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PRIVACY POLICY

Digitonic Ltd is a mobile marketing and technology company (“Digitonic”). Digitonic is a Scottish company (SC397173) with its registered office at The Forsyth Building, 5 Renfield Street, Glasgow, Scotland G2 5EZ.

Digitonic is committed to ensuring that all personal data we hold is processed in accordance with data protection law and that good data protection practice is imbedded in the culture of our staff and organisation.

Digitonic processes the personal data of individuals visiting our website and other web pages we operate on social media.

This notice sets out how we process data and the rights data subjects have in respect of their personal data.

Contact details

We have appointed a Data Protection Manager who may be contacted by you in relation to queries regarding your personal data:

a: Digitonic Ltd, The Forsyth Building, 5 Renfield Street, Glasgow, Scotland G2 5EZ e: [email protected]

1. WHAT PERSONAL DATA WE COLLECT AND WHY

If you provide us with your name and other details through our contact pages, we will use them to respond to your request for information. We will store them for a period one year in case you contact us again, after which time we wills securely delete your data from our systems.

We will also collect information through our analytics Cookies but this is not personal data as it cannot be used to identify you. For more information see our Cookie Notice.

2. WHO HAS ACCESS TO YOUR DATA

Your information may be shared within Digitonic as appropriate to the services which you have enquired about.

Digitonic also shares your data with third parties who provide services to us such, mainly IT service providers. Where we use such providers we have appropriate contractual arrangements in place to ensure the security and confidentiality of your data.

Digitonic may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

3. HOW DIGITONIC PROTECTS YOUR DATA

Digitonic Ltd is ISO27001 accredited. This is a globally recognised scheme which requires good practice information security.

4. YOUR RIGHTS

As a data subject, you have a number of rights. These include the right to:

  • Access and to obtain a copy of your data on request;
  • Require Digitonic to change incorrect or incomplete data;
  • Require Digitonic to delete or stop processing your data, in certain circumstances;
  • Object to the processing of your data where Digitonic is relying on its legitimate interests as the legal ground for processing; and
  • The right to object to your data being used to send marketing information to you.

If you would like to exercise any of these rights, if you have any concerns about how your personal data is being processed get in touch using the contact details above. If you believe that Digitonic has not complied with your data protection rights, you can complain to the Information Commissioner. Contact details are available at www.ico.org.uk/concerns

MONITORING AND REVIEW

This policy will be updated from time to time and will be reviewed annually. It was last updated on 12/09/2019.

BRAZIL PRIVACY NOTICE

This section applies to personal data processing activities if you are located in Brazil or if your personal data has been collected in Brazil according to Law No. 13,709/2018 and its changes ("LGPD"), in addition to the Privacy Notice above.

You in control of your personal data: In addition to the rights set forth in our Privacy Notice, according to the LGPD you own the following rights:

  • anonymization, blocking or deletion of unnecessary, excessive or non-LGPD personal data;
  • The portability of your personal data;
  • the deletion of personal data processed with your consent;
  • information on the possibility of not providing consent and on the consequences of the negative;
  • the right to revoke your consent; And
  • the review of automated decisions and behavioral profiling.

Your rights under the LGPD and this Privacy Notice may be exercised upon your request or from your legal representative to Digitonic and may be made through the communication channels mentioned in this Privacy Notice. You should be aware that your request may be legally rejected, whether for formal reasons (such as your inability to prove your identity) or legal (such as the request for deletion of personal data kept by Digitonic to preserve its rights), being certain that, reasonable justifications will be presented in the event of impossibility of fulfillment of those requests.

Security measures that we use to protect your personal data: Personal data are internally accessed at Digitonic only by duly authorized employees, respecting the principles of purpose, adequacy, necessity and other principles inherent in the processing of personal data, always for the purposes described in this Term, and with the commitment to confidentiality and preservation of privacy according to current legislation, in particular the LGPD. To ensure the same level of privacy protection required by law, Digitonic will also require all affiliated companies, employees, partners and their external service providers to use such personal data according to this Term and the LGPD.

Who may have access to your personal data: partners and other companies that provide us with services or assist us with internal functions or with compliance with legal/regulatory provisions, such as maintaining the security of internal systems, information security , data analytics, quality assurance assessments, auditing, accounting and legal services. If Digitonic, directly or indirectly, enters the business transaction process, such as mergers, acquisitions by another company, or the sale of all or part of its assets, we may share with the successor company or potential successor, as well as its employees during the transaction and with audit firms and law firms assisting in the operation.

Your consent is important to us: By interacting with our Facebook page and by pressing the "Get started" button and interacting with us, sharing your personal data to participate in our quizzes , you agree to receive our messages and represent that you have read and agreed to the terms of our Privacy Notice.

You may change or revoke your consent at any time, subject to legal or contractual restrictions and with reasonable notice, by communicating with us through our communication channels provided in this Privacy Notice. All communications regarding the revocation or amendment of your consent must be in writing and may take up to 15 days to process. Please note that in some circumstances, the revocation or amendment of your consent to certain uses of your personal information may affect: (i) our ability to provide you with the products or services requested by you; and, (ii) your ability to access the platform.

Time we keep your personal information: We keep your personal data for as long as reasonably necessary to comply with the purposes set forth herein in this Privacy Notice or for legal purposes. When determining the retention periods of personal data, we consider applicable laws, contractual obligations and expectations and requirements for the processing of such personal data.

Personal data of minors: we are concerned about the privacy of children and adolescents and, therefore, we act in their best interest and according to the current legislation. By interacting with us you agree to this Privacy Notice and represent you are 13 years or older.

International transfer of personal data: We will proceed with the international transfer of your personal data to international countries or organizations: if these countries provide an appropriate degree of protection of personal data as defined by the LGPD; when you provide your consent or when applicable laws may allow.

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