Voucher Webshop Privacy Policy

This document was last updated on August 1, 2019

This is the Voucher Webshop Privacy Policy applicable to Voucher Webshop Services and the Website operated and provided by Keymarking Ltd, as defined below. This Privacy Policy applies to Users who wish to open a Voucher Webshop account and should thus be read and interpreted accordingly.

By providing your personal information to us, you signify your acceptance of our Privacy Policy and agree that we collect, use, and disclose your personal information as described in this Privacy Policy. If you do not agree to this Policy, please do not provide your personal details to us.

Our Privacy Policy may be made available in several languages; all versions are legally binding, but in the event of inconsistency between English version and a translated version, the English version prevails.

Contents

Please click the links below if You wish to go directly to a particular section of this Privacy Policy. The headings are for reference only and do not affect construction and interpretation.

  1. Definitions
  2. About Us
  3. Scope of Privacy Policy
  4. Collection of personal information
  5. The purpose and legal basis for processing personal information
  6. Personal information that We may process and groups of the personal information
  7. Disclosure of collected personal information to Third Parties
  8. Automated decision making
  9. Transfer of personal information to third countries
  10. Marketing
  11. Retaining collected personal information
  12. Your rights
  13. Your consent and how to withdraw it
  14. Children
  15. If You choose not to give personal information
  16. Use of "cookies"
  17. Third party websites
  18. Security
  19. Changes to this Privacy Policy
  20. Contacting Us and how to make a complaint

1. Definitions

"Company", "We", "Us" or "Our" – Keymarking Ltd.

"Cookie Policy" means Our Voucher Webshop Cookie Policy as may be amended from time to time, concerning Voucher Webshop Services and the Website available on the Website which contains supplementary information to this Privacy Policy.

"EEA" means the European Economic Area.

"GDPR" means the General Data Protection Regulation 2016/679.

"Mobile Device" means a portable computing device such as a smartphone or tablet computer.

"non-personal information" means information which does not relate to an identified or identifiable natural person on which basis such individual is not distinguishable from other individuals. Anonymized personal information is an example of such non-personal information.

"personal information" means information that relates to an identified or identifiable natural person on which basis such individual is distinguishable from other individuals.

"process" or "processing" means any operation or set of operations which is performed on personal information, whether or not by automated means, such as collecting, storing, using, disclosing or transferring, restriction, destruction of personal information.

"Privacy Policy" means this Voucher Webshop Privacy Policy concerning Voucher Webshop Services and Our Website, as may be amended from time to time.

"sensitive personal information" means personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sexual life or sexual orientation.

"Terms and Conditions" means the Voucher Webshop Terms and Conditions describing provisions of the Voucher Webshop Services, as may be amended from time to time.

"User" means "You" a person that meets all the eligibility requirements set in the Terms and Conditions and who opens a Voucher Webshop account, thereby agreeing to the Terms and Conditions, this Privacy Policy and the Cookie Policy.

"Voucher" means a prepaid payment instrument issued by the Voucher Issuer, based on e-money and distributed by Us on the Website or prepaid gift card allowing to buy certain goods or services from the company who has issued this voucher.

"Voucher Issuer" means a licensed business entity legally entitled to issue e-money based payment instruments or business entity issuing prepaid gift cards allowing to buy goods or services provided by such business entity.

"Voucher Webshop" is Our brand name.

"Voucher Webshop Account" means Your profile as member on the Website required for receiving the Voucher Webshop Services.

"Voucher Webshop Services" means distribution of Vouchers on the Website, which includes letting You choose a Voucher from the list provided on the Website, making the Payment for the chosen Voucher and acquiring it, as well as activities required for identity verification and security checks, ensuring availability of payment methods and other activities performed by Us, as described in these Terms and Conditions.

"Website" means the website branded as Voucher Webshop at https://www.voucherwebshop.com/

"You", "Your" or "Yourself" means an individual who is using Voucher Webshop Services on his or her own account.

Other terms not provided in the preceding paragraphs are used in this Privacy Policy, too. Please check the Terms and Conditions for the meaning of capitalized terms that are not provided in this Privacy Policy.

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2. About Us

2.1 Personal information as described in section 6 of this Policy is processed by Us – Keymarking Ltd., a company incorporated under the laws of the Republic of Cyprus with registration number HE366720 and with registered office at Athalassas Ave 170, Floor 3, Strovolos, Cyprus.

2.2 We are the data controller responsible for processing Your personal information. Your personal information is processed by Us in line with the GDPR and all applicable data and privacy laws and regulations. Processing will only take place for the purposes and in the manner, and only will be disclosed to third parties, as set forth herein.

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3. Scope of Privacy Policy

3.1 Keymarking Ltd is committed to protecting Your privacy. This Privacy Policy has been developed to explain how we may collect, retain, process, share and transfer Your personal information. In particular, this Privacy Policy:

- Contains information on the personal information We collect about You.

- Describes how We process Your personal information.

- Tells You about persons with whom Your personal information might be shared with and the purpose for such disclosure.

- Tells You about Your rights and how to exercise them.

- Is intended to assist You in making informed decisions when purchasing and using Voucher Webshop Services or Our Website.

3.2 This Privacy Policy should be read together with the Terms and Conditions or other contracts concluded between Us and You, if You wish to use Voucher Webshop Services. Please also read Our Cookie Policy to find out more about how We use cookies.

3.3 This Privacy Policy applies:

- To features and services of the Website provided to You when You apply, access or use Voucher Webshop Services.

- At the moment when You apply to use and/or are accessing or using Voucher Webshop Services on Your own behalf.

- To Your use of any software, including Our Website, used by You to access or use Voucher Webshop Services.

- To communications between You and Us by using email and other electronic messages, including SMS, telephone, Our Website, and other communications.

3.4 We recommend that You download or print a copy of this Privacy Policy and store it for Your records and future reference. Please contact Us, if You want a copy of this Privacy Policy.

3.5 Please contact Us if You have any questions about Our privacy practices that may not be addressed in this Privacy Policy.

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4. Collection of personal information

We may collect information about You from these sources:

4.1 Personal Information You provide to Us directly:

- When You are applying, accessing or using Voucher Webshop services.

- When You upload and/or store information with Us while using Voucher Webshop services.

- When You are accessing or using Our Website.

- In communications between You and Us by using email and other electronic messages, including SMS, telephone, website/portal, and other communications.

- In financial reviews and interviews which you participate in with your consent.

- In customer surveys which you participate in with your consent.

4.2 Personal Information We collect when You are purchasing a Voucher and using Voucher Webshop Services:

- Data required for purchasing a Voucher.

- Data on a purchased Voucher.

- Usage of Our Website by You. Subject to the receipt of your informed, free and explicit consent, We gather information about how You use Our Website from devices You use to connect to Our Website, such as computers and Mobile Devices, and by using cookies and other internet tracking software.

4.3 Personal Information provided to us by third parties with whom we may cooperate with when necessary for the purposes set forth in this Privacy Policy:

- Government authorities, regulators and law enforcement authorities worldwide.

- Card associations, Card authorization and authentication service providers.

- Organizations with whom We have an agreement to corporate with, including banks, electronic money issuers and payment service providers.

- Our business partners, sub-contractors and other organizations providing services to Us and Our customers.

- Voucher issuers.

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5. The purpose and legal basis for processing personal information

5.1 We are processing Your personal information on the basis of one or more of the following reasons:

- To fulfil a contract We have with You (e.g., the Terms and Conditions).

- When it is Our legal obligation to do so (processing of Your personal information is necessary for Us to comply with the applicable law).

- When it is in Our legitimate interests. This is when We have a business or commercial reason to use Your personal information. However, when We process Your personal information for Our legitimate interest, your interests, rights and freedoms which require protection of personal data shall not be overridden.

- Where You provide us with your free, informed and explicit consent.

5.2 We use Your personal information in the ways and for the reasons listed below. Where We process Your personal information to achieve Our legitimate interests, We have provided an explanation about them.

If You provide Us with personal information, including sensitive personal information, about Yourself or other individuals, You agree (and confirm that such other individual has agreed) that We can process the said information in the way set out in this Privacy Policy.

Purpose(s) of Processing Legal Basis Legitimate Interest(s)
To provide Voucher Webshop Services and to manage Our business needs

To manage Our relationship with You.

  • - To provide advice or guidance about Vouchers and/or Voucher Webshop services.
  • - To collect and recover funds that are owed to Us.
  • - To respond to complaints and seek solutions for them.
  • - To communicate with You and to tell You about changes to Voucher Webshop services.
  • - To manage how We work with Our business partners and other organizations providing services to Us and Our customers.
  • - To exercise Our rights and obligations set out in the Terms and Conditions and other contracts concluded between Us and You.
  • - To run Our business in an efficient and proper way. This includes managing Our financial situation, corporate governance, and audit.
  • - Fulfilling contract.
  • - Our legitimate interests.
  • - Our legal duty.
  • - Being efficient about how We fulfil Our legal and contractual duties.
  • - Keeping Our records up to date.
  • - Complying with applicable laws.
  • - Managing Our everyday business needs.
To manage Our relationship with You
  • - To provide Voucher Webshop Services to You.
  • - To process Your request to purchase a Voucher.
  • - To manage fees and charges We charge You.
  • - Fulfilling contract.
  • - Our legitimate interests.
  • - Our legal duty.
  • - Being efficient about how We fulfil Our legal and contractual duties.
  • - Keeping Our records up to date.
  • - Complying with applicable laws.
To manage risks and protect Voucher Webshop services
  • - To keep Voucher Webshop Services safe and secure.
  • - To carry out Our identity and security validation and verification checks.
  • - To monitor use of Voucher Webshop Services.
  • - To detect, investigate, report and prevent financial crime, fraud and money-laundering.
  • - To detect and prevent abuse of Voucher Webshop Services.
  • - To manage risk for Us, Our customers and Our business.
  • - To obey any applicable law requirements.
  • - Fulfilling contract.
  • - Our legitimate interests.
  • - Our legal duty.
  • - Developing and improving how We deal with financial crime, fraud and money-laundering, as well as doing Our legal duties in this respect.
  • - Complying with applicable laws.
  • - Being efficient about how We fulfil Our legal and contractual duties.
  • - Managing Our everyday business needs.
To administer Voucher Webshop Services and Our Website:
  • - To allow Our customers to participate in interactive features of Voucher Webshop Services and the Website.
  • - To administer Voucher Webshop Services.
  • - To administer the Website and to improve its performance.
  • - To analyze Our customer behavior and preferences, to analyze trends and to manage the load on Our servers.
  • - Fulfilling contract.
  • - Our legitimate interests.
  • - Our legal duty.
  • - Being efficient about how We fulfil Our legal and contractual duties.
  • - Developing new products and services.
  • - Managing Our everyday business needs.
To render, develop and improve Our business
  • - To develop, manage and enhance Our brand, Voucher Webshop Services and the Website.
  • - To develop new ways to meet Our customers’ needs and to grow Our business.
  • - To test new products and services.
  • - To conduct market analysis and strategic planning.
  • - To study how Our customers use Voucher Webshop Services and other services similar to or connected with Voucher Webshop services.
  • - To measure and understand the effectiveness of advertising of Voucher Webshop services.
  • - Fulfilling contract.
  • - Our legitimate interests.
  • - Developing new products and services, and what We charge for them.
  • - Defining types of customers for new products or services.
  • - Being efficient about how We fulfil Our legal and contractual duties.
  • - Keeping Our records up to date.
  • - Assessing which of Our products or services may interest Our customers.
  • - Managing Our everyday business needs.
Marketing:
  • - To develop and carry out marketing activities.
  • - To establish Our customer eligibility to receive special features, promotions, products and services.
  • - To deliver relevant advertising to Our customers.
  • - Your consent.
  • - Our legitimate interests.
  • - Keeping Our records up to date.
  • - Assessing which of Our products or services may interest Our customers and telling about them.
  • - Seeking Your consent when We intend to inform You about special features, promotions, products and services.

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6. Personal information that We may process and groups of the personal information

6.1 We may process different kinds of personal information, including financial information You provide to Us. We gather personal information in the following groups:

Group Description Type of personal information that could be included within the group

Financial data

Our customers' financial position, status and history.

  • - Financial information.
  • - Payment instrument details (credit/debit card details, card number, card expiry date, CVC details, bank and/or card issuer details, bank account details).
  • - Information that We receive from Our business partners, sub-contractors and other organizations providing services to You, for example, financial data and data received from credit reference and fraud prevention agencies.

Contact

Our customers’ contact information.

  • - First name/last name.
  • - Date of birth.
  • - Nationality.
  • - Country of residence.
  • - E-mail address.
  • - Address (residence, postal address), including copies of proof of address.
  • - Phone number (landline/mobile phone number.
  • - Photograph.

Transaction data

Details about transactions on purchase of Vouchers.

  • - Type, amount and time of a transaction on purchase of a Voucher.
  • - Transaction details (geographical location, IP address and country, recipient's e-mail address (if applicable), phone number).
  • - Additional commercial information and identification information.
  • - Any other information You provide.

Contractual

Details about You and Voucher Webshop Services provided.

  • - First name/last name.
  • - Date of birth.
  • - Nationality.
  • - Country of residence.
  • - E-mail address.
  • - Address (residence, postal address), including copies of proof of address.
  • - Phone number (landline/mobile phone number).
  • - Payment instrument details (credit/debit card details, card number, card expiry date, CVC details, bank issuer details, bank account details).

Locational

Information We get about where You are. We may have this information from the device You use to access Our Website, including the address from which You connect the said device to the Internet.

  • - Geographic location, including access real-time location based information.
  • - IP address and country.

Behavioral and Technical (collected by cookies. Please see Our Cookie Policy )

Details about how You use Our Website and details on the devices and technology You use.

  • - IP address and country.
  • - Access time of the Website.
  • - Website response times.
  • - Length of visits of certain pages of the Website.
  • - The internet browser type, version, time zone setting, plug in types and versions, operating system and platform.
  • - Full Uniform Resource (URL) clickstream.

Communications

Information that We learn from Your letters, emails, and conversations, either textual or oral, with Us.

  • - Your comments and opinions disclosed in Your communications, for example, content of a complaint or question submitted to Us.

Open data and Public Records

Details about You that are in public records and information about You openly available on the Internet.

  • - Your comments and opinions made on social network sites (i.e. Facebook or Twitter) about Us, Voucher Webshop Services, other services similar to or connected with Voucher Webshop Services or the Website, and other products and services that are or may be provided by Us.
  • - Public records.

Usage data

Other information about Your use of Voucher Webshop Services, and/or other services similar to or connected with Voucher Webshop Services, and other products and services that are or may be provided by Us.

  • - Information that We receive from Our business partners, sub-contractors and other organizations providing services to You, for example, financial data and data received from credit reference and fraud prevention agencies.

Documentary data

Details about You that are stored in documents in different formats, or copies of them.

  • - Government issued photo identification.
  • - Details of passport/ identity card/ drivers license or birth certificate.

Consents

Any permissions, consents or preferences that You give Us.

  • - Consent to receive offers for special features, promotions, products and services from Us.
  • - Consent to collect real-time location based information.

National identifier

A number or code given to You by a government to identify who You are.

  • - Social security number/tax code.
  • - Details of passport/ identity card/ drivers license or birth certificate.

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7. Disclosure of collected personal information to Third Parties

7.1 We may share Your personal information in a variety of ways with the following third parties:

- Our affiliates, and their directors, employees, professional advisors, advisers, subsidiaries, agents, subcontractors, and service providers that We use to ensure the sale of Vouchers and the rendering of Voucher Webshop Services, the performance of Our obligations arising out of the Terms and Conditions, to manage risks, to help detect and to prevent financial crime, fraud and money-laundering, to help us to manage Our Website and Voucher Webshop Services, to collect funds what You owe to Us, to help Us to conduct marketing of Voucher Webshop Services and other services similar to or connected with Vouchers and/or Voucher Webshop Services and to explore new ways of doing business.

- Government authorities and regulators and law enforcement authorities worldwide pursuant to our legal obligation.

- Card associations, Card authorization and authentication service providers.

- Organizations that introduced You to Us.

- Organizations that We introduced to You.

- Organizations with whom We have agreement to corporate with, including banks, electronic money issuers and payment service providers, and payment initiation service providers.

- Our business partners, financial and legal advisers, sub-contractors and other organizations providing services to Us or Our customers.

- Persons to which You ask to share Your personal information with, this includes Voucher issuers which issued Vouchers You chose to purchase.

- Your agent or legal representative (such as the holder of a power of attorney that You grant, or a guardian appointed for You) and any other party linked with You.

- Service providers that manage Our marketing or development programs.

7.2 We may go through structural changes in future, in particular, if We sell, transfer or merge part or all of Our business or assets or any associated rights or interests, or if We acquire a business, or enter into a merger, We may disclose Your personal information to the prospective buyer, transferee, merger partner and/or their advisers. If the transaction goes ahead, the buyer, transferee or merge partner may use or disclose Your personal information in the same way as set in this Privacy Policy.

7.3 In addition, We may provide aggregated statistical data to third-parties, including other organizations or members of the public, about how, when, and why You visit Our Website, purchase Vouchers and/or use Voucher Webshop services. This data is non-personal information and will not identify You or provide information on how You individually use the Website, purchase Vouchers or use Voucher Webshop Services.

7.4 Where a third party process Your personal information on Our behalf, it is subject to strict security and confidentiality obligations consistent with this Privacy Policy and applicable laws. We will take all steps reasonably necessary to ensure that Your personal information is treated by the third party to which We disclose it securely and is processed in accordance with this Privacy Policy.

7.5 Your personal information may be disclosed only for the purposes of providing services by a third party to Us or in connection with Your use of Voucher Webshop Services or Your visits of the Website. Third parties to which We disclose Your personal information are governed by a contract and applicable laws and may not use Your personal information for secondary purposes. Processing of personal information by a third party on its own behalf is subject to its privacy policy and applicable laws.

7.6 We will not sell or rent any of Your personal information to third parties. We do not share Your personal information with third parties for their marketing purposes without Your consent.

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8. Automated decision making

8.1 We sometimes use systems to make automated decisions based on personal information We have or We are allowed to collect from others about You. This helps Us to make sure Our decisions are quick, fair, efficient and correct, based on what We know. These automated decisions can affect Our provision of Voucher Webshop Services and other services similar to or connected with Voucher Webshop Services to You now and in future, or the fees that We charge You.

8.2 We are making the following automated decisions:

- Applying for Voucher Webshop Services. When You are applying for Voucher Webshop services, We are performing Our identity and security validation and verification checks based on what We know and based on the personal information You provide to Us. This may include checking of age, residence, nationality, financial position. We are doing this to make sure You have told Us true and correct information, to confirm Your identity and to detect and prevent financial crime, fraud and money-laundering risks.

- Detecting fraud. We use Your personal information to detect if the Voucher Webshop Services are perhaps used for financial crime, fraud or money-laundering or being used or is used in the manner that potentially abuses Voucher Webshop Services or violates the Terms and Conditions. We may at Our discretion temporarily or permanently invalidate the Voucher Webshop Account and to terminate the Terms and Conditions at any time, if We suspect illegal use or fraudulent use of the Voucher Webshop Account or Voucher Webshop Services.

- Fees. We may decide what fees should be determined for some services on the basis of what We know.

- Tailoring Voucher Webshop Services and other services similar to or connected with Voucher Webshop Services. We may place You in groups with similar customers. These are called customer segments. We use these to study and learn about Our customers’ needs and to make decisions based on what We learn. This helps Us to design Vouchers and/or Voucher Webshop Services and other services similar to or connected with Voucher Webshop Services for different customer segments, and to manage Our relationships with them.

8.3 As an individual You have rights over automated decisions. You have the right:

- To ask Us not to make our decisions based on the automated means alone and to request that an individual reviews such decision.

- To object to an automated decision in accordance with section 14.7 below.

8.4 Please contact Us, to exercise Your rights mentioned in the preceding paragraph.

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9. Transfer of personal information to third countries

9.1 In order to deliver Voucher Webshop Services, Your personal information may be transferred to and stored at a destination outside the EEA. We will only send Your personal information outside the EEA to:

- Follow Your instructions.

- Comply with a legal obligation.

- Work with Our affiliates, subsidiaries, agents, subcontractors, and service providers who We use to help Us to render Voucher Webshop Services and to ensure performance of Our obligations under the Terms and Conditions.

9.2 If We do transfer Your personal information to Our affiliates, subsidiaries, agents, subcontractors and service providers outside the EEA, We will make sure that it is protected in the same way as if it was used in the EEA. We will take all steps reasonably necessary to ensure that Your personal information is treated securely and is processed in accordance with this Privacy Policy. If We transfer Your personal information outside the EEA, We will make sure that one of the following safeguards is put in place:

- Transfer of personal information to a non-EEA country with privacy laws that give the same protection as the EEA by way of an adequacy decision issued by the European Commission.

- A contract with the recipient according to the provisions of the GDPR pursuant to which the recipient is obliged to protect personal information to the same standards as required in the EEA.

- Transfer of personal information to organizations that are part of Privacy Shield (a framework that sets privacy standards for information sent between the US and EU countries).

9.3 By submitting personal information to Us, You agree to such transfer, storing and processing as stated in preceding paragraphs.

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10. Marketing

10.1 We may use Your personal information for marketing purposes, so that We can tell You about offers for special features, promotions, products and services We feel may interest You. This is what We mean when We talk about "marketing".

10.2 For marketing purposes We use the personal information We have on You based on what You tell Us and information We collect when You apply, access or use Voucher Webshop Services and Our Website, or from third parties We work with.

10.3 We study Your personal information to gain a view on what may interest You, or what You may want or need. This is how We decide which special features, promotions, products or services may be relevant for You.

10.4 We can only use Your personal information for marketing purposes, if We have either Your consent or a "legitimate interest". This is when We have a business or commercial reason to use Your personal information. However, when We process Your personal information for Our legitimate interest, it must not override Your interests and rights.

10.5 For marketing purposes, We will contact You by e-mail or phone, unless You have asked Us not to. You can either ask Us to stop sending You marketing messages by contacting Us at any time or you may opt out from the link that shall be provided to you in each marketing message.

10.6 If You change Your mind You can update Your choices at any time by contacting Us.

10.7 We may ask You to confirm or update Your choices, if You apply for a use or use any new product or service with Us in future. We will also ask You to do this, if there are changes in the applicable law or the structure of Our business.

10.8 Even if You asked Us not to send marketing messages, You will still receive statements and other important information regarding Voucher Webshop Services, such as, for example, changes to Vouchers distributed on the Website, Voucher Webshop Services or Fees that are not of a marketing nature but for your information.

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11. Retaining collected personal information

11.1 We will retain Your personal information as long as You are Our customer and for at least the period necessary for Us to comply with Our legal obligations and for Our business purposes.

11.2 Terminating Your relationship with Us does not necessarily mean that We will delete all personal information that We hold about You. We will continue to keep Your personal information for at least 5 (five) years or longer from the termination of our contractual relationship for reasons such as:

- To respond to any question or complaint.

- To maintain records required by applicable laws.

- To protect Our legitimate interests.

- To comply with applicable laws including but not limited for fraud and/or security purposes.

11.3 We also may keep Your personal information for longer than 5 (five) years for research or statistical purposes. If We do so, We will make sure that your personal information is anonymized rendering such information as non-personal.

11.4 Third parties to whom Your personal information has been disclosed to and/or to whom You have provided your personal information such as Voucher Issuers maintain their own privacy practices and retention policies, which means that if permitted by law they may retain Your personal information for a period of time deemed necessary.

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12. Your rights

12.1 You have certain rights that may be exercised regarding Our processing of Your personal information. To exercise Your rights mentioned below, please contact Us.

12.2 Accessing Your personal information. You have the right to access personal information We hold about You and to require Us to provide a copy of such personal information. We may request to prove Your identity before We disclose any information to You. This is known as the "right of access".

12.3 Letting Us know if Your personal information is incorrect. If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it corrected. If we've shared inaccurate or incomplete personal information with others, we will inform them about the rectification where possible. If you so require, and where it is possible and lawful to do so, we will also inform you of the parties with whom we have shared your personal information, so that you can contact them directly. This is known as the "right to rectification".

12.4 Requiring Us not to process Your personal information. In certain circumstances You have the right to ask Us to delete Your personal information, if for example there is no need for Us to keep it or if you have withdrawn Your consent. Even if You exercise this right, We may still have to process Your personal information to comply with a legal obligation that We are subject to, or for the establishment, exercise or defense of legal claims. If you are entitled to erasure however and if we have shared your personal information with other parties, we will let them know about the erasure where possible. This is known as the "right to erasure" or the "right to be forgotten".

12.5 Restricting Our processing of Your personal information. You have the right to restrict processing of Your personal information in certain situations described below. If one of these situations applied We would retain Your personal information but would not use or share it while it is restricted, except if We need to use it for certain things, such as legal claims or exercising Our legal rights. If you are entitled to restriction and if we have shared your personal information with other parties, we will let them know about the restriction where it is possible for us to do so. This is known as the "right to restriction of processing".

You can ask Us to restrict use of Your personal information if:

- It is not accurate.

- It has been used unlawfully, however You do not want Us to delete it.

- It is not relevant any more, however You want Us to keep it for use in case of legal claims.

- You already asked Us to stop using Your personal information, but You are waiting for Us to tell You if We are allowed to continue using it.

12.6 Receiving Your personal information. You have the right to receive Your personal information that We process by automated means on the basis of Your consent or on the basis of the Terms and Conditions or other contracts concluded between Us and You. In this situation We will provide Your personal information to You in a structured, commonly used, machine-readable format. You can also ask Us to pass on Your personal information in this format to other organizations, and, if technically feasible, We will do so. This is known as the "right to data portability".

12.7 Objecting Our processing of Your personal information. You have the right to object Our processing of Your personal information. Even if You object to Our processing of Your personal information, We may still process it due to legal or other official reasons, such as legal claims or exercising Our legal rights. However, please tell Us if You think that We should not be processing it. This is known as the "right to object".

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13.1 In case we have asked for your consent to process personal information that we hold about You, You can withdraw Your consent at any time free of charge without affecting the lawfulness of processing based on consent before such withdrawal. Please contact Us, if You wish to do so.

13.2 If You withdraw Your consent, We may be unable to provide Voucher Webshop Services and other services similar to or connected with Voucher Webshop Services to You fully or partly. We will of course advise you if this is the case at the time you withdraw your consent.

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14. Children

14.1 Vouchers are not sold, Voucher Webshop Services are not rendered to and Our Website is not directed to children under the age of majority in their country of residence. We do not knowingly collect information, including personal information, from children or other individuals who are not legally able to purchase and use Vouchers, use Voucher Webshop Services or Our Website.

If We obtain actual knowledge that We have collected personal information from a child under the age of majority in their country of residence without the consent of the holder of parental responsibility, We will promptly delete it, unless We are legally obligated to retain such information. Please contact Us, if You believe that We have mistakenly or unintentionally collected information from a child under the age of majority in their country of residence.

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15. If You choose not to give personal information

15.1 It may be necessary for Us to collect personal information for the purposes of complying with a legal obligation that We are subject to. It may also be necessary for Us to collect personal information for the purposes of performing a contract concluded between You and Us, or in order to take steps at Your request prior to entering such contract.

15.2 If You choose not to give Us Your personal information, it may delay or prevent Us from meeting Our obligations. Also, We may be unable or prohibited to render Voucher Webshop Services to You. Further, We may invalidate Your (or the business entity's You represent) Voucher Webshop Account and/or cancel provision of Voucher Webshop Services to You.

15.3 If collection of any information is optional, it will be made clear before its collection.

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16. Use of "cookies"

16.1 We use cookies to distinguish You from other customers that use Voucher Webshop Services or from other persons visiting the Website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

To find out more about how We use cookies please see Our Cookie Policy.

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17. Third party websites

17.1 This Privacy Policy applies to Your personal information when You (or the business entity You represent) purchase a Voucher and/or apply for, access or use Voucher Webshop Services, and does not apply to third party websites or services that We do not own or control. During the purchasing process you will asked to accept the terms and conditions and privacy policy of the Voucher Issuer. We urge you to review them before completing the purchase. We are not responsible for the operations of Voucher issuers or other third parties, including, but not limited to, their practices on processing of personal information. If You give personal information to or through a third party's website, please note that these third parties have their own privacy policies and You should review them before giving Your personal information to or through such third party's website.

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18. Security

18.1 We are committed to ensuring protection of information that You give Us by using state-of-the art security technology and employing strict physical, electronic and administrative measures, to protect your personal information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage both online and offline.

We use leading technologies such as, but not limited to, encryption by using the highest grade cryptographically strong cyphers before storing personal information in the database, along with firewall and network security technology to protect Our computer systems from unauthorized access. We test Our security systems regularly and also contract with outside companies to audit and test Our security systems and processes.

18.2 Our employees and third parties that provide support services to Us are required to conform to Our privacy standards. We restrict access to Your personal information to employees who need that information in order to perform their duties such as to provide access to the Website, to render Voucher Webshop Services, to perform Our obligations or to exercise Our rights under the Terms and Conditions. Such employees are bound by relevant confidentiality rules and the third parties with whom we may share Your personal information with, are bound by non-disclosure agreements and data processing agreements as applicable.

18.3 While we are dedicated to securing our systems by employing reasonable measures to protect against viruses and other harmful components, the nature of the internet is such that it is impossible to ensure that your access to the Website will be uninterrupted or error-free, or that this Website, its servers or e-mails which may be sent by us are free of viruses or other harmful components.

18.4 You are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the personal information we maintain about you is accurate and current.

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19. Changes to this Privacy Policy

19.1 This Privacy Policy may change. You are responsible for ensuring You periodically visit Our Website and this Privacy Policy to check for any changes. We will notify You before any material change to this Privacy Policy is due to take effect. We will do so by posting a notice of the changes on the Website.

19.2 Any changes to this Privacy Policy will be effective from the date indicated in the notice posted on the Website. If We give You (or the business entity You represent) notice and You (or the business entity You represent) do not tell Us that You (or the business entity You represent) wish to terminate our contractual relationship, then Your (or the business entity’s You represent) continued use of Voucher Webshop Services will constitute acceptance of the changes to this Privacy Policy and You will be deemed (or the business entity You represent) as having accepted the changes.

19.3 However, should You wish not to be bound by any changes of this Privacy Policy, You must notify Us that You do not agree to the changes before those changes enter into force. In that event, We will treat Your notice as a notification that You immediately wish to terminate our contractual relationship.

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20. Contacting Us and how to make a complaint

20.1 Please contact Our Customer Support Service, if You:

- Have any questions in relation to Your personal information or Your rights under the applicable law.

- Wish to exercise Your rights regarding Your personal information that We hold.

- Wish to make a complaint.

20.2 You can contact the Customer Support Service:

- via post by sending a letter to:

Voucher Webshop Privacy Keymarking Ltd Athalassas Ave 170, Floor 3, Strovolos, Cyprus

- via e-mail at: customersupport@voucherwebshop.com

- via the 'Contact' page on the Website: (https://www.voucherwebshop.com/).

20.3 File a complaint with a supervisory authority

Further to the above, you also have the right to file a complaint to the national data protection authority, the Office of the Commissioner for Personal Data Protection in Cyprus which is situated at 1 Iasonos Str., 1082 Nicosia, P.O. Box 23378, CY-1682 Nicosia, Cyprus, Tel.: +357 22 818 456, Fax: +357 22 304 565, E-mail: commissionerdataprotection.gov.cy.

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