Last Updated, November 28, 2023
Data Controller: Obscuro Limited, company incorporated and registered in England and Wales under company number 13873741 with a registered office at Ground Floor, Cromwell House, 15 Andover Road, Winchester, SO23 7BT, UK.
Contact information: e-mail address: email@example.com
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.
Usage Data - Information collected automatically through this Platform (or third-party services employed in this Platform), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Platform, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Platform) and the details about the path followed within the Platform with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User - The individual using this Platform who, unless otherwise specified, coincides with the Data Subject.
Data Subject - The natural person to whom the Personal Data refers.
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 Platform. The Data Controller, unless otherwise specified, is the Owner of this Platform.
This Platform - The means by which the Personal Data of the User is collected and processed.
Service - The service provided by this Platform as described in the relative terms and on this Platform
This section explains generally the sources from which, and the means by which, we collect and process personal information.
We collect the following data:
We collect the following categories of Personal data for the following activities:
|Categories of Personal data
|Visiting the Platform
|Contacting Obscuro Limited support teams
|Allowing the visitors and Users to exercise their data protection rights
|Complying with legal requests or manage litigation
|Provide our Services on Platform
|Sending you marketing communications or newsletter
We use the personal information that we collect or receive from our Users for the purposes described in this Policy and for other business purposes allowed by law, including the development, delivery, and performance of our services, sharing with our affiliates for related business purposes, and as follows:
We process personal data on the following legal basis for the following purposes:
|If you communicate with us (for example, if you email or call us), we will use your information for dealing with your queries, training and customer service purposes.
|Contractual necessity: where you provide information that is necessary for us to fulfil our contract with you and provide our Services. Our legitimate interests are to handle your queries and provide you with the requested information, ensure high customer service quality and to train staff in responding to such requests.
|To send you marketing communications about our Services (and the products or services of third parties that we make available through our Services), or to send you our newsletter when you sign up to receive this and to monitor whether you open our emails and/or click on URLs in our emails.
|We rely on your consent, where this is required by law. Otherwise, we rely on our legitimate interest to keep you informed of products and services on our platforms, when we are allowed by law to do so.
|To carry out market research and create marketing profiles about our users and understand their preferences in relation to our Services (including the products and services available through these).
|Our legitimate interest to carry out marketing activities.
|To display our advertisements to you on other platforms, such as social media platforms or to display on our website and app advertisements which we think you might like.
|Your consent, where we obtain this information by using cookies or where otherwise required by law. Otherwise, we rely on our and third parties’ legitimate interests to carry out marketing activities and inform you of products and services we think you might like.
|To compile statistics and analysis about the use of our Services and use such statistics to enable us to provide a better service, features, and functionality to you and other users. Your consent, where we obtain this information by using cookies.
|Our legitimate interests (where consent is not required by law) so as to ensure the smooth and effective functioning of our Services, to make sound business decisions about our products and services and to design, inform and deploy our business strategies.
|To respond to legitimate requests for the disclosure of information, made by public authorities, law enforcement or government bodies or under a court order.
|Legal requirement, to the extent we are obliged under law to process such requests. Our legitimate interests to assist legitimate investigations carried out by official authorities.
|To respond to complaints, to protect our legal rights and to establish, exercise or defend legal claims relating to our platforms and/or our products and services.
|Our legitimate interests to protect our legal rights.
|For tax, accounting, record keeping and audit purposes.
|Legal requirements, to the extent the law requires that we use your information (for example, to comply with our tax obligations).
Wherever we rely on consent, you will always be able to withdraw that consent at any time, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing purposes, at any time. You can do this by clicking on the unsubscribe link in the relevant marketing communication or emailing us at - firstname.lastname@example.org.
We do not use your personal information to take automated decisions about you which have a legal or similarly significant effect on you
Obscuro Limited takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Obscuro Limited, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Platform (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Obscuro Limited. The updated list of these parties may be requested from the Owner at any time
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with Obscuro Limited using the information provided in the contact section.
Where we need to transfer your personal data outside the European Economic Area (“EEA”), the United Kingdom or Switzerland, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses or a vendor’s Processor Binding Corporate Rules.
Obscuro Limited may store, process, and/or transfer personal data to countries outside of the European Economic Area (EEA) (including countries where the European Commission has not made a decision of an adequate level of protection of personal data), but in these cases Obscuro Limited will ask for specific consent regarding these data transfers.
In this case, Obscuro Limited processes your data in United Kingdom.
We may share your personal data with following recipients:
We will store your personal information for as long as it is required for us to fulfil the purposes for which we have collected it, as described in this Policy, and for such further period that is necessary to comply with our legal and regulatory obligations, to exercise our legal rights and to protect our business from legal claims. Therefore:
Obscuro Limited may be allowed to retain Personal Data for a longer period whenever the User 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 of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period
Users may exercise certain rights regarding their Data processed by Obscuro Limited. In particular, Users have the right to do the following:
Any requests to exercise User rights can be directed to Obscuro Limited 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.
If user has any issues regarding data processing done by Obscuro Limited, user can send request to the Information Commissioner’s Office
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
Should the changes affect processing activities performed on the basis of the User’s consent, Obscuro Limited shall collect new consent from the User, where required