Data protection policy

In accordance with the legislation: Data Protection Act 2018, UK General Data Protection Regulation (GDPR), and The Privacy and Electronic Communications (EC Directive) Regulations 2003, we provide you with the following information:

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

Aldaniti International Network, LTD

Regus Falcon Drive, Cardiff Bay

Cardiff, Wales, CF10 4RU

Co. Number: 06785315

Telephone: +441989320006

Contact the Data Protection Officer: [email protected]

2. WHAT IS THE PURPOSE OF THE PROCESSING?

PURPOSE 1: To manage the participation of the data subject in draws and/or promotions organised by ALDANITI.

PURPOSE 2: The commercial use of the database through the sending of commercial communications of third parties, Direct Advertisers or Networks (such as Click Labs Group and their Client Portfolio, We Breathe Media and their Client Portfolio, Monetise and their client Portfolio among others) or the carrying out of market studies. To this end, it is necessary to submit the data subjects’ personal details to standardisation, deduplication, filtering and verification operations. Commercial communications will be sent directly by ALDANITI. For this purpose, ALDANITI will never communicate any personal detail of data subjects to advertisers.

The activity sectors which the interested parties may receive information on will be:

• Retail: General stores, online retail, baby products and pet products, fashion, mail order, Fast Moving Consumer Goods
• Leisure: Travel, Magazines/Publishing/Media, Online Dating, Tarot, Music, Sport, Automotive (test drives and brochures request)
• Lifestyle: fitness,well being/beauty, Toiletries/Cosmetics, Optics and Optometry
• Charitable Organisations: Products and Services related to charitable organisations
• Gaming: Lottery, Online Bingo, Online Casino, Sports Bets, Gambling
• Finance: Banking, Claims Companies, Debts, Pensions, Forex, Loans Credit Cards And Mortgage. , Savings And Investment Products, T Dot UK Limited and High Cost Short Term Loans/ Credit Broking
• Property: Home & Lifestyle, Home Improvement and Gardening, Household, Housing Disrepair
• Insurance: Life, Home, Automotive, General, Private Medical, Premium Rate, Travel and Others. Neilson Financial - Smart Insurance, British Seniors Insurance.
• General: Utilities, Broadband, Telecoms, IT/Technical, Legal Services, Education, Mobility, Delivery
• Marketing companies: Online sweepstakes, Freebie and Competition Sites, Market Research, Call Centers

PURPOSE 3: To communicate the personal details of data subjects to companies, organisations and/or entities interested in directing advertising campaigns in the sectors listed above, or to carry out market research. This will imply the need to submit personal data to standardisation, deduplication, filtering and verification operations. Advertising will be sent by these third party companies. These third party companies may be located outside the UK, the communication is made in compliance with the applicable legislation.

The advertising campaigns, both those made by ALDANITI and by third party companies/entities, may be carried out through the following channels:

• Email.
• Telephone calls to landlines or mobile numbers.
• Sending of SMS or MMS messages.
• Push notifications.

In addition to the data requested from the data subject through the registration form, ALDANITI INTERNATIONAL NETWORK, LTD also stores the IP and navigation data of the data subject. All of this with the purpose of preventing crimes or technological fraud. All data collected by ALDANITI are securely stored on servers located within the EU, this transfer, into and out of the EU servers to UK, is made on the basis of the adequacy decision adopted on June 28th 2021 between UK and EU.

PURPOSE 4: Profiling and Partially Automated Decisions. 

Taking into account only the data provided by data subjects in the registration form, sometimes, the advertising campaigns are segmented with the sole objective of increasing its success. (Ex: the opening of a certain men's clothing store in London, will only be addressed to men who live in certain postal codes of the city). In this type of segmentation, the level of intrusion in the private sphere of the interested party is minimal, since only the data that the data subject has provided in their registration (age, sex, zip code ...) is available. In no case are people tracked through different websites, devices and/or services.

Conservation of your data:

Through this Personal Data Retention Policy, it is intended to establish action guidelines related to determining when to proceed with the conservation or destruction of data, in order to comply with the requirements arising from the duty of quality.

What personal information do we keep?

The data that we keep in our files must include the registration date, IP address, name, surname, sex, age, email address, telephone number and postal address.

Likewise, optionally and through a survey, we will ask you additional data that you can freely answer. These data will be referred to user profile data such as if you have a car, its brand and its model, if you have private medical insurance, what telephone company you use, etc. This data will be kept together with the rest of the mandatory data until its definitive de-registration from our file.

Time of data retention

As a general rule, all your data will be automatically canceled from all purposes five years after their registration date (reference has been taken from the period of limitation of actions derived from a contractual relationship, that is five years).

• If you expressly gave your consent to receiving advertising communications from third-party companies via email, we will cancel your data if in the continuous period of 6 months you have not shown any interest in the offers sent. That is, if for six consecutive months, you do not open nor click on the offers received, we will proceed automatically to the cancellation of your data for this purpose.
• Periodically, if you are an active user, that is, if you open and visit the offers sent, you will receive emails reminding that your personal data is stored in our file, as well as the treatment or treatments to which you gave your consent to. In all these emails, you will be given the option to cancel its treatment or unsubscribe from our file.
• If you expressly gave your consent to receiving advertising communications from third parties via phone or sms, we will automatically cancel your data five years after your date of registration, unless you exercised your right to unsubscribe prior to this period, in which case you will be definitively de-registered at the time of the request.
• If you entered the draw without consenting the reception of advertising communications, we will automatically cancel your data once the draw took place.

3. WHAT IS THE LEGITIMIZATION FOR THE PROCESSING OF YOUR DATA?

The basis of legitimization for the processing of data in relation to the purposes of this processing is:

1. To manage the participation of the data subject in draws and/or promotions organised by ALDANITI: For the performance of a contract.
2. To carry out third party advertising campaigns / market studies by ALDANITI - Consent of the data subject.
3. To communicate the data to companies, organisations and/or entities interested in carrying out advertising campaigns / market studies - Consent from the data subject.
4. For the profiling and partially automated decisions - The legitimacy basis is the legitimate interest of the company in trying to ensure the best result of its advertising campaigns.

4. WHO WILL YOUR PERSONAL DATA BE COMMUNICATED TO?

Purpose 1: The data collected for the management of the participation of the data subject in draws and/or promotions organised by ALDANITI, shall be communicated at the points of sale of the products of the draw prizes and/or gift prizes. The basis of legitimization for the communication is the performance of the contract.

Purpose 2: The data collected for advertising actions by ALDANITI: Data transfers are not foreseen to be forwarded.

Purpose 3: The data collected to be communicated to other companies, organisations or entities interested in carrying out advertising actions will be communicated to:

1. Advertiser Companies belonging to the activity sectors mentioned in point 2,
2. Marketing Companies.
3. Call Centers.
4. Promotion sponsors. To manage which offers you want to receive from our sponsors, you must first accept the declaration of consent on the registration page. Note: Your data will be communicated to our sponsors and also could be communicated to companies in the sectors referenced above in point 2. If you do not want your data to be communicated to any of our sponsors, mark the checkbox to state this.

The Company Desarrollos Tecnicos Soluciones TIC, S.L. (hereinafter eDigitalTrust) will have access to all the personal data for audit purposes. EDigitalTrust will act as an online notary for all the registrations without using the information provided by the data subjects for any other purpose. 

5. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR PERSONAL DATA?

You have the right to:

• Access your personal data.
• Rectification
• Erasure. 
• Restriction of processing.
• Data portability.
• Object.

Right to complain to the Information Commissioner’s Office (Supervisory Authority).

In the context of your personal data, you have the right to complain to the Information Commissioner’s Office (ICO). If you feel you need to make a complaint, please consider complaining to us directly by using the contact information described below. Alternatively, you may complain directly to the ICO whose contact details are as follows:

The Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

https://ico.org.uk/global/contact-us/

0303 123 1113

Right to withdraw consent.

In circumstances where you have provided consent for your personal data to be processed, you have the right to withdraw consent. If you would like to withdraw consent, you may do so by contacting us directly by using the contact information described below.

You may exercise your rights by contacting us directly and free of charge through the following email address: [email protected], indicating in the subject line "EXERCISING YOUR RIGHTS", or by written communication to the following address: ALDANITI INTERNATIONAL NETWORK, LTD, Regus Falcon Drive, Cardiff Bay, Cardiff, Wales, CF10 4RU, UK

Your request must include the date, your name and surname(s), your specific request and address for notification purposes. In order to dispel any reasonable doubt about the identity of the person sending the request, we ask you to provide a passport or similar identifying document, to confirm your identity.

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Last updated: August 23, 2022