This is intellectual Property Policy document for the Itransition iDiscount Application

PRIVACY POLICY

This Policy provides an overview of how Itransition Holding Limited, together with its subsidiaries (collectively hereinafter referred to as “Itransition”), collects your personal data, how it handles it, and how it protects your privacy.

YOUR PERSONAL DATA CONTROLLER

Itransition is a group of companies that act as joint controllers of your personal data. It means that the companies of the group jointly determine the purposes and means of personal data processing.

Itransition data protection officer can be contacted at privacy@itransition.com.

PERSONAL INFORMATION WE COLLECT AND USE

Itransition may collect your personal data that you provide to it, for example, when you contact Itransition electronically or respond to an email from Itransition. Itransition may collect your business contact details when you exchange business cards with Itransition representatives at meetings and events, or when you provide your contacts to sign up for Itransition events.

When submitting your request/inquiry on Itransition websites, you may be asked for information such as, but not limited to, your full name, email address, phone number, company you work for or own and/or country where you reside or work.

When contacting Itransition through live chats on its websites, you may be asked for information such as, but not limited to, your name and email address. This is needed when we are not ready to answer you immediately and need more time to handle your request. When you give Itransition your personal data in live chat, we assume that you consent to processing it by Itransition.

By using cookies, Itransition may collect details of your visits to its websites such as, but not limited to, the pages you visited, the date, time and duration of your visit and/or your IP address as well as the browser you use and its version, your operating system and its version, your city and state.

It is Itransition policy to collect only the minimum information required to handle and complete your request/inquiry or to reach other purposes for which Itransition processes your personal data. If you believe Itransition websites have collected excessive information about you, please contact Itransition through the request/inquiry form to raise your concerns.

Itransition does not intend to collect sensitive information through its websites unless it is legally required to do so. Examples of sensitive information include race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, sexual life or sexual orientation, and criminal records. Itransition asks that you do not provide sensitive data of such nature when using its websites.

When you submit your request/inquiry on Itransition websites, Itransition uses your data on the basis of your consent. In other cases, when you voluntarily exchange business contact details with Itransition, Itransition sends you information or marketing communications on the basis of its legitimate interests in maintaining a business relationship with you or companies you work for or represent and/or on the basis of your consent (when it is technically possible to collect your freely given, specific, informed and unambiguous consent). Cookies are used on the basis of your consent and/or Itransition legitimate interest described below.

PURPOSES FOR WHICH ITRANSITION USES YOUR PERSONAL DATA

Itransition may use your data to interact with you and/or respond to your requests/inquiries, to negotiate, perform or facilitate a contract with you or related to you, to send you invitations to events it organizes, to share with you information you might be interested in and/or to inform you about its services. Itransition may also use your personal data to comply with law, regulations, public authority requests or court orders.

These are examples of purposes for which Itransition may use personal data you provide to it:

Itransition websites do not collect or compile personally identifying information for sale to third parties for consumer marketing purposes.

WHO MAY ACCESS YOUR PERSONAL DATA

Itransition may disclose your personal data to (1) its employees who are in contact with you or who are responsible for marketing, (2) other companies of Itransition (some of them are located outside the European Union), (3) third-party service providers.

Statistical data about Itransition websites’ visitors may be accessed by (1) Itransition employees in marketing and/or IT departments who are responsible for analysing such data and for improving Itransition websites, (2) other companies of Itransition (some of them are located outside the European Union), (3) third-party service providers.

TRANSFERS TO THIRD COUNTRIES

Itransition is a multinational group of companies. For this reason, your personal data may be transferred to and stored outside the country where you are located. This includes countries outside the European Economic Area with no adequate level of personal data protection (third countries).

As some of the countries where our offices are situated are not yet recognized by the European Commission as countries with an adequate level of personal data protection, these offices have access to personal data on the basis of instruments that cover the European Union requirements for the transfer of personal data to data controllers/processors outside the European Union (Standard Contractual Clauses approved by the European Commission). You may ask Itransition to inspect copies of these clauses by contacting its data protection officer.

THIRD-PARTY PROVIDERS

When Itransition transfers personal data, it does so for the purposes for which the information has been collected/submitted, for the purposes listed above, for the administration and maintenance of its websites and associated systems, and/or other internal or administrative purposes. Itransition also may transfer personal data to third parties providing identity management, website hosting and management, data analysis, data backup, security and storage services.

Itransition works only with those third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal data only as instructed by Itransition and to flow those same obligations down to their sub-processors.

iDiscount App also uses the following third-party services (links to their privacy policies are provided):

Firebase Analytics;

Fabric;

Crashlytics.

Visit www.google.com/policies/privacy/partners/ to get familiar with Google’s policies.

RETENTION OF YOUR PERSONAL DATA

Itransition will retain your personal information in its systems only for as long as Itransition needs it, given the purposes for which it was collected, or as required to do so by law.

RIGHTS IN RELATION TO YOUR PERSONAL DATA

Under your local laws and the European Union legislation, you may exercise the following rights by submitting your request/inquiry on Itransition websites:

In some cases, you may also have a right (1) to request restriction on processing of your personal data or (2) to object to processing of your personal data.

There are cases when Itransition can retain copies of the personal data you requested it to erase. They concern the necessity to protect legitimate interests of Itransition or third parties, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have formed with Itransition.

RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You have the right to lodge a complaint with your local data protection regulator if you think your privacy rights have been violated.

CONTACT ITRANSITION

If you have any questions or comments regarding this Privacy and Cookies Policy, you can contact Itransition via the request/inquiry form on this website.