Privacy Policy of Pause-i Ltd
This Service collects some Personal Data from its Clients.
OWNER AND DATA CONTROLLER
Johan Truter for Pause-i Ltd
Orion House, 14 Barn Hill, Stamford, Lincolnshire, PE9 2AE
Owner contact email: johan@pause-i.com
TYPES OF DATA COLLECTED
Among the types of Personal Data are name, date of birth, address, contact details, medical history, and third party details emergency contact. Service process also gains further personal information that is psychologically based.
Unless specified otherwise, all Data requested by Pause-i is mandatory and failure to provide this Data may make it impossible for us to provide its services. In cases where we specifically state that some Data is not mandatory, Client s are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Client s who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Client s are responsible for any third-party Personal Data obtained and confirm that they have the third party’s consent to provide the Data to the Owner.
MODE AND PLACE OF PROCESSING THE DATA METHODS OF PROCESSING
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using a paper copy; computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated.
In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved administration, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
LEGAL BASIS OF PROCESSING
The Owner may process Personal Data relating to Client s if one of the following applies:
- Client has given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the Client objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the Client and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
PLACE
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the Client ‘s location, data transfers may involve transferring the Client ‘s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Client s can check the section containing details about the processing of Personal Data.
Client s are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Client s can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
RETENTION TIME
Personal Data shall be processed and stored for 7 years by the purpose they have been collected for where after they would be destroyed.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the Client shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Client s may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner. The Owner may be allowed to retain Personal Data for a longer period whenever the Client has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
THE PURPOSES OF PROCESSING
The Data concerning the Client is collected to allow the Owner to provide its Services. The data held is for Pause-i use only and will not be shared with the client s employer without the consent from the client.
Client s can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
THE RIGHTS OF CLIENT
Client s may exercise certain rights regarding their Data processed by the Owner. In particular, the Client has the right to do the following:
- Withdraw their consent at any time. Client s have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Client s have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Client s have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Client has the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Client has the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Client has the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Client has the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the Client ‘s consent, on a contract which the Client is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Client has the right to bring a claim before their competent data protection authority.
DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Client s may object to such processing by providing a ground related to their particular situation to justify the objection.
Clients must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Client s may refer to the relevant sections of this document.
HOW TO EXERCISE THESE RIGHTS
Any requests to exercise Client rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING LEGAL ACTION
The Client ‘s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of the related Services. The Client declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
ADDITIONAL INFORMATION ABOUT CLIENT ‘S PERSONAL DATA
In addition to the information contained in this privacy policy, this Service may provide the Client with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
INFORMATION NOT CONTAINED IN THIS POLICY
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
CHANGES TO THIS PRIVACY POLICY
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Client s on this page and possibly within this Service and/or – as far as technically and legally feasible – sending a notice to Client s via any contact information available to the Owner.
It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the Client ’s consent, the Owner shall collect new consent from the Client, where required.
DEFINITIONS AND LEGAL REFERENCES
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Client
The individual using this Service who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers. Data Processor (or Data Supervisor) The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
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, including the security measures concerning the operation and use of this Service. The Data Controller, unless otherwise specified, is the Owner of this Service.
Service
The service provided by this Company, Pause-i Ltd, as described in the relative terms agreed with client’s employer.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Service, if not stated otherwise within this document.