INTRODUCTION

This Privacy Policy applies to the personal data we collect during the course of sending out our newsletters to people who have joined our mailing list, carrying out surveys in relation to our products and services, operating contests and promotions and responding to general enquiries or customer service queries sent to us. "Personal data" is information about living individuals, being information that relates to them or which identifies them directly or indirectly. This Privacy Policy explains what personal data we process, why, how it is legal and what your rights are.

ABOUT US AND THIS PRIVACY POLICY

This Privacy Policy is provided by Mark Anthony Brands International Unlimited Company, 4th Floor, Donnybrook House, 36 – 42, Donnybrook Road, Dublin D04 WN49 (Ireland) ("we" or "us"). We are a 'controller' for the purposes of the General Data Protection Regulation (EU) 2016/679, the Irish Data Protection Acts 1988 to 2018 and the German Federal Data Protection Act 2017 (collectively the "Data Protection Laws"). We take your privacy very seriously and ask that you read this Privacy Policy carefully as it contains important information about our processing activities and your rights.

HOW TO CONTACT US

If you would like this Privacy Policy in another format or if you have any queries regarding our processing of data, please contact us by using the details below:

Customer Services info@markanthonyintl.com

CHANGES TO THIS PRIVACY POLICY

The latest version of the Privacy Policy can be found here. We may change this Privacy Policy from time to time. We will alert you on our website, de.whiteclaw.com when changes are made.

Current version: May 2020

INFORMATION WE COLLECT AND WHAT WE USE IT FOR

• Newsletters
  We regularly send newsletters about our products and events to those who have consented to join our mailing list. For this purpose, we process your name and email address. You can withdraw your consent at any time by clicking "unsubscribe" in the email. Please refer to the section "Your rights" for more information.
• Surveys
  As part of our efforts to continuously improve our business, we carry out surveys in relation to our products and services. For this purpose, we process your name, email address and your survey feedback.
• Contests and Promotions
  As part of our marketing campaigns we regularly run contests and promotions. For this purpose, we process your name and email address in accordance with your marketing preferences, if relevant.
• General Enquiries
  We process your name, contact details and details of the enquiry when you send us enquiries about our business. We will use this information to respond to you.
• Customer Service Queries
  We process your name, contact details and details of the query when you send us a query about our customer service. We will use this information to respond to you.
• Enforcing and Defending Our Rights
  We have a legitimate interest in ensuring that our services and the website are used in accordance with our terms and conditions of use and policies. We may use your name and contact details and any other information provided to us where necessary for the purpose of complying with our legal obligations and otherwise where necessary for the purpose of establishing, exercising or defending a legal claim, a prospective legal claim, legal proceedings or prospective legal proceedings.

HOW WE KEEP YOUR PERSONAL DATA SECURE

We implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data.

LEGAL BASIS FOR PROCESSING YOUR INFORMATION

Surveys, General Enquiries made by you, Customer Service Queries made by you - The legal basis we rely on for the processing of your personal data is for our legitimate interests i.e. we have good, sensible, practical reasons for processing your personal data which is in our interest. We have outlined these interests in the section "Information we collect and what we use it for". We have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. You can object to any of the processing that we carry out on the grounds of legitimate interests on grounds which are personal to you and we will consider any such objection in accordance with our legal obligations under Data Protection Laws.

Contests and promotions - The legal basis we rely on for the processing of your personal data is that processing is necessary for us to perform the contract you have agreed to enter with us (i.e. the terms and conditions of the contest/promotion). If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms and conditions.

Newsletter - We process your personal data based on any consent you have given (if required) or in accordance with our legitimate interests in communicating with our customers, subject to any marketing preferences you have expressed to us.

ORGANISATIONS THAT WE MAY SHARE YOUR DATA WITH

These providers (together with any other IT or business support service providers we may engage from time to time) process your personal data as part of the services they offer to us. We take steps to ensure that our service providers process your data in accordance with the Data Protection Laws, only use it in accordance with our contract with them and keep it secure. If you would like more information about our processors, please contact us using the details at the "How to contact us" section. Your personal data is transferred outside of Ireland and the EEA in order for website hosting services provided by Amazon Web Services which is in US and Mark Anthony Group in Canada who provide Management of website and any IT services to us. It may be necessary for other transfers outside the EEA to occur in accordance with the business practices of any other of the above service providers we may engage from time to time. Any transfer of your data outside Ireland and the EEA will be carried out in accordance with the Data Protection Laws to safeguard your privacy rights. In case of Canada, there is an adequacy decision of the European Commission pursuant to Directive 95/46/EC which avails under article 46 of the GDPR. In case of the United States of America, we ensure that the relevant company has entered into a data transfer agreement containing clauses offering an adequate level protection according to the European Commission, has adopted corporate binding rules, or has otherwise implemented appropriate safeguards. If you have any questions around the transfer mechanisms used by us, please contact us using the contact details in the 'How to Contact Us' section.

RETENTION AND DELETION OF YOUR PERSONAL DATA

We only retain your personal information for as long as we need it in order to provide you with the service you have requested from us.

• Newsletter – When you withdraw your consent, we will only retain your email address in our "do not contact" list for newsletters to ensure that your marketing preferences are respected.
• Survey – 12 months from the date the data is collected.
• Contest and Promotions – 6 months from the date the contest/promotion is completed.
• General Enquiries – 12 months from the date your query is resolved.
• Customer Service queries – 12 months from the date your query is resolved.

The above periods may be extended if any of the above is retained by us in the context of your purchase of a product or a legal process or where legal retention periods require a longer processing.

YOUR RIGHTS

As a data subject, you have the following rights under the Data Protection Laws:

• Right to object to processing of your personal data;
• Right of access a copy of personal data relating to you;
• Right to correct any mistakes in your information;
• Right to restrict the processing of your personal data, e.g. if you dispute the correctness of your personal data;
• Right to ask us to stop contacting you with direct marketing;
• Right to have your personal data ported to another controller;
• Right to withdraw a consent you have given at any time; the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal; and
• Right to erasure.

Rights in relation to automated decision making do not apply as we do not carry out any automated decision making.

If you would like to exercise your rights, please contact us at the details set out above in the section "How to contact us" section.

We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.

Please note that exceptions apply to some of these rights which we will apply in accordance with the law.

Complaints

If you believe your information has not been handled in accordance with this Privacy Policy, please contact us using the details in the "How to contact us" section.

Alternatively, you can send your complaint to a German Data Protection Supervisory Authority. The addresses and URLs of the German Data Protection Supervisory Authorities can be found at https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

Alternatively, you can send your complaint to the Irish Data Protection Commission. Information about how to do this is available on its website at www.dataprotection.ie.

In any case, we would ask that you contact us in the first instance so that we can assist you with your query or concern.