The Fine Print.

Terms and Conditions - Please read these terms and conditions before using the COLORBARMANAGER application and salon service

 ("Terms", "Terms and Conditions") refer to your use of the COLORBARMANAGER application (the "Service") operated by COLORBARMANAGER ("us", "we", or "our")

Your access to and the use of the Service is based on your acceptance of and compliance with these Terms. These Terms apply to all visitors, users and others who access or use the Service. By accessing or using the Service you agree to be bound by these Terms and accept all legal consequences. If you do not agree to these terms and conditions, in whole or in part, we ask that you please do not use the COLORBARMANAGER service.


ACCOUNTS

You must provide us information that is accurate, complete, and current at all times in order to create an account with us. Failure to do so constitutes a breach of the Terms, which may result in immediate termination of your account with the COLORBARMANAGER service. You are responsible for the password that you use to access the COLORBARMANAGER service, safeguarding it and for any activities or actions under your password, whether your password is with our COLORBARMANAGER service or a third-party service. You agree to not disclose your password to any third party. You must notify us immediately upon awareness of any breach of security or any and all unauthorised use of your account. You may not use as a username the name of another person or entity or that is not lawfully available for use, a name or trade mark that is subject to any rights of another person or entity other than you without appropriate authorisation, or a name that is otherwise offensive, vulgar or obscene.

The COLORBARMANAGER service and all contents, including yet not limited to text, images, graphics or code are the property of COLORBARMANAGER and are protected by database, copyright, and further intellectual property rights. You may display, download, copy, and / or print material from the different areas of the COLORBARMANAGER service only for your own use. Any other use is strictly prohibited and may violate copyright, trademark and other laws. These terms do not grant you a license to use any trademark of COLORBARMANAGER or its affiliates. You further agree not to use, change or delete any proprietary notices from materials downloaded from the COLORBARMANAGER service.


BILLING and SUBSCRIPTIONS

Our Services are billed on a subscription basis ("Subscription(s)"). You will be billed in advance on a recurring periodic basis ("Billing Cycle"). Billing cycles are set either on a monthly or annual basis, this is dependent on the type of COLORBARMANAGER service subscription plan you select when purchasing. 

Your Subscription will automatically renew at the end of your billing cycle under the exact same terms unless you or we cancel it.

You may cancel your Subscription renewal using your online account management page https://app.colorbarmanager.com/ or by contacting the COLORBARMANAGER support team contact@colorbarmanager.com. A valid credit card payment method is required to process your payment to begin your subscription.  Accurate and complete billing information including full name, address, telephone number, and a valid payment method information must be provided to COLORBARMANAGER. By submitting such payment information, you automatically authorise COLORBARMANAGER to charge all subscription fees incurred through your account.  Should automatic billing fail to occur for any reason, COLORBARMANAGER will issue an electronic invoice indicating that you must proceed manually with the full payment corresponding within a deadline date to the billing period as indicated on the invoice.  Failure to make payment will result in immediate cessation of the service provided by COLORBARMANAGER. 

At any time and at its sole discretion, COLORBARMANAGER service may modify the fees for subscriptions. Any subscription fee changes will become effective at the end of the current Billing Cycle. COLORBARMANAGER will provide you with prior notice of any change in subscription fees to allow you the opportunity to terminate your subscription before the fee change becomes effective. Your continued use of the COLORBARMANAGER service after the subscription fee change comes into effect constitutes your agreement to pay the modified subscription fee amount.

Please note all prepaid annual and ongoing monthly subscription fees are non-refundable except when required by law.


TERMINATION

If you wish to terminate your account, you may simply discontinue using the COLORBARMANAGER service and terminate your subscription using your online account management page

We may suspend access or terminate access to our COLORBARMANAGER service immediately, without prior notice or liability, for any reason whatsoever, including, without limitation, if you breach the terms. All provisions of the terms shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability. Upon termination, your right to use the COLORBARMANAGER service will immediately cease.

 You agree to indemnify, defend and hold harmless COLORBARMANAGER , its principals, officers, directors, representatives, employees, contractors, licensors, licensees, suppliers and agents, from and against any claims, losses, damages, losses, obligations, costs, actions or demands. These include but are not limited to: (a) legal and accounting fees resulting from your use of the  COLORBARMANAGER service; (b) your breach of any of these terms; (c) anything you post on or upload to the service; and (d) any activity related to your account. This includes any negligent or illegal conduct by you, any person or entity accessing the service using your account whether such access is obtained via fraudulent or illegal means.


CONTENT

The COLORBARMANAGER service allows you to store, share and otherwise make available information, text or other material ("Content"). You are responsible for the content that you share to the service, including its legality, reliability, and appropriateness. By sharing content to the service, you grant us the right and license to use, modify, perform, display, reproduce, and distribute such content on and through the COLORBARMANAGER service. You retain any and all of your rights to any content you submit or display on or through the COLORBARMANAGER service and you are responsible for protecting those rights. You represent and warrant that: (i) the content is yours (you own it) or you have the right to use it and grant us the rights and license as provided in these Terms, and (ii) the posting of your content on or through the COLORBARMANAGER service does not violate the privacy rights, publicity rights, copyrights, contract rights or any other rights of any person. We reserve all rights to block or remove communications or materials that we determine to be: (a) abusive, defamatory, or obscene; (b) fraudulent, deceptive, or misleading; (c) in violation of a copyright, trademark or, other intellectual property right of another or; (d) offensive or otherwise unacceptable to COLORBARMANAGER service in our sole discretion. You acknowledge that, by providing you with the ability to view and distribute user-generated content using the COLORBARMANAGER service, we are merely acting as a passive conduit for such distribution and COLORBARMANAGER are not undertaking any obligation or liability relating to any contents or activities on the COLORBARMANAGER service.


THIRD PARTY

The Service may contain links to third-party web sites or services that are not owned or controlled by COLORBARMANAGER, COLORBARMANAGER has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party websites or services. You further acknowledge and agree that COLORBARMANAGER shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services. We strongly advise you to read the terms and conditions and privacy policies of any third-party web sites or services that you visit.


LIMITATION OF LIABILITY

COLORBARMANAGER, its directors, employees, partners, agents, suppliers, or affiliates, shall not be liable for any loss or damage, direct or indirect, incidental, special, consequential or punitive damages, including without limitation, economic loss, loss or damage to electronic media or data, goodwill, or other intangible losses, resulting from (i) your access to or use of the service; (ii) your inability to access or use the service; (iii) any conduct or content of any third-party on or related to the Service; (iiv) any content obtained from or through the service; and (v) the unauthorised access to, use of or alteration of your transmissions or content, whether based on warranty, contract, tort (including negligence) or any other claim in law, whether or not we have been informed of the possibility of such damage, and even if a remedy set forth herein is found to have failed of its essential purpose.

Disclaimer And Non-Waiver of Rights

No guarantees, representations or warranties of any kind with regard to the website and associated technologies are made by COLORBARMANAGER. Any purportedly applicable warranties, terms and conditions are excluded, to the fullest extent permitted by law. Your use of the service is at your sole risk. The service is provided on an "AS IS" and "AS AVAILABLE" basis. The  COLORBARMANAGER service is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement or course of performance, except as provided for under the laws of any province in Canada. In such cases, the provincial law shall apply to the extent necessary.  COLORBARMANAGER its subsidiaries, affiliates, and its licensors do not warrant that a) the  COLORBARMANAGER service will function uninterrupted, secure or available at any particular time or location; b) any errors or defects will be corrected; c) the service is free of viruses or other harmful components; or d) the results of using the COLORBARMANAGER service will meet your requirements. If you breach any of these terms and COLORBARMANAGER chooses not to immediately act, or chooses not to act at all,  COLORBARMANAGER will still be entitled to all rights and remedies at any later date, or in any other situation, where you breach these terms. COLORBARMANAGER does not waive any of its rights.  COLORBARMANAGER shall not be responsible for any purported breach of these terms caused by circumstances beyond its control. A person who is not a party to these terms shall have no rights of enforcement. You may not assign, sub-license or otherwise transfer any of your rights under these terms.


EXCLUSIONS

As set out, above, some jurisdictions do not allow the exclusion of certain warranties or the exclusion or limitation of liability for consequential or incidental damages, so the limitations above may not apply to you. 

Governing Law

If any provision of these Terms is held to be invalid or unenforceable by a court of competent jurisdiction, then any remaining provisions of these terms will remain in effect. These terms constitute the entire agreement between us regarding our COLORBARMANAGER service, and supersede and replace any prior agreements, oral or otherwise, regarding the COLORBARMANAGER service.

Changes

We reserve the right, at our sole discretion, to modify or replace these terms at any time. If a revision is material we will make reasonable efforts to provide a minimum of 30 days' notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion. By continuing to access or use our  COLORBARMANAGER service after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, in whole or in part, please stop using the website, terminate your subscription and discontinue your use of the COLORBARMANAGER service.

Contact Us

If you have any questions about these Terms, please contact us at: marketing@colorbarmanager.com

Privacy Policy

COLORBARMANAGER, Inc. ("COLORBARMANAGER “/“us”/“our”/“we”) are committed to protecting privacy. Our website, www.colorbarmanager.com (the "Website"), and the App “COLORBARMANAGER” (“App”) are available together with the COLORBARMANAGER services through the Website and App (the "Service"). As you use our services, we want you to know how we’re using information and the ways in which we protect your privacy and the ways you can protect your privacy.

Our Privacy Policy explains:

  • What and why we collect the information we collect

  • How we use that information and where and when we disclose it.

  • How you can access and update your personal information.

Familiarise yourself with these policies, and if you have any questions please contact us at: marketing@colorbarmanager.com

This Privacy Policy aims to give you information on how COLORBARMANAGER collects and processes your personal information through your use of our Website, App and the COLORBARMANAGER services, including any information you may provide when you 

*sign up for our Services

*when you create an account and a profile with us

*when you submit status updates

*when you search our Website or App

*when you use our App

*when you subscribe to our email alerts 

*on the contact of our customer service

*when you participate in surveys, public forums, chats, or 

*when you respond to one of our requests for suggestions and other content 

*on the purchase or use our Services


Please note that neither the Website, App nor the Service is intended for children under 16 years of age.  We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Website, App or on or through any of its features, use any of the interactive or public comment features of the Website or App or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.

Controller or Processor

To the extent that COLORBARMANAGER holds information about you due to your use of our Services, COLORBARMANAGER is the controller and responsible for your personal information. To the extent that COLORBARMANAGER holds information about you due its presence in content uploaded by COLORBARMANAGER customers, COLORBARMANAGER acts as a processor. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.


Contact Details

Our full details are:

COLORBARMANAGER LTD

Email address: contact@colorbarmanager.com

Postal address: PO Box 22333, Khandallah, Wellington 6035, New Zealand

Telephone number: +64 274 377477

If you are based in the European Union, you have the right to make a complaint any time to your local supervisory authority for data protection issues. We would appreciate the chance to deal with your concerns before you approach the regulator so please contact us at: marketing@colorbarmanager.com 

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on Tuesday 26 January 2021

We reserve the right to change the terms of this Privacy Policy at any time. When we do, the revised Privacy Policy will be accessible on our Website and the date of revision will be updated to provide full and clear understanding of what information we collect, how we use the information, and under what circumstances we may share this information with others. It is important that the information we hold is accurate and current, please keep us informed if your personal information changes during your relationship with us.

Third-party Links

The Website or App may include links to third-party websites, plug-ins and applications. Clicking on those links and/or enabling these connections may allow third parties to collect and/or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website or App, we encourage you to read the privacy notice of every website you visit.

2. THE INFORMATION WE COLLECT ABOUT YOU

Personal data, or personal information, means any information relating to an identifiable person who can be directly or indirectly identified. It does not include data which cannot be related to an identifiable person (anonymous data).

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes payment card details.

  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website or on which the App is installed and used.

  • Profile Data includes your username and password, purchases or orders made by you, your location, preferences, feedback and survey responses.

  • Usage Data includes information about how you use our Website, App, other app(s) and Services, such as the buttons, controls, products and ads you click on, pages of our App or Website that you visit, the time spent on those pages, your search queries, the dates and times of your visits or use, but also about the products that you are tracking through the App and Service, how often you use those products, and other related data regarding such usage by you.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal information

In some instances we need to collect personal information by law, or under the terms of a contract we have with you. If you fail to provide that information when requested, we may not be able to perform the existing  contract we have or  trying to enter into with you (for example, to provide you with our services). In this instance, we may have to cancel a service you have with us, you will be notified at the time.

3. HOW IS PERSONAL INFORMATION COLLECTED

Our methods of data collection vary from and about individuals including through:

  • Direct interactions by you. You may give us Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • Create an account and profile with us

    • Purchase our services

    • Subscribe to our email alerts

    • Complete one of our online forms

    • Download or otherwise access any of our resources online or otherwise

    • Contact marketing or our customer service resources

    • Request marketing to be sent to you

    • Place feedback

  • Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

  • Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:

    • Technical Data from the following parties:

      • Providers such as Google Analytics based outside the EU;

      • Information from search providers such as Google based inside or outside the EU.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.

  • Identity and Contact Data from our partners, data brokers or aggregators based inside or outside the EU.

  • Identity and Contact Data from publicly available sources such as LinkedIn, Instagram, and other social networking sites based outside the EU.

4. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To perform the contract we have or are about to enter into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

The types of lawful basis that we will rely on to process your personal data are:

Legitimate Interest  - In the interest of our business in conducting and managing our processes and systems to give you the best service and the most secure experience. We ensure and consider any potential impact on you (both positive and negative) and your rights before we process personal information for our legitimate interests. We do not use personal information for activities where our interests are overridden by the impact on you. In these circumstances we seek to have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact by contacting us at: marketing@colorbarmanager.com

Performance of Contract – The processing of your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation - The processing of personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent – You have consented to our use of data. We may ask for your express consent for certain uses, you are free to withdraw that consent at any time.

Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications. You have the right to withdraw consent to marketing at any time by contacting us at: marketing@colorbarmanager.com

Purposes for which we will use your personal information

As set out below, a description of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. If you need details about the specific legal ground we are relying on to process personal information where more than one ground has been set out in the table below please contact us.

Purpose/Activity

Type of Data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

  • Identity

  • Contact

Performance of a contract with you

Allow your use of the Service

  • Identity

  • Technical

  • Contact

  • Financial

  • Transaction

Performance of a contract with you

To process and deliver your order including:

  • Manage payments, fees and charges

  • Collect and recover money owed to us

  • Identity

  • Contact

  • Financial

  • Transaction

  • Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  • Notifying you about changes to our terms or Privacy Policy

  • Reviews or Surveys

  • Identity

  • Contact

  • Profile

  • Marketing and Communications

Performance of a contract with you

Necessary to comply with a legal obligation


Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

Enabling entry into a prize draw, competition or complete a survey

  • Identity

  • Contact

  • Profile

  • Usage

  • Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

To administer and protect our business, this Website and Mobile App (including yet not exclusive to troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Identity

  • Contact

  • Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)


Necessary to comply with a legal obligation

To use data analytics to improve our website, services, customer relationships and experiences

  • Technical

  • Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our Website and Mobile App updated and relevant, to develop our business and to inform our strategy)

To make suggestions and recommendations to you about services that may be of interest to you

  • Identity

  • Contact

  • Technical

  • Usage

  • Profile

Necessary for our legitimate interests (to develop our services and grow our business) or where have otherwise consented to such usage


Marketing

We will provide you with choices regarding certain personal information uses around marketing and advertising. You may elect to opt out of receiving further marketing or advertising emails or SMS messages from us through the processes provided in these emails or messages. We may deliver targeted advertising through the Service on to you.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to gain insight and understand what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal information with any company outside our company for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a service purchase, service experience or other transactions.

Cookies (website only)

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the COLORBARMANAGER website may become inaccessible or not function properly.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at: marketing@colorbarmanager.com

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL INFORMATION BY US OUTSIDE OF THE SERVICES

We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Third Party categories as set out below:

  • Service providers who provide IT and system administration services.

  • Social networking sites to which you have linked your account.

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • Regulators and other government authorities.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal information within our company and to our third party service providers. This may involve transferring your information internationally including without limitation, if you are based in the European Union, transferring your data outside the European Economic Area (EEA).

Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.

If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

How long will you use my personal information for?

We will retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax and other legally required purposes.

In some circumstances you can ask us to delete your information: see Request erasure below for further information.

In some circumstances we may anonymise your personal information for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal information. You have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

  • If you wish to exercise any of the rights set out above, please contact us using the details set out above.

No fee usually required

You will not have to pay a fee to access your personal information. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Effective date: January 26 2021