Regarding the performance of information obligations under Article 13 of Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016. on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC.

Hamlet Consulting Luxembourg s.à r.l.

14-16 avenue Pasteur
L-2310 Luxembourg
RCS Luxembourg B226002

Private limited liability company (“s.à r.l.”) with a share capital contribution of 12000 EUR.

 1. ADMINISTRATOR OF YOUR PERSONAL DATA:

The Administrator of your personal data is Hamlet Consulting Luxembourg s.à r.l. headquartered at 14-16 avenue Pasteur at L-2310 Luxembourg, e-mail contact: admin@hamletconsulting.com

 2. PURPOSES FOR WHICH WE WILL PROCESS YOUR PERSONAL DATA:
Your personal data is processed for the purpose of providing services or selling products by the Administrator. This purpose also includes the processing of your personal data for marketing purposes and for the organization and conduct of contests by the Administrator.

2.1 Your personal data may also be processed for the purpose of handling complaints or other claims made by you against the Data Administrator.
2.2 With your voluntary consent, your data may also be processed for marketing purposes, including profiling, also in relation to third party products and services. If you give this consent, your data may be processed by TRUSTED PARTNERS.
2.3 In addition, your data may also be processed to match the content of the Administrator’s websites to your interests, as well as to detect bots and abuse, and for statistical measurement and improvement of the Administrator’s services.

3. FOR WHAT PERIOD WILL YOUR PERSONAL DATA BE STORED?


3.1 With respect to the Administrator’s services, your data will be processed for the period during which the services are provided and, occasionally, after the services are terminated, but only if permitted or required by applicable law, e.g., processing for statistical or billing purposes, or for the purpose of asserting claims. In this case, the data will be processed only for the period necessary for such purposes.
3.2 With respect to the sale of products or the processing of complaints or your other claims, your data will be processed for the period of time necessary to fulfill the sales contract or to process the complaint and, thereafter, only if permitted or required under applicable law, e.g., processing for statistical, billing purposes or to assert claims.
3.3 Data will be processed for marketing purposes until you withdraw your consent to such processing.
3.4 When it comes to tailoring the content of the Administrator’s services to your interests, as well as detecting bots and abuse and statistical measurements and improving the service, your data will be processed for these purposes until you object or until you stop using the Administrator’s services.

4. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?


4.1 With regard to the provision of service and sale of products and the processing of complaints or other claims by the Administrator, your data will be processed on the basis of Article 6(1)(b) of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (GDPR, General Data Protection Regulation) (this is necessary for the performance of the contract to which the data subject is a party).
4.2 The legal basis for the processing of your personal data for marketing purposes is your voluntary consent to data processing, including profiling.
4.3 When it comes to tailoring the content of the Administrator’s service to your interests, as well as detecting bots and abuse and statistical measurements and improving the service, and in some cases handling complaints, your data will be processed on the basis of Article 6(1)(f) of the GDPR (legitimate interest of the Administrator). The Administrator’s legitimate interest is to tailor the content of the Administrator’s services, e.g. websites or applications, to your needs, to ensure the security of these services, as well as their continuous improvement, and to process complaints about the Administrator’s products.

5. DATA REQUIREMENTS


5.1 The provision of data for the performance of services or sales of products and the processing of complaints or other claims is necessary for the provision of these services and the performance of sales or the processing of complaints. If these data are not provided, the service cannot be provided or the sale cannot be realised , and the complaint cannot be accepted.
5.2 In the case of contests – the provision of data is necessary for the purpose of conducting the contest. If this data is not provided, it is not possible to participate in the contest.

5.3 Providing personal data for marketing purposes is voluntary. If you do not consent to the processing of personal data left by you in the course of using the websites, services and other functionalities, including those stored in cookies, your personal data will not be processed for this purpose. For the avoidance of doubt, the lack of consent referred to in the previous sentence does not stop the storage of cookies on your device.

5.4 The processing of data for other purposes, i.e. matching the content of the Administrator’s websites to your interests, detecting bots and abuse of the Administrator’s services, statistical measurements and improving the Administrator’s services is necessary to ensure the high quality of the Administrator’s services. Failure to collect your personal data for these purposes may prevent the proper provision of services.

6. TO WHICH RECIPIENTS WILL YOUR PERSONAL DATA BE TRANSFERRED?


6.1 Your data may be transferred to entities processing personal data on behalf of the Administrator, e.g. IT service providers, marketing agencies – with such entities processing data on the basis of a contract with the Administrator and only in accordance with the Administrator’s instructions.
6.2 Your data may also be prepared to entities authorized to obtain them under applicable law, e.g. law enforcement agencies in the event of notification by an authority on the appropriate legal basis (e.g. for the purposes of ongoing criminal proceedings).

7. TRANSFERS OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA


Your personal data will not be transferred to third countries outside the European Economic Area.

8. WHAT ARE YOUR RIGHTS RELATED TO THE PROCESSING OF YOUR PERSONAL DATA?


You have the following rights in connection with the Administrator’s processing of your personal data:
 – The right to access your data, including obtaining a copy of your data,
 – The right to request rectification of your data,
 – The right to have your data deleted (in certain situations),
 – The right to lodge a complaint with a supervisory authority dealing with personal data protection,
 – The right to restrict data processing.

To the extent that your data are processed on the basis of consent or as part of the service provided (the data are necessary for the purpose of providing the service), you may additionally exercise the following rights:

– The right to withdraw consent to the extent that they are processed on that basis. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal,
 – the right to portability of personal data.
In order to exercise the above rights, please send an email to admin@hamletconsulting.com
In accordance with the provisions of Article 12(3) of the GDPR, we will inform you of the action taken by us within 30 days.

9. INFORMATION ABOUT COOKIES


9.1 The Administrator uses two types of cookies:


(a) session cookies: they are stored on the user’s device and remain there until the session of a given browser ends. The stored information is then permanently deleted from the device’s memory. The mechanism of session cookies does not allow the collection of any personal data or any confidential information from the user’s device;


b) permanent cookies: they are stored on the user’s device and remain there until they are deleted. Ending the session of a given browser or switching off the device does not delete them from the user’s device. The mechanism of permanent cookies does not allow the collection of any personal data or any confidential information from the User’s Device.

9.2 The cookies used by the Administrator are safe for the user’s device. In particular, by this means it is not possible for viruses or other unwanted software or malware to enter the users’ devices. These files allow to identify the software used by the user and to customize the Administrator’s service individually for each user. Cookies usually contain the name of the domain from which they originate, the time they are stored on the device and the assigned value.

9.3 The User has the option to restrict or disable access of cookies to his/her Device. If this option is exercised, the use of the site will be possible, except for functions that by their nature require cookies.

9.4 The administrator uses own cookies for the following purposes:


a) service configuration: adapting the content of the website to the user’s preferences and optimizing the use of the website, recognizing the website user’s device and its location and, accordingly, displaying the website, tailored to the user’s individual needs, remembering the settings selected by the user and personalizing the user’s interface, e.g. with regard to the selected language or the region from which the user comes, remembering the history of visited pages on the website for the purpose of recommending content, font size, website design, etc,

b) authenticating the user on the site and ensuring the user’s session on the site: maintaining the user’s session on the site (after logging in), which allows the user not to re-enter his/her login and password on each sub-page of the site; correct configuration of selected functions of the site, allowing, in particular, to verify the authenticity of the browser’s session, optimizing and increasing the efficiency of the services provided by the Administrator,

c) implementation of processes necessary for full functionality of the websites: adapting the content of the website to the user’s preferences and optimizing the use of the website. In particular, these files allow to recognize the basic parameters of the user’s device and properly display the website, tailored to his individual needs,


d) remembering the user’s location: to correctly configure selected functions of the website, allowing in particular to adjust the information provided to the user taking into account his location,


e) analysis and research, as well as audience auditing: creating anonymous statistics that help to understand how users of the website use the website, which allows to improve its structure and content, creating viewing statistics for our FAVORITE PARTNERS and advertisers,


f) provision of advertising services: customization of advertisements presented through the service for third-party services and products,

g) to ensure the security and reliability of the service: creating online surveys and protecting them from multiple voting by the same people.

9.5 The user may independently and at any time change the settings for cookies, specifying the conditions for their storage and access by cookies to the user’s device. The user may change the settings referred to in the preceding sentence through the settings of the web browser or through the configuration of the service. These settings can be changed, in particular, in such a way as to block the automatic handling of cookies in the settings of your web browser or inform you of the placement of cookies on your device each time. Detailed information about the possibility and methods of handling cookies is provided in the settings of your software (web browser).

9.6 The user may delete cookies at any time using the available functions in the web browser he/she uses.

9.7 Restricting the use of cookies, may affect some of the functionality available on the website.

10. OTHER INFORMATION

The Administrator’s services may use so-called social plugins for social media such as Facebook, Google+, Twitter, Pinterest, LinkedIn, Instagram . Using the functionalities provided by these plugins, you can recommend particular content or share it on a particular social media site. Please note that by using these plugins, you are exchanging data between you and the respective social network. The administrator does not process this data, nor does the administrator have knowledge of what data is collected. Therefore, we encourage you to read the regulations and privacy policies of the owners of these social networks before using a particular plug-in.

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