1. Data Collection
The Website (www.astrum.consulting) is operated by Astrum Consulting LLC (KRS 0001007307), a company incorporated in Poland.
We are committed to safeguarding the privacy of visitors to our Website, contacts for our clients and prospective clients, contacts for suppliers of goods and services, and any other individuals about whom we obtain Personal Data (each, "you"). This privacy policy ("Privacy Policy") describes why and how we collect and use your information and provides information about your rights.
In this Privacy Policy, "Personal Data" means information that (either in isolation or in combination with other information held by us) enables us to identify or recognize you. Although you are not obligated to provide any Personal Data on the public areas of the Website, you may choose to do so by voluntarily providing your Personal Data to us, and we may keep a record of it.
We collect Personal Data from a number of sources, either directly from the data subjects or from clients, colleagues, agents, and other publicly available sources. This includes information provided by filling in forms on the Website or information provided to us by you via phone, e-mail or otherwise. We use information available from certain 3rd parties as detailed in this policy.
We may collect the following categories of data about you:
Basic Data: name, surname, gender, state, phone number, organisation, mailing and email address, social media accounts;
Financial Data: bank account information, invoicing details;
Client service data: Personal Data received from clients in respect of employees, customers, or other individuals known to clients;
Compliance data: government identifiers, beneficial ownership data, due diligence data;
Device data: Internet Protocol (IP) address, device identifier, cookies, traffic data, location data, weblogs and other communication data and other data linked to a device and data about usage of our Website.
2. Data Usage
We may use your Personal Data for the following purposes and, for each purpose, based on the following legal grounds:
2.1. Fulfil a contract we have with you and responding to inquiries
We use Personal Data that you voluntarily submit to us during our engagement, regardless of the media used, that we may process in connection with our cooperation. When you request something from us, we will use your information to fulfil our obligations under our contracts with you, including for the processing of invoices, updating of client records, and management of our vendor relationships. Also, we may use Personal Data to provide and improve our products and services and to respond to you if you contact us.
2.2. Providing relevant marketing
We use Personal Data to communicate with you by providing you with information about other goods and services we offer that may be interesting to you. To identify visitors to our sites including any social media platforms including capturing information where you post any comments in order to contact you and to use it to improve our products or services. This processing is necessary for our legitimate interest to send you tailored marketing messages, client newsletters, and invitations, to understand you better as a customer by analysing information you provide to us or which we learn through your interactions with us, to notify you about changes to our products or service, changes to our site or others changes which might otherwise affect you.
You have control regarding our use of Personal Data for direct marketing. If you no longer wish to receive any marketing communications or to remain on a mailing list to which you previously subscribed, please follow the unsubscribe link in the relevant communication or contact us at info@nousevolution.com.
2.3. Keeping Website and IT systems safe
We use Personal Data for our legitimate interests to administer our site and for internal operations, including troubleshooting, data analysis, testing, market research, statistical and survey purposes, to monitor how our Website is used to detect and prevent fraud, other crimes, and the misuse of our Website. This helps us to ensure that you can safely use our Website.
2.4. Complying with the law
When the law requires us to process your data, we will do so. This can include legal, compliance, regulatory and investigative purposes, including for government agencies and law enforcement. When you exercise your rights under data protection legislation, including when you ask to unsubscribe from our marketing communications.
3. Data Transfer
We may share your Personal Data with:
Affiliates in order to provide you with our goods and services and to administer our relationship with you (e.g. invoicing, marketing),
Vendors that may process your Personal Data on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, customer relationship management databases and other cloud-based solutions, third-party companies providing us with business analytics and statistics to assist with our marketing campaigns,
Third parties in connection with business transfers, such as a reorganisation, restructuring, merger, acquisition, or transfer of assets, provided that the receiving party agrees to treat your Personal Data in a manner consistent with this Privacy Policy,
Law enforcement and regulatory or government agencies requesting such Personal Data in connection with any inquiry, subpoena, court order, or other legal or regulatory procedures with which we are legally obligated to comply. We may also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
Please note that the Privacy Policy covers this Website only. We are not responsible for the data policies, procedures, or content of any linked websites. We recommend that you check the privacy and security policies of each website you visit.
We may need to transfer your Personal Data outside of the country in which we collected or obtained it, including outside the European Economic Area ("EEA") or to an international organisation. This may include transfers to our offices in London and New York. It may be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of services.
However, all of our offices adhere to the same procedures with respect to your Personal Data, including this Privacy Policy. By submitting your personal data, you agree to this transfer, storing or processing. Where we transfer your personal information outside the EEA, the country to which it is transferred will either be subject to an adequacy decision by the European Commission, or if not (or if we transfer your personal information to an international organisation), we will ensure that the transfer takes place on the basis of one or more of the following:
Standard data protection clauses adopted by the European Commission or adopted by the Information Commissioner's Office and approved by the European Commission in accordance with relevant law;
Where you have given explicit consent to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards;
Where the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person.
4. Data Security and Retention
We have implemented technical and organisational security measures in an effort to safeguard the Personal Data in our custody and control. Such measures include, for example, restricted access to Personal Data only to staff and authorised service providers on a need-to-know basis, as well as other administrative, technical, and physical safeguards.
While we endeavour to always protect our systems, sites, operations, and information against unauthorised access, use, modification, and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.
Please note that email is not a secure medium and should not be used to send confidential or sensitive information. By providing information online, you accept the inherent security risks of providing information over the Internet and will not hold us responsible for any breach of security, unless it is due to our negligence or willful default.
If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.
We will only retain your Personal Data for as long as necessary for the purposes for which that information was collected as set out in this Privacy Policy or for longer as required under any applicable legal, regulatory, accounting, or reporting requirements.
We will generally keep your personal data for no longer than ten years, after which it will be destroyed if it is no longer required for the purpose(s) for which it was obtained.
5. Your Rights
If you are in the EEA, you have the following rights:
Access. You have the right to request a copy of the Personal Data that we process about you, which we will provide to you in electronic form. If you require additional copies, we may need to charge a reasonable administration fee;
Rectification. You have the right to require the correction of any mistake in the Personal Data, whether incomplete or inaccurate, that we hold about you;
Deletion. You have the right to require that we delete your Personal Data unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims;
Restriction. You have the right to request that we restrict our processing of your Personal Data where (i) you believe such data to be inaccurate, (ii) our processing is unlawful; or (iii) we no longer need to process such data;
Portability. You have the right to receive your Personal Data that you have provided to us in a structured, commonly used, and machine-readable format and have the right to transmit that data to a third party in certain situations;
Objection. You have the right to (i) object at any time to the processing of your Personal Data for direct marketing purposes and (ii) object to our processing of your Personal Data where the legal ground for such processing is necessary for legitimate interests pursued by us or by a third party. We will then abide by your request unless we can demonstrate compelling legal grounds for continued processing of the data.
Withdrawing Consent. If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge. However we reserve the right to charge a fee if you request further copies following a request.
If you are in the EEA, you also have the right to lodge a complaint with the local data protection authority, if you believe that we have not complied with applicable data protection laws.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process your Personal Data.
If you are in the EEA and would like to exercise any of those rights, please:
Email us at info@nousevolution.com
Provide enough information to identify yourself (e.g., name, email address, etc.)
Provide proof of your identity (a copy of your passport); and
Provide the information to which your request relates.
6. Notification of Changes
We may occasionally update this Privacy Policy as our services and privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, this policy was last updated on [17 July 2024], and we encourage you to review this Privacy Policy periodically to be informed of how we use your Personal Data.
7. Contacts
If you have any questions, concerns, or suggestions regarding this Privacy Policy, please contact us by email at contact@astrum.consulting.
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