Privacy Policy

Updated: November 2023

Updated: November 2023

1. INTRODUCTION

This Privacy Policy (“Privacy Policy”) relates to (i) Ealiox® services or any related software application ("Apps") and (ii) the website https://www.ealiox.com and/or any sub-website and/or associated domains (and/or sub-domains) of https://www.ealiox.com (the “Site”), (iii) the owner of the Site and (iv) the services provided by Ealiox Inc. its subsidiaries, whether direct or indirect, including but not limited to Ealiox Inc. (hereinafter collectively referred to as “We”, “Us”, “Our", “Ourselves”).

“You”, “Your” and “User” refer to an identified or identifiable natural person being the user of the Site, Apps and/or client (or prospective client) of any of our services.
This Privacy Policy provides detailed, layered information as to how and why we process personal data (via the Site, any of Our Apps, or otherwise) as well as detailed information about your various rights we are committed to protecting your privacy and handling your information in an open and transparent manner.

2. PRIVACY POLICY OUTLINE

  • Introduction
  • Privacy Policy Outline
  • What is personal data?
  • Personal data we collect about you
  • What we use your personal data for (purpose of processing)
  • Why do we collect and store some personal data?
  • Special Note on consent
  • Accuracy of Personal Details
  • Direct Marketing
  • Security measures
  • Retention periods
  • Processing for research and statistical reasons
  • Links to third-party sources
  • Cookies
  • Minors
  • Your rights under the data protection laws
  • Ealiox Inc. – Company contact
  • Updates

3. WHAT IS PERSONAL DATA

“PERSONAL DATA” means any information that identifies you as an individual or that relates to an identifiable individual. Whenever it is not possible or feasible for us to make use of anonymous and/or anonymized data (in a manner that does not identify any users of the Site, Apps or customers of Our services), we are nevertheless committed to protecting your privacy and the security of your personal data at all times. We collect personal data in various ways, digitally via the Site or the Apps (either when you choose to provide us with certain data or in some cases automatically, or from third parties).

4. PERSONAL DATA WE COLLECT ABOUT YOU

We collect various categories of personal data from you, namely:

Whilst using our website or services, you may be required to provide personal information (name, address, email, telephone number). We will use this information to administer our website, applications, client databases and marketing material. We will ensure that all personal information supplied is held securely in accordance with US Federal Data Privacy Laws and the General Data Protection Regulation (EU) 2016/679, as adopted into law of the United Kingdom in the Data Protection Act 2018. Further, by providing telephone and email details, you consent to Ealiox contacting you using that method. You have the right at any time to request a copy of the personal information we hold on you. Should you wish to receive a copy of this, or would like to be removed from our database, please contact us at privacy@ealiox.com.

Ealiox will process data in line with US Federal Data Privacy Laws and GDPR guidelines and the requirement for legal and accounting records.

CATEGORY OF PERSONAL DATA

Contact Details

Location Based

Approved Financial MetaData

DESCRIPTION

Full legal name, email address, residential address and mobile/phone number.

IP address of the computer connected to the internet, location data through the mobile phone and Apps used and GPS data. National Identifier

A number or code attributed to you by a government to identify who you are, However, we may also collect personal data from other sources, including data companies, publicly accessible databases, joint marketing partners, social media platform and other third parties. We may also receive personal data about you from third parties when we need to confirm your contact details. Should this be the case, We will take all measures as required by law to further inform You about the source of such personal data as well as the categories of personal data We collect and process. There are certain instances at law where We are specifically forbidden from disclosing to You such activity (for example, when carrying out due diligence for anti-money laundering purposes).

For information about the personal data that we may collect automatically via the Site or Apps, please see the cookies section below. Unless otherwise specified and subject to various controls, as a general rule, We only collect personal data (from you or elsewhere) that We:

  • Need to be able to provide you with the services you request from us; 
  • Are legally required to collect/use and to keep for a predetermined period of time believe to be necessary for our legitimate business interests 

A detailed description of the reasons why we process specific categories of personal data as well as the corresponding legal ground(s) for doing so, please see the ‘What We Use Your Personal Data For (Purpose of Processing)’ below.

5. WHAT WE USE YOUR PERSONAL DATA FOR (PURPOSE OF PROCESSING)

The Data Protection Laws permit us to use personal data only if we have a proper reason to do so. GDPR states that we must have one or more of these reasons:

  • To render the services you have contracted to
  • When it is our legal duty.
  • When it is in our legitimate interest – this refers to when we have a business or commercial reason to use your personal data. If we rely on our legitimate interest, We will inform you. 
  • When you consent to it.

Below is a description of what we use your personal data for and the corresponding legal ground(s) we rely on for doing so.

Please note that where we rely on your consent, this can be withdrawn at will.

  • For the purposes of setting up an account on our system, categories of personal data we collect include contact details, documentary data, national identifiers and special category (particularly political connections) data. The legal basis for processing such data is based on contractual necessity, legitimate interest to ensure we have an accurate account and legal duty for due diligence purposes.
  • For the purposes of managing our relationship with you, categories of personal data we collect are mainly contact details for purposes of contractual necessity and compliance with legal obligations.
  • For the purposes of establishing and investigating any suspicious behavior in order to protect our business from any risk, fraud or other illegal activities (such as money laundering or terrorist financing) categories of personal data we collect are mainly documentary data and contact details. The legal basis to collect this data is based on our compliance with legal obligations and legitimate interest in detection and prevention of fraud or other illegal activities.
  • For the purposes of subscribing to a newsletter or mailing list we mainly collect contact details based on your consent.
  • For the purposes of evaluating your queries and/or requests you send us to use/receive any of our services (including customer support services) we mainly collect contract details based on contractual necessity and legitimate interest to be able to attend to your queries.
  • For the purposes of maintaining and updating the user accounts records on our system we will be required to collect contact details based on contractual necessity and legitimate interest to ensure we have an accurate user account record.
  • For the purposes of continuing to manage our relationships with you we will be required to collect contact details based on contractual necessity and compliance with legal obligations.
  • For the purposes of complying with legal and regulatory obligations including the detection and prevention of any financial crime we will be required to collect documentary data, special types of data, national identifiers and locational data based on our legal obligations.
  • For the purposes of providing you with our services, especially those provided via the App including location services we will be required to collect contact details and tracking data based on our contractual necessity.
  • For the purposes of developing and managing our brands, products and services we will be required to collect contact details based on legitimate interest to develop our products and services.
  • For the purposes of internal data analysis, we will be required to collect contact details and tracking data based on contractual necessity.

Should we need to process your data for a new purpose in the future, which is entirely unrelated to the above, We will inform you of such processing in advance and you may exercise your applicable rights (as explained below) in relation to such processing.
Finally, do note that without certain personal data relating to you, We may not be in the position to provide some or all of the services you expect from us or even to guarantee the full functionality of our Site and/or App.

6. WHY DO WE COLLECT AND STORE SOME PERSONAL DATA?

In order for us to contact you and provide you any level of service required, we need to collect personal data for correspondence purposes. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes Ealiox would contact you for additional consent, unless you have formerly ticked the consent option on our contact form.

7. SPECIAL NOTE ON CONSENT

In those limited cases, We will process your personal data on the basis of your consent, which we will obtain from you in a clear and manifest manner. In such cases where you provide us with your consent, You shall have the right to withdraw your consent at any time and this, in the same manner as you shall have provided it to us unless an alternative option is provided by us.

Should you exercise your right to withdraw your consent at any time (by writing to us at the physical or email address below), We will determine whether at that stage an alternative legal basis exists for processing your personal data (for example, on the basis of a legal obligation to which we are subject) where we would be legally authorized (or even obliged) to process your personal data without needing your consent and if so, notify you accordingly.

When we ask for such personal data, You may always decline, however, should you decline to provide us with necessary data that we require to provide requested services, We may not necessarily be able to provide you with such service (such as location services), especially if consent is the only legal ground that is available to us.

Just to clarify, consent is not the only ground that permits us to process your personal data. In the above Section 7, We pointed out the various grounds that we rely on when processing your personal data for specific purposes.

8. ACCURACY OF PERSONAL DATA

All reasonable efforts are made to keep any personal data we may hold about you up-to- date and as accurate as possible. You can check the information that we hold about you at any time by contacting us in the manner explained below. If you find any inaccuracies, We will correct them and where required, delete them as necessary. Please see below for a detailed list of your legal rights in terms of any applicable Data Protection Laws.     

9. DIRECT MARKETING    

We only send mail messages, emails and other communications relating to marketing where we are authorized to do so at law. In most cases we rely on your consent to do so (especially where we use electronic communications). If, at any time, You no longer wish to receive direct marketing communications from us please let us know by contacting us at the details below or update your preference on any of our site(s) or apps.

In the case of direct marketing sent by electronic communications (where We are legally authorized to do so) You shall be given an easy way of opting out (or unsubscribing) from any such communications. Please note that even if you withdraw any consent you may have given us or if you object to receiving such direct marketing material from us (in those cases where we do not need your consent), from time to time we may still need to send you certain important communications from which You cannot opt out.

10. SECURITY MEASURES

The personal data which we may hold (and/or transfer to any affiliates/partners/subcontractors as the case may be) will be held securely in accordance with our internal security policy and the applicable law. We use reasonable efforts to safeguard the confidentiality of any and/or all personal data that we may process relating to you and regularly review and enhance our technical, physical and managerial procedures so as to ensure that your personal data is protected from:

  • Unauthorized access
  • Improper use or disclosure unauthorized modification
  • Unlawful destruction or accidental loss

We have implemented security policies, rules and technical and organizational measures to protect the personal data that We may have under our control. All our members, staff and data processors (including specific subcontractors and cloud service providers established within the European Union), who may have access to and are associated with the processing of personal data, are further obliged (under contract) to respect the confidentiality of our users’ or clients’ personal data as well as other obligations as imposed by the Data Protection Laws.

Authorized third parties, and external/third-party service providers, with permitted access to your personal data (as explained in this Privacy Policy) are specifically required to apply appropriate technical and organizational security measures that may be necessary to safeguard the personal data being processed from unauthorized or accidental disclosure, loss or destruction and from any unlawful forms of processing.

As stated above, the said service providers are also bound by a number of other obligations in line with the Data Protection Laws (particularly, Article 28 of the GDPR).

11. RETENTION PERIODS

We will retain your personal data only for as long as is necessary (taking into consideration the purpose for which it was originally obtained). The criteria we use to determine what is ‘necessary’ depends on the particular personal data in question and the specific relationship we have with you (including its duration).

We would also have to determine whether there are any laws and/or contractual provisions that may be invoked against us by you and/or third parties and if so, what the prescriptive periods for such actions are (this is usually five (5) years). In the latter case, We will keep any relevant personal data that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you and/or third parties for such time as is necessary.We will retain your personal data on our systems for the longest of the following periods:

  • As long as you are a customer or user of our services.
  • Any retention period that is required by applicable law.
  • The end of the period in which litigation or investigations might arise in respect of our products or services. 
  • Where your personal data is no longer required by us, We will either securely delete or anonymize the personal data in question.

12. PROCESSING FOR RESEARCH AND STATISTICAL REASONS

Research and statistics using user or client information is only carried out so that we may understand our users’ and/or clients’ needs and to develop and improve our services/activities. In any case, We will always ensure to obtain any consent we may legally require from you beforehand. As in all other cases, We will also ensure to implement all appropriate safeguards as may be necessary.

13. LINKS TO THIRD-PARTY SOURCES

Links that we may provide to third-party websites are clearly marked and we are not in any way whatsoever responsible for (nor can we be deemed to endorse in any way) the content of such websites (including any applicable privacy policies or data processing operations of any kind). We suggest that you should be cautious when accepting the privacy policies of any such third-party websites.

14. COOKIES

When you visit our site or use our App, We will collect certain categories of personal data automatically through the use of cookies and similar technologies. For more detailed information including what cookies are and how and why we process such data in this manner (including the difference between ‘essential’ and ‘non-essential’ cookies) please read our detailed cookies policy.

15. MINORS

Our site, app and services are not intended to be used by any person under the age of thirteen (13) and therefore We will never intentionally collect any personal data from such persons. If you are under the age of consent, please consult and get your parent’s or legal guardian’s permission to use the site, app and any of our other services.

We shall consider that any personal data of any persons under the age of thirteen (13) received by us, shall be sent with the proper authority from the holder of parental responsibility over the child and that the sender can demonstrate such authority at any time, upon our request.

16. YOUR RIGHTS UNDER THE DATA PROTECTION LAWS

Before addressing any request you make with us, We may first need to verify your identity. As explained in the retention periods section above, We may need to keep certain personal data for compliance with our legal retention obligations but also to complete transactions that you requested prior to the change or deletion that You requested.

Under certain circumstances, by law you have the right to:

  • Be informed in a clear, transparent and easily understandable way about how we use your personal data and about your rights. 
  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
  • Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about You corrected. 
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our regulatory and legal obligations). 
  • Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something that makes you want to object to us using your personal data and we do not have a legitimate basis for doing so, which overrides your rights, interests and freedoms (for instance, We may need it to defend a legal overrides your rights, interests and freedoms (for instance, We may need it to defend a legal case). You also have the right to object when we are processing your personal information for direct marketing purposes. 
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it. 
  • Request the transfer of your personal data to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means. 
  • Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other legal grounds set out above) to the collection, processing and transfer of your personal data for a specific purpose, You have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, We will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have a legitimate interest in doing so or we are bound by regulatory requirements to continue doing so for a defined period of time. 
  • Lodge a complaint. If you think that we are using your information in a way which breaches Data Protection Laws, You have the right to lodge a complaint with the appropriate Data Protection Supervisory Authority, if you are in Malta, this will be the Office of the Information and Data Protection Commissioner (‘OIDPC’) which may be accessed by clicking this link www.idpc.org.mt. We kindly ask that you please attempt to resolve any issues you may have with us first.

WHAT WE MAY REQUIRE FROM YOU

We may need to request specific information from you to help us understand the nature of your complaint or request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Should your requests in exercising your aforementioned rights be manifestly unfounded or excessive, in particular because of their repetitive nature, We reserve the right to charge you a reasonable fee which shall be determined at our sole discretion, taking into account the administrative costs incurred by us to provide the information or communication or taking the action requested by you. We shall communicate to you in advance the fee amount that will be charged in the given circumstances.

HOW QUICKLY WILL WE RESPOND TO YOUR REQUEST?

In all cases, We will try to act on your requests as soon as reasonably possible, within a maximum of one month of receipt of the request, which period may be extended by two (2) more months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one (1) month of receipt of the request, together with the reasons for the delay.

17. Ealiox Inc. – COMPANY DETAILS

If you have any questions/comments about privacy or should you wish to exercise any of your individual rights, please contact us by sending an email to the following address: privacy@ealiox.com with the subject “PRIVACY REQUEST”.

18. UPDATES

We reserve the right to unilaterally modify this privacy policy at any time, particularly if statutory obligations so mandate or the interest of our users" security so requires. To let you know when we make changes to this privacy policy, we will amend the revision date at the top of this page. The modified privacy policy will apply from such revision date. We will not officially notify you about such changes, and it is therefore in your own interest to check this privacy policy page from time to time so as to familiarize yourself with any changes.

Your privacy is an absolute priority at Ealiox.

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