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PRIVACY POLICY

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This website is operated by Spot-on Global Group Ltd. We take your privacy very seriously therefore we urge to read this policy very carefully because it contains important information about on:

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  • who we are,

  • how and why we collect, store, use and share personal information,

  • your rights in relation to your personal information, and

  • how to contact us and supervisory authorities in the event that you have a complaint.



Who we are

Spot-on Global Group Ltd ('we' or 'us') collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data protection Regulations which apply across the European Union (including the United Kingdom) and we are responsible as 'controller' of that personal information for the purposes of those laws.



The personal information we collect and use

a) Personal information you provide to us

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We collect the following personal information that you provide to us:

Full name, email address, phone number, address and purchase details including place of purchase, date of purchase and proof or purchase.

Some examples of when we collect this information include:

When registering for an extended warranty


b) Personal information you provide about third parties

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If you give us information about another person, you confirm that the other person has appointed you to act on their behalf and agreed that you:

shall consent on their behalf to the processing of their personal data;
shall receive any data protection notices on their behalf; and
shall consent on their behalf to the transfer of their personal data abroad.


c) Monitoring and recording communications

We may monitor communications such as emails and telephone calls for the following purposes:

quality assurance, training and record keeping.



How we use your personal information

We collect information about our users for the following purposes:

To identify and manage extended warranties; conduct research and statistical analysis



Who your information may be shared with

We may share your information with:

Law enforcement agencies in connection with any investigation to help prevent unlawful activity

We will not share you personal information with any other 3rd parties.



Marketing

We would like to send you information about products, services, offers, competitions and our business which may be of interest to you. Such information could be sent by post, email, telephone, text message or automated call.

We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on purchase, signing up to a newsletter, entering a competition etc). If you do opt in to receive such marketing from us you can opt out at any time (see 'What rights do you have?' below for further information). If you have any queries about how to opt out, or if you are receiving messages you do not want you can contact us using the details provided below.



Whether personal information has to be provided by you, and if so why

No personal information has to be provided by you to us at any time.



How long your personal information will be kept

We will hold your personal information for the following periods:

Name, email address, phone number, address and purchase details including place of purchase, date of purchase and a copy of your proof of purchase will be kept on record for 8 years to cover the extended warranty period.

These periods are no longer than necessary in each case.



Reasons we can collect and use your personal information

We rely on the following as the lawful basis on which we collect and use your personal information:



Keeping your information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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We will also use technological and organisation measures to keep your information secure. These measures may include the following examples:

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All data is served on secure servers.

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We are certified to ISO 27001. This family of standards helps us manage your information and keep it safe and secure.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

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Indeed, while we will use all reasonable efforts to secure your personal data, in using the site you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using the details below.



Transfers of your information out of the EEA

We may need to transfer your personal data to the following countries outside of the European Economic Area:

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Australia

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These transfers will be undertaken for the purpose of

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Personal information is sent to our office located in Australia.

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Any transfers to these countries will be undertaken on the basis that that country, territory or one or more specific sectors in that country, or an international organisation ensures an adequate level of protection.

For more information on the basis of any non-EEA transfers, our safeguards or Commission details, please contact us as described below. We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.



What rights do you have?

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
 

  • fair processing of information and transparency over how we use your use personal information

  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address

  • require us to correct any mistakes in your information which we hold

  • require the erasure of personal information concerning you in certain situations

  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

  • object at any time to processing of personal information concerning you for direct marketing

  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

  • object in certain other situations to our continued processing of your personal information

  • otherwise restrict our processing of your personal information in certain circumstances

  • claim compensation for damages caused by our breach of any data protection laws
     

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individual's rights under the General Data Protection Regulations (http://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)

If you would like to exercise any of these rights please:
 

  • email, call or write to us

  • let us have enough information to identify you

  • let us have proof of your identity (a copy of your driving license, passport or a recent credit card/utility bill)

  • let us know the information to which your request relates
     

From time to time we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.



How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.



Changes to the privacy policy

This privacy policy was published on 03/10/2022 and last updated on 03/10/2022.

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this website. We will also attempt to notify users of any changes by:

Email if you have opted in to receive emails;
A notice on the website header.



Contacting us

If you have any questions about this policy or the information we hold about you, please contact us by:

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E-mail: mark.hunter@hunterglobalsolutions.com

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Post: 19/F, Lee Gardens One, Hysan Avenue, Causeway Bay, Hong Kong SAR

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