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Welcome to our Privacy Notice (hereinafter “Notice”). We have compiled this Notice to help you better understand the nature of your relationship with us and enable you to make informed decisions about certain aspects of our relationship and more specifically your data processing. For the purposes of this Notice, ADME (CY) Ltd (“ADME) is the “Data Controller” pursuant to the EU General Data Protection Regulation 2016/679 (“GDPR”), and the Republic of Cyprus’ related laws on processing of personal data. The main establishment and the central administration of ADME is 62 Agiou Athanasiou, BG Waywin Plaza, 1st Floor, Office 101, 4102, Limassol, Cyprus. If you leave in a country outside the European Economic Area (EEA), collection and processing of your data shall be governed in accordance with the privacy laws of the state of California and where applicable Brazilian related General Data Protection Law. 

 

Should you require any further clarifications or information as to how ADME processes your personal data, you may do so by sending an email at privacy@thesoul-publishing.com.

 

We are committed to process your personal data as follows:

 

  • Fairly and lawfully;

  • In an appropriate manner;

  • For limited purposes and not longer than necessary;

  • For the purposes required and not in an excessive way;

  • Keep them up-to-date and accurate;

  • Processed in line with your individual rights (as applicable) and in accordance with the law;

  • In a secure way avoiding unauthorized or unlawful processing;

  • Protected against breach, accidental loss, destruction, or damage by using appropriate technical and organizational measures;

  • Not transferred to third parties or organizations without adequate protection. 

 

We will collect, store, use and overall process the following categories of data:

 

  • Information you have provided on our application form, including your business / company name, your full name/surname, email address, and location details;

  • Details about your business portfolio and previous works of yours;  

  • Data captured at the time of submitting the application form, to confirm the validity of acceptance, such as date, time, browser name and type, operating system, IP address and device details. 

 

Any collected personal data of yours, including any special categories of personal data (where applicable) shall be processed solely by us for the purposes and for organizing the selection process for external content providers, assess your content production capabilities and to facilitate negotiations with you for a potential cooperation. In addition, we will process any such data to comply with our legal and statutory obligations, as well as for the purposes of the legitimate interests pursued by ADME.

 

We will only use the data for the purposes mentioned above. Your data may be processed through our secure computer network systems and accessed only by authorised persons of ADME. Data processing may be carried out on behalf of us by third party data processors which may be located in the European Economic Area (EEA) or in other third countries, pursuant to written and express authorisation for specific purposes contained in the relevant authorisation. We have taken all necessary steps, including the implementation of appropriate legal, technical and organisational measures, to ensure that the data processing meets all applicable statutory requirements, thus safeguarding your rights.

 

We may operate within the European Union (EU), the European Economic Area (EEA) and other third countries, and therefore your personal data or part of them may have to be transferred overseas.

 

We have taken all reasonable steps to ensure that your personal data are provided with adequate protection based on international protection frameworks and that all transfers of data are conducted pursuant to our written agreements and the supervisory authorities’ guidelines (if required) and/or other legal and/or regulatory requirements.

 

You will not be subject to decisions that will produce legal effects or have a significant impact on you, based solely on automated decision making.

 

You have the right to request access, rectification, to restrict the processing of your personal data, to object, to request erasure as well as the right to data portability. Where the data processing is taking place solely pursuant to your express consent, you have the right to withdraw such consent at any given moment. Such consent withdrawal will not affect the lawfulness of any data processing based on that ground prior to your withdrawal.

 

Any personal data related requests shall be processed within reasonable time and in any case within 1 (one) month from your written request. This period of time may be extended under certain circumstances by further 2 (two) months.

 

You will not have to bear any cost to exercise any of your rights. We may though charge a reasonable fee should your requests be clearly unfounded or excessive, due to their repetitive character, or refuse to comply with such requests.

 

If and as applicable, we may request specific information to assist us confirm your identity and ensure your capacity to enforce your rights. This is part of our security measures to certify that personal information is not disclosed to any person who has no right to receive it.

 

We will retain your personal data for as long as our contractual relationship exists plus a period of time corresponding to the applicable statute of limitations for any kind of claims, or legal or regulatory obligations. In case that no agreement is executed between us, the retention period will be 1 year from the date of submission of the application form.  

 

 refresh token data for a period of 7 (seven) days from the date of collection and any other statistical non-identifiable or personal related data for as long as required to reach statistical results, plus a period of time corresponding to the applicable statute of limitations for any kind of claims, or legal or regulatory obligations.

 

For both hard and electronic copy processing (where and as applicable) we have data management systems which are periodically updated in accordance with technological development and a framework of multilevel security policies to hold data confidential and secure. Security measures have also been taken to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

 

Moreover, we have procedures to deal with suspected data security breaches or threats and should a breach ever materialise, you will be notified accordingly, along with the supervisory authority, if we are required to do so.

 

We keep our Notice under regular review and we reserve the right to update the same at any time. If we make changes to this Notice during any contractual relationship with you which, in our sole discretion, has a material impact on your rights with respect to how we process your personal data, we will notify you via email to the email address you provided us.

 

Complaints relating to the processing of any data may be communicated electronically at privacy@thesoul-publishing.com.

 

Complaints may also be lodged before the supervisory authority responsible for the protection of personal data, in the country of your habitual residence, place of work, or place of the alleged infringement of your personal data. More information about how to contact the supervisory authorities across the EEA, can be found in the European Data Protection Board’s website here (https://edpb.europa.eu/about-edpb/about-edpb/members_en).

Privacy Notice

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