For the purposes of this Policy, we, ADME (CY) Ltd, a Cyprus private limited liability company having registration number HE347617, registered office at 62 Agiou Athanasiou Ave., BG Waywin Plaza, 1st Floor, Office 101, 4102, Limassol, Cyprus, are the “Data Controller” pursuant to the EU General Data Protection Regulation 2016/679 (“GDPR”), and the Republic of Cyprus’ related laws on processing of personal data. Our main establishment and our central administration is located at the address specified above. your withdrawal.
If you live in a country outside the European Economic Area (EEA), collection and processing of your personal data shall be governed in accordance with the privacy laws of the state of California and where applicable Brazilian related General Data Protection Law.
Any terms or keywords contained in this section shall have the same meaning as defined in GDPR.
Should you require any further clarifications or information as to how we process your personal data, you may do so by sending an email at privacy@thesoul-publishing.com.
We will collect, store, use and overall process the following categories of personal data about you:
5.1 Information and data you have provided on the submission form, including, name/surname, email, country of residence and any other additional related information; and
5.2 For any transactions involving payments, verification documents including a copy of your ID and/or Passport and proof of address, your bank, or other e-payment details. We will process your account information in accordance with internationally recognised and accepted business practices and standards for this kind of transactions.
5.3 Data captured at the time of submitting the form, to confirm the validity of acceptance, such as date, time, browser name and type, operating system, IP address and device details.
5.4 Any other information which might be statutory required to be requested, depending on the nature of the service or operations.
Any collected personal data of yours, including any special categories of personal data (where applicable) shall be processed solely by us for the purposes and for delivering the Creator Services, to comply with our legal and statutory obligations, as well as for the purposes of the legitimate interests pursued by us.
We will only use your personal data for the purposes mentioned above. Your data will be processed through our secure computer network systems and accessed only by authorised persons of ours. Data processing may be carried out on behalf of us by third party data processors which may be located in the EEA or in other third countries, pursuant to written and express authorisation for specific purposes contained in the relevant authorisation. We have taken all necessary steps, including the implementation of appropriate legal, technical and organisational measures, to ensure that the data processing meets all applicable statutory requirements, thus safeguarding your rights.
We may operate within the European Union (EU), the EEA and other third countries, and therefore your personal data or part of them may have to be transferred overseas.
We have taken all reasonable steps to ensure that your personal data are provided with adequate protection based on international protection frameworks and that all transfers of data are conducted pursuant to our written agreements and the supervisory authorities’ guidelines (if required) and/or other legal and/or regulatory requirements.
You will not be subject to profiling or decisions that will produce legal effects or have a significant impact on you, based solely on automated decision making.
You have the right to request access, rectification, to restrict the processing of your personal data, to object, to request erasure as well as the right to data portability. Where the data processing is taking place solely pursuant to your express consent, you have the right to withdraw such consent at any given moment. Such consent withdrawal will not affect the lawfulness of any data processing based on that ground prior to your withdrawal.
Any personal data related requests shall be processed within reasonable time and in any case within 1 (one) month from your written request. This period of time may be extended under certain circumstances by further 2 (two) months.
You will not have to bear any cost to exercise any of your rights. We may though charge a reasonable fee should your requests be clearly unfounded or excessive, due to their repetitive character, or refuse to comply with such requests.
We may request specific information to assist us confirm your identity and ensure your capacity to enforce your rights. This is part of our security measures to certify that personal information is not disclosed to any person who has no right to receive it.
We will retain your personal data for as long as our contractual relationship exists plus a period of time corresponding to the applicable statute of limitations for any kind of claims, or legal or regulatory obligations.
For both hard and electronic copy processing (where applicable) we have data management systems which are periodically updated in accordance with technological development and a framework of multilevel security policies to hold data confidential and secure. Security measures have also been taken to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed.
Moreover, we have procedures to deal with suspected data security breaches or threats and should a breach ever materialise, you will be notified accordingly, along with the supervisory authority, if we are required to do so.
We keep our policy under regular review, and we reserve the right to update the same at any time. If we make changes to this policy during our contractual relationship with you which, in our sole discretion, has a material impact on your rights with respect to how we process your personal data, we will notify you via email to the email address you provided us.
Complaints relating to the processing of any personal data may be communicated electronically at privacy@thesoul-publishing.com.
Complaints may also be lodged before the supervisory authority responsible for the protection of personal data, in the country of your habitual residence, place of work, or place of the alleged infringement of your personal data. More information about how to contact the supervisory authorities across the EEA, can be found in the European Data Protection Board’s website here (https://edpb.europa.eu/about-edpb/about-edpb/members_en).