INTRODUCTION

Qoobiss.com publishes this Privacy Policy (hereinafter referred to as the Privacy Policy), to give you an overview of our practices regarding the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data (hereinafter the Processing).

PERSONAL DATA CATEGORIES

For the purposes of the Processing indicated at paragraph III below, we process your personal data, hereinafter referred to as Personal Data. Personal Data will include, as appropriate, both your Personal Information as well as the Special Categories of Personal Data, as defined below. Personal Information may refer to: name and surname, name of your position and your company/entity, postal address, professional address, telephone number, mobile phone number, fax number, e-mail and other similar data about you, information collected from public sources and databases, IP address, other personal data regarding your browsing preferences and other data related to your interaction with us.

We collect your Personal Data directly from you, in certain circumstances, including:

  • When you request legal, tax or insolvency advice or representation from us;
  • When browsing, requesting information or interacting on our website;
  • When you provide or offer to provide services for us;
  • When you voluntarily communicate to us, for any reason, your Personal Data.

PROCESSING PURPOSES

We process your Personal Data to the extent permitted or required by the applicable law for the following purposes:

  • Communicating with you to keep you informed on the progress of the service you requested, the analysis and improvement of our services and communications to you, the provision of legal advice, including tax and insolvency advice or other services and other procedures that you may have requested, including legal representation before courts of law, arbitral tribunals or other competent authorities;
  • Management and administration of the business relationship between you and Qoobiss.com, including services regarding payment processing, accounting, auditing, invoicing and collection, advice;
  • Compliance with our legal obligations (such as record keeping obligations), compliance checking or registration obligations (such as under trade sanction and embargo law, antitrust law, for purposes of combating money laundering, financial verification and compliance, for purposes of preventing and identifying fraud and crime), which could include automatic verification of your Personal Data with applicable lists of sanctioned persons and contacting you to confirm your identity in the event of a potential positive outcome, or recording the interaction with you that may be relevant for compliance purposes;
  • Protecting security and managing access to our website, IT and communication systems, online platforms, websites and other systems, prevention and detection of security threats, fraud or other criminal activities;
  • For purposes of ensuring, monitoring and evaluating compliance with our policies and standards, for the purpose of identifying the persons authorized to trade on behalf of our customers, beneficiaries, suppliers and/or service providers;
  • For the purpose of complying with court decisions and exercising and/or defending our legal rights; and
  • For any purpose related to and/or auxiliary to any of the above.

With regard to marketing communications, we will make that information available to you, if legally required, only after you have selected the option to receive such communications, and we will provide you with the opportunity to unsubscribe at any time, if you no longer wish to receive marketing communications from us. We will not use your Personal Data in making automated decisions that affect you or create profiles other than those described above.

BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA

Any operation equivalent to the processing of your Personal Data will be performed under one or more of the following legal bases:

  • The Processing is based on your consent as the legal basis for the collection, storage and use of your Personal Data, as permitted by the applicable law;
  • Processing is necessary in order to comply with a legal obligation;
  • Processing is necessary in order to protect your vital interests or those of another individual; Processing is necessary for the purpose of the legitimate interests of Qoobiss.com or those of a third party, unless your interests or fundamental rights and freedoms prevail over these interests. We use your Personal Data for our legitimate interests, namely for the exercise of our obligations and rights deriving from an agreement concluded with your company/entity, to improve our performance and work methods and for administrative and fraud detection purposes.

In cases where the applicable legal provisions require your prior and explicit consent for the Processing of Special Categories of Personal Data, we will process such data only with your prior and explicit consent.

You can choose to withdraw your consent regarding marketing materials at any time by sending a request to the e-mail: sales@qoobiss.com

DATA TRANSFERS, RECIPIENTS AND THE LEGAL BASIS OF THESE TRANSFERS

During the course of our activity, we may send your Personal Data to:

  • Attorneys-at-law, other legal specialists, including mediators, notaries public, bailiffs, consultants or experts involved in your case, if the transmission of data is required by the subject matter of the proceedings relating to your case;
  • Courts of law, law enforcement authorities, regulators, attorneys or other persons if it is deemed necessary in order to establish, exercise or defend a right in court or for the purpose of an alternative settlement process;
  • Foreign law firms for the purpose of obtaining foreign legal advice, when such advice is required by the resolution of the mandate entrusted by you or by your company;
  • Companies providing services for controls against money laundering, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit bureaus and regulators with whom those data are shared;
  • Any third party to whom we assign or novate any rights or obligations under the law;

We may also send your Personal Data to our data processors, mainly service providers within or outside Qoobiss.com, for the Processing of Personal Data for the permitted purposes, on our behalf and only in accordance with our instructions. Qoobiss.com will maintain control over your Personal Data and will use appropriate protection measures, in accordance with the applicable law, to ensure the integrity and security of your Personal Data in relation to those processors.

Otherwise, we will transmit your Personal Data only when you instruct or grant us permission or when required by the applicable law or at the request of judicial or official bodies.

We may transfer your Personal Data abroad. Some recipients of your Personal Data may be located in countries in connection with which the European Commission has not issued a decision on ensuring the appropriate level of data protection, namely: United States of America or some of the locations that are not in Europe.

Some recipients located outside the European Economic Area (EEA) are certified under the EU-US Privacy Shield, while others are located in countries for which the European Commission has issued compliance
decisions [Andorra, Argentina, Canada (for private organizations subject to the Canadian Personal Information Protection and Electronic Documents Act), Switzerland, the Faroe Islands, Guernsey, Israel, Isle of Man, Jersey and New Zealand]. In each case, the transfer is recognized as providing an adequate level of data protection from the perspective of European data protection laws (Article 45 of the GDPR).

We may conclude data transfer agreements based on the Standard Contractual Clauses (European Commission Decision 2010/87/EU and/or European Commission Decision 2004/915/EC), in accordance with Article 46(5) of the GDPR or by using other appropriate means, ensuring that all other recipients located outside the EEA will provide an adequate level of data protection for the Personal Data, and that there are adequate technical and organizational security measures in place for the protection of Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access and against all other illegal forms of Processing.

SECURITY OF YOUR PERSONAL DATA

Qoobiss.com has implemented appropriate technical and organizational measures to maintain the confidentiality and security of your Personal Data, in accordance with the internal procedures regarding the storage, transmission and access of Personal Data. Personal Data may be stored on our Personal Data technological systems or in hard copy.

RETENTION PERIODS

Personal Data processed for the purposes mentioned herein will only be retained for as long as necessary, for the duration of your relation with Qoobiss.com as well as subsequently for the retention periods required by the applicable law. If legal action is initiated, Personal Data may be retained until the completion of this action, including during any appeal or remedy periods, and will then be deleted or archived, in accordance with the provisions of the applicable law.

In principle, we will retain your Personal Data for the period required or permitted by the applicable law. Subsequently, upon the expiry of these periods or the exercise of one of your rights, in accordance with the law, we will remove/delete your Personal Data from our systems and records and/or take steps to anonymize them so that you can no longer be identified on their basis.

YOUR LEGAL RIGHTS

If you have given your consent with regard to the Processing activities, you may withdraw this consent at any time with future effect. Such withdrawal will not affect the lawfulness of the Processing prior to the withdrawal of consent. As a general rule, in cases where you withdraw your consent, Qoobiss.com will no longer allow the Processing of your Personal Data and will take appropriate measures to delete any records containing your Personal Data. However, if the Processing is strictly necessary for the provision of services by Qoobiss.com, and the Processing could be based on other legitimate interests provided for by the applicable legal provisions, Qoobiss.com will proceed to the respective Processing and will inform you in this respect.

Under the conditions provided for by the applicable law, you have the following rights:

  1. Right of access: You have the right to be notified, upon request, if your Personal Data are being processed, and if so, you have the right to request access to them. The information includes,
    but is not limited to, the purposes of the Processing, the categories of Personal Data affected and the recipients or categories of recipients to whom your Personal Data has been or will be transmitted.

You have the right to obtain a copy of the Personal Data processed. For additional copies, we may charge a reasonable fee based on administrative costs.

  1. Right to rectification: You have the right to obtain from us the rectification of your incorrect Personal Data. Depending on the purpose of the Processing, you have the right to complete incomplete Personal Data, including by an additional statement.
  2. Right to erasure (“right to be forgotten”): You have the right to ask us to erase your Personal Data.
  3. Right to restriction of processing: You have the right to request the restriction of the processing of your Personal Data. In this case, those data will be marked and can be processed by us only for certain purposes.
  4. Right to data portability: You have the right to receive your Personal Data that you have provided to us, in a structured, common and machine-readable format, and you have the right to transmit these
    data to another entity without objections from us.
  5. Right to object: You have the right to object, for reasons related to your situation, at any time, to the processing of your Personal Data by us, and we may be asked to stop processing your Personal Data. If you have the right to object and exercise it, we will no longer process your Personal Data for that purpose. Exercising this right does not involve any cost.This right may be invalidated in particular if the Processing of your Personal Data is necessary for the formalities related to the conclusion of an agreement or for the performance of an already concluded agreement.

You can exercise your aforementioned rights and find out more about these rights by submitting a written request to Qoobiss.com.

You also have the right to file a complaint with the National Authority for the Supervision of Personal Data Processing.

VERSIONS OF THIS PRIVACY POLICY

This Privacy Policy may be updated periodically. Any update will become applicable when the new version is published on the website of Qoobiss.com or when it is communicated to you in any other way.