Pixel as well as Website Custom Audience including retargeting are used.

Through Facebook Pixel, cookies are set in your browser when you visit our websites through Facebook. With the help of Facebook Pixel, it is possible for Facebook to recognize visitors to our websites as users of the Facebook network and to assign them to interest groups (interests in certain products and services of the websites visited). 

The cookies are used to create so-called user profiles, by means of which the relevant information about the user is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information (device information, metadata), such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this can also be processed. The tracking of usage also takes place across devices.

As a result, our advertisements (so-called "Facebook ads") are only displayed within the Facebook network to users who have also shown a potential interest in our online offering. 

In your own use of the Facebook social network, this data can be assigned to your user profile there. As a matter of principle, we only receive access to summarized information about the success of our advertisements and can publish advertising campaigns and advertisements to the relevant interest groups (Custom Audience).

With the help of the Facebook pixel, we can also analyze the success of our marketing measures.

These cookies can later generally also be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data.

You can find more information about data protection at Facebook here https://www.facebook.com/about/privacy. You can object to the collection by the Facebook pixel and the use of your data. You can change the settings for user-based advertising here: https://de-de.facebook.com/ads/settings. You can also prevent the Facebook Pixel cookie from being set by setting your browser accordingly.

If you have a Facebook account, you can disable the features in the Ads Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. If you do not have a Facebook account, you can disable behavioral advertising from Facebook on the European Interactive Digital Advertising Alliance website: https://www.youronlinechoices.com/uk/your-ad-choices.

In doing so, we process your personal data on the basis of your consent pursuant to Art. 6 (1) sentence 1 lit. a DSGVO with regard to the processing of your personal data in connection with the analysis of our offers as well as a targeted and economic optimization of our marketing measures.

e) Hubspot

We use the Hubspot analytics service on our website. The service is operated by HubSpot, Inc, 25 First Street, 2nd Floor, Cambridge, MA 02141 USA.

Hubspot uses so-called cookies. The information generated by the cookies about your use of our website is transmitted to a Hubspot server and stored there. Based on this information, we evaluate your use of the website in order to optimize and further develop our offer.

Furthermore, your contact information will be stored at Hubspot if you have filled out our "Request a demo" form and have given your consent for data processing. You can ask us to delete your contact data at any time.

You can find more information about data protection at Hubspot here:

https://legal.hubspot.com/de/privacy-policy.

The legal basis for the data processing is your consent according to Art. 6 para. 1 p. 1 lit. a DSGVO.

5. Company profiles in social networks

Our presence on social networks allows us to get in touch with you outside of our website. In the following, we inform you about which data is processed when you visit our company profile.

5.1 Facebook and Instagram fan pages

We operate fan pages as part of the social networks Facebook and Instagram, a service of Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. We use the fan pages to inform users about our company and current developments and to communicate with our users.

Users have the option of sending us messages via our fan pages using Facebook Messenger or Instagram Direct Messages, as well as sharing our posts, commenting on them or giving them a "Like". In doing so, profile data (in particular the name of the user), as well as the respective interaction (e.g. the content of the message or comment) are processed by us. The data processing is based on your consent according to Art. 6 para. 1 p. 1 lit. a DSGVO. If the communication (via Messenger or Direct Messages or the comment functions) serves the purpose of fulfilling a contract or carrying out pre-contractual measures, the legal basis for this data processing is Art. 6 para. 1 p. 1 lit. b DSGVO.

We use the "Insights" function as part of our fan pages. These are page statistics provided by Facebook, through which we obtain information about how users interact with our fan page. Page Insights may be based on personal data collected in connection with a user's visit to or interaction with our fan page and its content. Facebook and we are jointly responsible for the processing of the Insights data and have concluded an agreement within the meaning of Art. 26 DSGVO.

 

The agreement can be viewed at the following link: https://www.facebook.com/legal/terms/page_controller_addendum.

In addition, personal data is processed by Facebook when you visit our fan pages. We have no influence on this data processing. The purpose and scope of data processing by Facebook as well as the related rights and setting options for protecting the privacy of users can be found in the data policy for Facebook (https://www.facebook.com/about/privacy/) and Instagram (https://help.instagram.com/519522125107875).

5.2 XING

We operate a company profile on the Xing portal, a service provided by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. We use the Xing profile to present our company and to get in touch with potential employees.

You have the option of contacting us via our Xing profile. In doing so, the available profile data (e.g. job title, company name, industry, education, contact options, photo) as well as the content of the message will be processed by us in order to handle your request. The legal basis for this data processing is Art. 6 (1) sentence 1 lit. b DSGVO, provided that the communication serves the purpose of fulfilling the contract or carrying out pre-contractual measures. In other cases, the data processing is based on your consent pursuant to Art. 6 (1) sentence 1 lit. a DSGVO. If you submit an application to us via Xing, your name, contact data, qualifications, and other data contained in the application will be processed for the purpose of evaluating and possibly conducting an application process. For this purpose, the application documents may be forwarded internally to the responsible and decision-making employees. The data processing is based on § 26 para. 1 BDSG. Additional voluntary information is processed on the basis of Art. 6 para. 1 p. 1 lit. a DSGVO. After completion of the application process, the data is deleted after six months at the latest, unless the data is required for the implementation of a possible employment relationship. In addition, we contact Xing users directly if the information in their profile has aroused our interest. In doing so, we process the available profile data. The legal basis is Art. 6 para.1 p. 1 lit. f DSGVO. We have a legitimate interest in contacting other users via Xing.

If you register for an event organized by us via Xing, we will process your profile data to enable you to participate in the event. The legal basis is Art. 6 para.1 p. 1 lit. b DSGVO.

In addition, personal data may be processed by Xing when you visit our Xing profile. We have no influence on this data processing. The purpose and scope of data processing by Xing, as well as the related rights and setting options for protecting the privacy of users, can be found in the privacy policy of Xing (https://privacy.xing.com/en/privacy-policy).

5.3 LinkedIn

We operate a company profile on the LinkedIn portal, a service provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. We use the LinkedIn profile to present our company and to get in touch with potential employees.

You have the option of contacting us via our LinkedIn profile. In doing so, the available profile data (e.g. job title, company name, industry, education, work experience, skills, contact options, photo) as well as the content of the message will be processed by us in order to handle your request. The legal basis for this data processing is Art. 6 (1) sentence 1 lit. b DSGVO, provided that the communication serves the purpose of fulfilling the contract or carrying out pre-contractual measures. In other cases, the data processing is based on your consent according to Art. 6 para. 1 sentence 1 lit. a DSGVO. If you submit an application to us via LinkedIn, your name, contact details, qualifications and other data contained in the application will be processed for the purpose of evaluating and possibly conducting an application process. For this purpose, the application documents may be forwarded internally to the responsible and decision-making employees. The data processing is based on § 26 para. 1 BDSG. Additional voluntary information is processed on the basis of Art. 6 para. 1 p. 1 lit. a DSGVO. After completion of the application process, the data will be deleted after six months at the latest, unless the data is required for the implementation of the employment relationship.

In addition, we contact LinkedIn users directly if the information in their profile has aroused our interest. In doing so, we process the available profile data. The legal basis is Art. 6 para.1 p. 1 lit. f DSGVO. We have a legitimate interest in contacting other users via LinkedIn.

When visiting our LinkedIn profile, personal data may be processed by LinkedIn. We have no influence on this data processing. The purpose and scope of data processing by LinkedIn, as well as the relevant rights and settings options for protecting the privacy of users, can be found in the privacy policy of LinkedIn (https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy).

6. Third-party services

6.1 Google Web Fonts

This website uses so-called web fonts provided by Google for the uniform display of fonts. The provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When you call up a website, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly.

For this purpose, the browser you use must connect to Google's servers. This enables Google to know that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a uniform and appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 (1) p. 1 lit. f DSGVO.

If your browser does not support web fonts, a default font is used by your computer.

For more information on Google Web Fonts, please visit https://developers.google.com/fonts/faq and see Google's privacy policy: https://www.google.com/policies/privacy/.

6.2 Vimeo

We integrate videos from the Vimeo platform, operated by Vimeo, Inc., 555 West 18th Street, New York, New York 10011, USA, into our online offering.

In the process, usage and communication data, device data and content data may be transmitted to the provider. The legal basis here is also Art. 6 para. 1 lit. f DSGVO. Our legitimate interests lie in the user-friendly integration of videos and their optimal presentation.

Further information on data protection at Vimeo can be found here: https://vimeo.com/privacy. Vimeo may use Google Analytics for its own purposes. You can object to the processing by following the procedure described above for Google Analytics.

6.3 Userlike

We integrate the communication service of Userlike into our online offer. The service is operated by Userlike UG (haftungsbeschränkt), Probsteigasse 44-46, 50670 Cologne, Germany.

In the process, usage and communication data, device data and content data may be transmitted to the provider. The legal basis here is also Art. 6 para. 1 lit. f DSGVO. Our legitimate interests lie in the integration of a user-friendly communication service to increase the attractiveness of our website.

Further information on data protection at Userlike can be found here: https://www.userlike.com/en/terms#privacy-policy. Userlike may use Google Analytics for its own purposes. You can object to the processing by following the procedure described above for Google Analytics.

7. Transfer of personal data to third parties

The following categories of recipients, which are usually processors, may receive access to your personal data:

  • Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data center services, IT security, usage analysis). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f DSGVO, insofar as they are not order processors;

  • Government agencies/authorities, insofar as this is necessary to fulfill a legal obligation. The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. c DSGVO;

  • Persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. b or lit. f DSGVO.

In addition, we will only disclose your personal data to third-parties if you have given your explicit consent to do so in accordance with Art. 6 (1) p. 1 lit. a DSGVO.

8. Transfer of personal data to third countries

Within the scope mentioned above, it is possible that we transfer your personal data to other countries (including countries outside the EEA, so-called third countries), where different data protection standards may apply than in your place of residence.

Please note that the data processed in other countries may be subject to foreign laws and may be accessible to local governments, courts, law enforcement and regulatory authorities. However, when transferring your personal data to third countries, we will take appropriate measures to adequately secure your data.

In the case of transfers to third countries, the transfer is usually protected by the application of the so-called EU standard contractual clauses. Corresponding evidence or further details on this can be requested by e-mail to info@circuli-ion.com.

9. Data security

We have appropriate, state-of-the-art security measures in place to protect your data from loss, misuse, and alteration. For example, our security policies and privacy statements are regularly reviewed and improved as needed. In addition, only authorized employees have access to personal data. Although we cannot guarantee or warrant that loss, misuse or alteration of data will never occur, we do everything in our power to prevent it.

Please keep in mind that data transmission over the Internet is never completely secure. We cannot guarantee the security of data entered on our website during transmission over the Internet. This is done at your own risk.

Our website uses SSL encryption, TLS encryption respectively, for security reasons and to protect the transmission of confidential content, such as requests that you send to us as the website operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line. If SSL encryption or TLS encryption respectively, is activated, the data you transmit to us cannot be read by third parties.

10. Your rights

You have the following data protection rights, depending on the circumstances of the specific case:

  • Information: You have the right to request information about and access to your personal data and/or copies of this data. This includes information about the purpose of the use, the category of data used, its recipients and authorized persons and, if possible, the planned duration of data storage or, if this is not possible, the criteria for determining this duration.

  • Correction, blocking, deletion: You have the right to demand the correction, deletion or restriction of the processing of your personal data, insofar as their use is inadmissible under data protection law. This is the case in particular if (i) the data is incomplete or inaccurate, (ii) it is no longer necessary for the purposes for which it was collected, (iii) the consent on which the processing was based has been revoked, or (iv) you have successfully exercised a right to object to data processing; in cases where the data is processed by third parties, we will forward your requests for rectification, erasure or restriction of processing to those third parties, unless this proves impossible or involves a disproportionate effort;

  • Refusal/revocation of your consent: Many data processing operations are only possible with your explicit consent. You have the right to refuse your consent or to revoke consent already given - without affecting the lawfulness of the data processing operations carried out prior to revocation - at any time. 

  • Automated decision-making including profiling: You have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you;

  • Data-transferability: You have the right to have data that you have provided to us handed over to you or a third party in a common structured, machine-readable format. However, the right to request direct transfer to another controller only exists to the extent that this is technically feasible.

  • Right of appeal to the competent supervisory authority: If you believe that your rights have been violated as a result of processing of your personal data that does not comply with data protection law, you have the right to lodge a complaint with the competent supervisory authority.

  • Right to object: You have the right to object to the processing of your personal data at any time, insofar as we process your personal data for direct marketing purposes or insofar as we process your personal data for the pursuit of our legitimate interests and there are reasons arising from your particular situation. 

You may (i) exercise the rights set out above or (ii) ask questions or (iii) lodge a complaint about the processing of your personal data carried out by us by contacting us - as described above.

11. Amendment of this privacy policy

We reserve the right to change this privacy policy as our website is updated. Please visit this website regularly and take a look at the current privacy policy.

This privacy policy was last updated on the 23rd of December 2020.