Last update: 02.04.24
PRIVACY PRACTICES OF ALUNIMO LIMITED
This document outlines the privacy practices of the soullinkers.com website (referred to as "Website" or "Websites"), focusing on how we collect and use the personal information you provide while using the ALUNIMO LIMITED Website to access ALUNIMO LIMITED Service. It also explains the choices you have regarding our use of your personal data and how you can control and manage that information.
You do not need to provide personal information just by visiting the Website. However, if you choose to utilize ALUNIMO LIMITED Service through our Website, we may need to collect and process personal data.
In such cases, we typically ask for the user's consent as the data subject. Under GDPR regulation Article 37/1, ALUNIMO LIMITED is not obliged to appoint a Data Protection Officer (DPO). However, ALUNIMO LIMITED has appointed an individual responsible for monitoring GDPR compliance, who will address any questions, requests, or concerns about data protection. You can reach this person via the [email protected] email.
ALUNIMO LIMITED is dedicated to complying with the General Data Protection Regulation (GDPR) and relevant data protection laws in different countries when dealing with personal data such as names, addresses, email addresses, phone numbers, or payment information of any person ("data subject"). Our Privacy Policy is crafted to clearly outline the kind of personal data we gather, utilize, and process, as well as its scope and intention. It also aims to inform data subjects (users) about their rights concerning their personal data.
As the data controller, ALUNIMO LIMITED has implemented extensive technical and organizational measures to guarantee the utmost security for the personal data under our care on this Website.
In this Privacy Policy, "We", "Us", "Our", and "ALUNIMO LIMITED " refer to ALUNIMO LIMITED .
It is important to highlight that our services do not cater to minors, and our Website is not designed for individuals under 18 years of age.
RIGHTS OF PERSONAL DATA OWNERS
Right to Correction
According to the rights granted by European law, any person from whom data has been collected has the right to request that the data collector correct any inaccurate information about them without delay. Furthermore, individuals have the right to complete any incomplete personal data relevant to the processing's purposes by submitting an additional statement.
Right to Deletion
As per the rights provided by European Union law, every individual whose data is collected has the right to have the data collector remove any personal information about them immediately, unless there are valid reasons to keep it. The data collector is required to erase the personal information promptly under the specified conditions, unless its processing is still necessary:
- the personal data becomes unnecessary concerning the objectives for which it was initially collected or processed;
- the data subject withdraws their consent, which was the foundation for processing the data as per GDPR's Article 6(1)(a) or Article 9(2)(a), and there's no other legal justification for the processing;
- the data subject objects to the processing in line with Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject disputes the processing under Article 21(2) of the GDPR.
Right to Restrict Processing
Under European law, every individual whose data is processed has the right to ask the data controller to limit processing under certain situations. These situations include, but are not limited to, the following conditions:
- when a data subject disputes the accuracy of their personal data, allowing the controller some time to confirm the truthfulness of the information;
- in cases where the processing of data violates legal regulations, but the data subject prefers to restrict the use of the data rather than demanding its deletion;
- when the data is no longer needed for the purposes it was collected by the controller, but the data subject keeps it for legal claim purposes.
If the data subject objects to the processing of their data under Article 21(1) of the GDPR, while it's being determined if the controller's legitimate grounds outweigh the data subject's objections.
Data Portability Right
Every individual, whose data is managed by a data controller, is granted specific rights by the European legislative body. Included in these rights is the right to data portability. This right allows the data subject to retrieve and reuse their personal data across various services. It ensures that individuals can obtain their data from a controller in a format that is structured, commonly used, and readable by machines, thus facilitating the easy transfer of data to a different controller.
The original controller who collected the personal data should not hinder this process, as long as the data processing is carried out based on consent according to Article 6(1)(a) or Article 9(2)(a) of the GDPR, or on a contractual necessity according to Article 6(1)(b) of the GDPR. Additionally, this right is only applicable to data processing performed via automated means and does not affect processing necessary for public interest tasks or the exercise of official authority vested in the controller.
Data Protection Rights
The European laws grant individuals the right to access their personal data held by data controllers at any time. This encompasses the ability to request and obtain a copy of their personal data, as well as receiving information on various aspects of data processing. In detail, individuals have the right to be informed about:
- the purposes for processing their data;
- the categories of personal data being processed;
- the recipients or types of recipients to whom the personal data have been disclosed, especially if they are in foreign countries or are international bodies;
- the planned retention period of the personal data, or if not possible, the criteria used to determine that period;
- the rights to correct or delete their personal data held by the controller, to restrict processing of their data, or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- if the personal data was not collected from the individual directly, any available information about the source of the data.
This full access promotes clarity and governance over one's own data for individuals, enhancing their privileges in the era of technology.
Automated Decision-Making and International Data Transfers
The law recognizes the role of automated decision-making, including profiling, as specified in Articles 22.1 and 22.4 of the GDPR. Individuals have the right to be informed about the crucial details of the logic behind these automated processes, their importance, and how these decisions might affect them. Moreover, individuals are entitled to be informed if their personal data is being moved to another country or to an international entity. In such cases, they have the right to be informed about the safeguards concerning their data during these transfers. If individuals wish to learn more about these practices, they are advised to contact us using the instructions provided at the end of this Privacy Policy. We are dedicated to promptly responding to and resolving any inquiries.
Right to Object
According to the rights established by the European legislator, each person has the power to object to the processing of their personal data, especially when the processing is based on the conditions mentioned in Article 6(1), points (e) or (f) of the GDPR. This includes any profiling based on these legal grounds. If individuals believe their personal situations warrant such objections, they are encouraged to contact us using the details provided at the end of this Privacy Policy. It is our responsibility to promptly acknowledge and address the request without unnecessary delay.
Right to Confirmation
Under the rights granted by the European legislator, every individual is entitled to get confirmation from the controller on whether their personal data is undergoing processing.
Upon receiving such a request, we will provide detailed and clear information about what data is processed, why it's being processed, and any other relevant details of interest to the person. This approach reflects our steadfast dedication to transparency and safeguarding an individual's rights in accordance with the GDPR.
DATA MANEGEMENT
Data Storage and Elimination
The duration for which we keep personal data is determined by the relevant legal retention requirements. After this period ends and the data is no longer needed for its original purpose, we methodically and securely delete or destroy the data, assuming it is not necessary for the purpose it was initially collected for.
Committed to the principles of data storage and elimination, we actively work to protect the privacy and security of personal information. This involves proactive steps to ensure data is not kept longer than its useful life or the period legally allowed. Our policies adhere strictly to data privacy laws, including the GDPR for entities in the European Union, underscoring the need for data minimization and limiting data storage to only what is necessary for processing activities.
When the legally allowed period expires or the data no longer fulfills its initial purpose, we proceed with a deliberate process of data elimination or de-identification. The elimination process is conducted with the same level of care for security and confidentiality as data storage, guaranteeing that personal information is permanently removed from our systems. However, in instances where complete elimination is not feasible immediately or when keeping the data for archival purposes meets a legitimate interest within legal boundaries, data may be de-identified to strip away personal identifiers, thus reducing the risks related to data breaches or unauthorized access.
Cancel Email Subscription
To stop receiving future emails from us, you can unsubscribe either by visiting the "Unsubscribe Page" or by using the contact information provided at the end of this Privacy Policy.
Please note, it may take up to 10 (ten) business days to process your request to opt-out completely. If you need to make changes or updates to the personal information we hold, please contact us using the details given at the end of this Privacy Policy.
USE OF INFORMATION
At ALUNIMO LIMITED , we place the highest importance on user privacy and control over personal information. Our approach to data management is founded on obtaining the explicit consent of the individuals involved, who we refer to as data subjects or users. In essence, consent must be a clear, informed, specific, and unambiguous agreement from the data subject, given through a definitive positive action that allows the use of their personal data.
A data subject or user is any identifiable natural person whose personal data we process at ALUNIMO LIMITED . This process encompasses a wide range of activities including the gathering, storing, organizing, altering, accessing, reviewing, utilizing, sharing, combining, and erasing of data, which may be done either manually or through automated systems.
Personal data refers to any information related to a data subject or user that can directly or indirectly identify them. This includes, but is not limited to, their name, ID numbers, location details, online identifiers, or any characteristics that are physical, psychological, genetic, mental, economic, cultural, or social in nature.
Our commitment to careful data management reflects our dedication to protecting our users' privacy and rights. We ensure that data subjects are thoroughly informed and give their consent freely to our data handling activities. By doing so, ALUNIMO LIMITED adheres to the GDPR and other privacy regulations, upholding the highest standards of data privacy and security.
CATEGORIES OF PERSONAL DATA COLLECTED
As part of our commitment to GDPR compliance, ALUNIMO LIMITED observes the principle of data minimization to safeguard personal information. We collect specific categories of personal data as described below, which are critical for us to deliver our services efficiently. This information includes:
The user's complete name, encompassing the first and last names:
1. An email address is essential for account registration, allowing users to access the ALUNIMO LIMITED Service.
2. Billing information, including the user's complete address, zip code, city, country, and phone number, is required for processing transactions.
3. The selected payment method, noting that we do not store complete credit card numbers or their expiration dates.
4. The IP address, supplied by the user's Internet Service Provider (ISP), crucial for identifying the user.
5. Location data, collected to analyze user engagement from various regions.
When you sign up for the ALUNIMO LIMITED Service, we require key personal information, which falls under the category of User's Information. This includes identifiable details like your full name (including both your first and last names) and email address. These pieces of information are collected, processed, and stored by ALUNIMO LIMITED for the purposes of account creation and management. Furthermore, you will need to supply Billing Information, which consists of personal details that are partially kept by ALUNIMO LIMITED and partially handled by external payment processors. The use of your Personal Data serves multiple purposes, such as:
- improving your experience by tailoring the website and enhancing the ALUNIMO LIMITED Service;
- sending you relevant emails about your registration status, password reset, and payment confirmation;
- aiding in communication about your interactions with the Service and any related content/materials;
- sharing aggregated statistical data with our partners about our user demographic, ensuring secure transmission and adherence to data processing agreements (DPA).
COOKIE POLICY
Managing Cookies
We primarily gather marketing-oriented data essential for sending updates or promotional content, which includes basic personal information such as your name, address, phone number, and email. We utilize this data while ensuring your anonymity and treat it as statistical information. We guarantee not to share this information with any third parties.
Various web browsers enable you to manage cookies to match your privacy preferences. You can adjust your browser settings to reject new cookies, receive alerts for new cookies, or disable existing cookies. Note that disabling cookies entirely may negatively impact your online experience, limiting access to the full range of services our website provides.
Our website requires cookies for certain functionalities. You have the option to delete or reject cookies by changing your browser settings whenever you prefer. For more information, you might want to visit www.allaboutcookies.org and/or www.youronlinechoices.com.
Cookie and Pixel Tag Policy
Should you prefer not to use Cookies, your browser settings may allow you to disable them.
ALUNIMO LIMITED utilizes Pixel tags—also known as transparent GIFs, clear GIFs, or web beacons. These work in conjunction with Cookies to track users who visit our Website or open our HTML-formatted emails. Users can opt to deactivate Cookies on our Website by modifying their web browser settings, effectively blocking Cookies permanently.
Additionally, it's possible to delete already stored Cookies at any time using a web browser or other software solutions. Our website uses Cookies to gather statistical reports, which are crucial for tailoring online experiences and supporting online behavioral advertising.
We carefully gather statistical data on the most visited pages, the types of files downloaded, the domain and country of the internet service providers, and the URLs visited immediately before and after ALUNIMO LIMITED . Through Google Analytics, we assess the effectiveness of our marketing endeavors and the usability and performance of our website.
LEGAL DISCLOSURES
At ALUNIMO LIMITED , protecting your service usage privacy is our top concern. However, there are certain situations where we may need to disclose personal information stored in your account or on ALUNIMO LIMITED 's servers and databases. Such situations include, but are not limited to, the following:
- fulfilling legal duties or answering to legitimate legal requests and proceedings that involve us;
- handling and examining possible breaches of this privacy policy or cases where the service could be exploited for illegal acts;
- probing into activities that are suspected to be fraudulent;
- protecting the rights, assets, or safety of {companyname}, our staff, our customers, or the public.
ALUNIMO LIMITED is deeply dedicated to upholding your privacy, but it's crucial for ensuring compliance and the overall protection and integrity of our services and everyone involved.
In the event that ALUNIMO LIMITED experiences a change in ownership due to events such as mergers, acquisitions, reassignments, or the dissolution of the business, or if there's a direct or indirect sale of our publishing assets or Website(s), the personal information of users related to the involved Website(s) will be transferred to the new owners.
Notifications about any transitions will be sent to you, giving you the chance to exercise your GDPR rights. You have the right to alter or delete your personal data, or revoke consent at any time by reaching out through the specified channels, or you may choose to adhere to any new guidelines should the acquiring entity update the Privacy Policy.
To ensure the protection and legal processing of personal data in accordance with GDPR, we might share Information Gathering with third-party entities, such as strategic partners for marketing purposes, provided that formal data processing agreements are in place.
For handling payment transactions, the controller may share personal data of individuals with various processors, like payment gateways that comply with DPA, a crucial action taken by the controller to facilitate transactions granting users access to and usage of ALUNIMO LIMITED Service. Due to our dependence on external technology providers for delivering our Services, there is a likelihood of your data being transferred internationally.
Tech service providers are only permitted to process the personal data we provide as sub-processors, strictly following the Data Processing Agreement (DPA) in accordance with GDPR guidelines. However, it's important to note that encryption efforts become ineffective if a data subject does not securely manage and store their access credentials, such as passwords. In cases where credentials are compromised due to the data subject's negligence, the controller is not responsible for any resulting data breaches.
In the event of a personal data breach, the controller must immediately report the incident to the relevant supervisory authority, ideally within 72 hours of discovering the breach, unless it is impractical to do so. Moreover, if the breach poses a potential risk for unauthorized access to personal data, the controller must inform the affected data subject as soon as possible. However, the controller's obligation to notify the data subject may be waived if strong security measures, including encryption, were already in place and applied to the data involved in the breach.
CHANGES TO PRIVACY POLICY
We may change or update this privacy policy at any time for any reason. Changes become effective immediately after the updated policy is posted on our website. We advise our users to frequently check our privacy policy for updates to stay informed on how we protect their personal data. The last update date will be clearly indicated at the top of the policy, helping users to know when it was last revised.
We will notify users of significant updates to our privacy practices through our website or, when suitable, through direct communication. Nonetheless, we advise users to periodically review this policy to stay informed of any changes and their potential impact on their information.
Continuing to use our services after we post changes to this privacy policy signifies your acceptance of those modifications. We prioritize privacy and are dedicated to being clear about how we handle your personal information. For any queries regarding our privacy practices or data protection measures, please get in touch with us through our support channel.
APPLICABLE LAWS
Our Privacy Policy adheres to relevant legal standards, including the Data Protection Directive (95/46/EC) and Regulation 2016/679, aimed at protecting individuals' rights in the processing of Personal Data and ensuring the free movement of such data, thereby repealing Directive 95/46/EC ("GDPR") as of May 25, 2018. Visitors from outside the European Union are responsible for complying with any applicable local laws to the extent that they apply.
The GDPR identifies two main roles in personal data management: data controllers and data processors. Data controllers set the purposes and methods for processing personal data. In this context, all clients of ALUNIMO LIMITED , including both organizations and individuals, act as data controllers. This makes ALUNIMO LIMITED a data processor, responsible for processing your personal data. It must comply with GDPR requirements and ensure its data processing partners also adhere to these standards.
CONTACT INFORMATION
For questions about this Privacy Policy, to adjust your personal data, or to remove yourself from our database, please email us at [email protected] with the subject line "Re: Privacy Policy" for clarity.
In accordance with Articles 6-III and 19 of the Law No. 2004-575 of June 21, 2004, on Confidence in the Digital Economy, known as LCEN, we offer the following information to users and visitors of the soullinkers.com website:
- OWNER STATUS: Company
- PREFIX: LTD
- COMPANY NAME: ALUNIMO LIMITED
- ADDRESS: Giagkou Potamiti, 27 3036, Limassol, Cyprus
- COMPANY NUMBER: HE 410184
- COMPANY DIRECTOR: Katerina Papalambrianou
- VAT: CY 10410184J
- EMAIL ADDRESS: [email protected]
- SITE BUILDER: ALUNIMO LIMITED
- PUBLISHING MANAGER: ALUNIMO LIMITED
- RESPONSIBLE PERSON FOR THE PUBLICATION: [email protected]
- RESPONSIBLE PERSON FOR THE PUBLICATION AS A LEGAL PERSON:
- WEBMASTER: ALUNIMO LIMITED
- CONTACT THE WEBMASTER: [email protected]