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GLOBAL PRIVACY POLICY



Privacy Policy

The purpose of this privacy policy is to provide all the information on the
processing of personal data carried out by Demalia OÜ when the User accesses and
navigates this site (as better indicated below).‍


1. INTRODUCTION - WHO ARE WE?

Demalia OÜ having its registered office in Tornimäe tn 5, Tallinn, Harju
maakond, 10145, Estonia, with VAT No. EE102554218 (here in after, "Owner"),
owner of this website/landing page (hereinafter, the "Site"), as the owner of
the processing of personal data of the users who browse the site (hereinafter,
"Users") provides below the privacy policy pursuant to Art. 13 of the EU
Regulation 2016/679 of April 27, 2016 (hereinafter, "Regulation", or "Applicable
Legislation").
‍


2. HOW TO CONTACT US?

The Controller holds in the highest regard the right to privacy and protection
of personal data of its Users.
‍
For any information in relation to this privacy policy, Users may contact the
Controller at any time using the following methods:
‍


 * By sending a registered letter with return receipt to the registered office
   of Demalia OÜ: Tornimäe tn 5, Tallinn, Harju maakond, 10145, Estonia;
 * By sending an e-mail message to: info@demalia.com;

The Owner has not identified a Data Protection Officer (DPO or DPO), as it is
not subject to the designation requirement under Article 37 of the Regulations.


3. WHAT WE DO? - PURPOSE OF PROCESSING

The Site allows Users to release their contact information in order to be
contacted in order to receive offers, coupons, discounts and/or compare quotes
with each other regarding promotions presented on the page from time to time
(hereinafter, the "Service"). In connection with the activities that may be
carried out through the Site, the Owner processes and collects personal data
relating to Users.

This Site and any services offered through the Site are restricted to
individuals who are eighteen years of age or older. Therefore, the Controller
does not collect personal data relating to individuals under the age of 18. Upon
the request of Users, the Controller will promptly delete all personal data
unintentionally collected relating to individuals under the age of 18.

In particular, Users' personal data will be lawfully processed by the
Controller, in accordance with Article 6 of the Regulations, for the following
processing purposes:
‍


a. contractual obligations and provision of the Service, to enable navigation of
the Site, enjoyment of the Service, and fulfill specific User requests.
‍


User data processed by the Owner for the purpose of any registration on the Site
include:
‍

 * "browsing" personal data (i) collected through the use of so-called.
   "technical cookies", the only ones present within the Site (which do not
   require the User's consent) and (ii) the transmission of which is implicit in
   the use of Internet communication protocols, such as: IP addresses used by
   users who connect to the Site, the URI (Uniform Resource Identifier) notation
   addresses of the requested resources, the time of the request, the method
   used in submitting the request to the server, the size of the file obtained
   in response, log files and other parameters relating to the User's operating
   system and computer environment;
 * data collected as a result of completion of the registration form by the
   User, such as the User's first name, last name and gender, e-mail address, as
   well as any personal information the User may and voluntarily provide to the
   Controller.

Unless the User gives the Data Controller a specific and optional consent to the
processing of his/her data for the additional purposes provided for in the
following paragraphs, the User's personal data will be used by the Data
Controller for the sole purpose of ascertaining the identity of the User
(including through validation of the e-mail address), thus avoiding possible
fraud or abuse, and contacting the User for service reasons only (e.g. sending
notifications regarding the services offered on the Site). Notwithstanding the
provisions elsewhere in this privacy policy, under no circumstances will the
Owner make Users' personal data accessible to other Users and/or third parties.
‍

b. legal obligations, i.e., to fulfill obligations required by law, authority,
regulation or European legislation.
‍


The provision of personal data for the above processing purposes is optional but
necessary, as failure to provide it will make it impossible for the User to
browse the Site, register on the Site and take advantage of the services offered
by the Owner on the Site.


4. ADDITIONAL PURPOSES OF PROCESSING

4.1 DIRECT MARKETING (SENDING ADVERTISING MATERIAL, DIRECT SALES AND COMMERCIAL
COMMUNICATION)

Some of the User's personal data (first name, last name, gender, e-mail
address), may also be processed by the Data Controller for marketing purposes
(sending advertising material, direct sales and commercial communication), i.e.
so that the Data Controller can contact the User by mail, e-mail, telephone
(fixed and/or mobile, with automated call or call communication systems with
and/or without the intervention of an operator) and/or SMS and/or messaging
systems to propose to the User the purchase of products and/or services offered
by the Data Controller itself and/or third party companies, present offers,
promotions and commercial opportunities.

In case of non-consent, the possibility to use the Site will not be affected in
any way.

In case of consent, the User may at any time revoke the same by making a request
to the Owner in the manner indicated in paragraph 8 below.

The User may also easily object to further sending of promotional communications
via e-mail also by clicking on the appropriate link for revocation of consent,
which is present in each promotional e-mail. Upon making the revocation of
consent, the User will see a message confirming that the request has been
received by the Controller. If the User wishes to revoke his or her consent to
the sending of promotional communications via telephone, while continuing to
receive promotional communications via e-mail, or vice versa, please send a
request to the Controller in the manner indicated in paragraph 8 below.

The Data Controller informs that, following the exercise of the right to object
to the sending of promotional communications by e-mail, it is possible that, for
technical and operational reasons (e.g. formation of contact lists already
completed shortly before the receipt by the Data Controller of the request for
objection) the User will continue to receive some additional promotional
messages. Should the User continue to receive promotional messages after 24
hours have elapsed since the exercise of the right to object, please report the
problem to the Controller, using the contacts indicated in paragraph 8 below.

4.2 PROFILING

The User's personal data (i.e. personal and contact data and information
relating to the services towards which the User has expressed interest) may also
be processed by the Data Controller for profiling purposes, i.e. to reconstruct
the User's tastes and consumption habits, identifying the User's consumer
profile, in order to be able to send the User commercial offers consistent with
the identified profile.

If consent is not given, the possibility of registering with the Site will not
be affected in any way.

In case of consent, the User may at any time revoke the same by making a request
to the Data Controller in the manner indicated in paragraph 8 below.

4.3 DISCLOSURE OF DATA TO THE OWNER'S PARTNERS

The User's personal data (i.e., first name, last name, e-mail) will be disclosed
by the Owner to the following categories of third-party companies: (i) Household
Products; (ii) Telecommunications; (iii) Energy Providers; (iv) Entertainment;
(v) Investment; (vi) Financing; (vii) Real Estate Services; (viii) E-commerce;
(ix) Health & Beauty; (x) Fashion; (xi) Technology; (xii) Insurance Provider
Companies; (xiii) Food & Beverage; (xiv) Automotive; (xv) Claims; (hereinafter,
collectively, the "Data Controller's Partners")
‍
The Owner's Partners, as autonomous data controllers, will process the User's
personal data for their own marketing purposes (direct sales, sending of
advertising material and commercial communication), and may contact the User by
mail, e-mail, telephone (fixed and/or mobile, with automated call or call
communication systems with and/or without the intervention of an operator)
and/or SMS and/or messaging systems to propose to the User the purchase of
products and/or services offered by the same categories of third party companies
and/or other companies and present the User with offers, promotions and
commercial opportunities. Once the transfer has taken place, it will be the
responsibility of the Holder's Partner to provide Users in accordance with
Article 14 paragraph 3 of the Regulations with all the information provided for
in the same Article 14 of the Regulations.

In case of non-consent, the possibility to register on the Site will not be
affected in any way.

In case of consent, the User may at any time revoke the same by making a request
to the Controller in the manner indicated in paragraph 8 below.

The Data Controller informs that the User's personal data will be processed by
the Data Controller's Partners as autonomous data controllers, on the basis of
the specific information that will be issued by the Data Controller's Partners
to the Users. Any requests not to receive further commercial communications from
the Controller's Partners, to whom the data have already been disclosed by the
Controller, should therefore be addressed directly to them.


5. LEGAL BASIS

Service provision (as described by par. 3, lett. a) above): the legal basis
consists of art. 6, par. 1, lett. b) of the Regulations, i.e. the processing is
necessary for the performance of a contract to which the User is a party or the
performance of pre-contractual measures taken at the User's request.

Legal obligations (as described by Section 3(c) above): the legal basis consists
of Article 6(1)(c) of the Regulations, as the processing is necessary to fulfill
a legal obligation to which the Data Controller is subject.

Additional processing purposes: for processing related to marketing activities,
profiling, communication of data to the Data Controller's Partners (as described
by Paragraph 4 above), the legal basis consists of Art. 6(1)(a) of the
Regulations, i.e. the provision by the data subject of consent to the processing
of his/her personal data for one or more specific purposes. For this reason, the
Data Controller asks the User for the provision of a specific free and optional
consent, in order to pursue this processing purpose.


6. MODES OF PROCESSING AND DATA RETENTION TIMES

The Data Controller will process Users' personal data by means of manual and
computerized tools, with logic strictly related to the purposes themselves and,
in any case, in such a way as to ensure the security and confidentiality of the
data.

The personal data of the Users of the Site will be kept for the time strictly
necessary to fulfill the primary purposes illustrated in paragraph 3 above, or
in any case as necessary for the protection in civil law of the interests of
both the Users and the Data Controller.

In the cases referred to in paragraphs 4.1, 4.2, 4.3 above, the personal data of
the Users will be kept for the time strictly necessary to carry out the purposes
illustrated in the same and, in any case, until the User revokes his/her
consent.


7. SCOPE OF COMMUNICATION AND DISSEMINATION OF DATA

The User's personal data may be transferred outside the European Union and, in
this case, the Controller will ensure that the transfer takes place in
accordance with the Applicable Legislation and, in particular, in accordance
with Articles 45 (Transfer on the basis of an adequacy decision) and 46
(Transfer subject to adequate safeguards) of the Regulations.
‍
The personal data of the Users may come to the attention of the employees and/or
collaborators of the Controller in charge of managing the Site and the Users'
requests. These individuals, who have been instructed to do so by the Data
Controller pursuant to Article 29 of the Regulations, will process Users' data
exclusively for the purposes indicated in this notice and in compliance with the
provisions of the Applicable Regulations.
‍
Third parties who may process personal data on behalf of the Data Controller as
Data Processors may also become aware of Users' personal data, such as, by way
of example, IT and logistics service providers functional to the operation of
the Site, outsourcing or cloud computing service providers, professionals and
consultants.
‍
Listed below are the Data Processors that the Data Controller uses to send
promotional communications:
‍

 * REEMEDIA INTERNET, SL C / Filá Cordón no 36, Pol. Indl Cotes Altes, 03804
   Alcoy, Alicante, Spain
 * Mapp Digital Italy SRL - Via Pietro Orseolo 12 20144 Milan Italy

Users have the right to obtain a list of additional Data Processors appointed by
the Controller by making a request to the Controller in the manner set forth in
paragraph 8 below.

In addition to the sectors listed, you can expect Demalia OÜ to find and run 3rd
party offers from Advertisers that we believe will be of interest to our
members. The following Networks allow us to send their third party offers. You
can view their Advertisers/Client List here:
‍

 * Neilson Financial (British Seniors Insurance) -
   https://www.britishseniors.co.uk/privacy-policy/
 * Neilson Financial (Smart Insurance) -
   https://www.smartinsurance.co.uk/privacy-policy-cookies/
 * WE BREATHE MEDIA LIMITED    91 Waterloo Road   London, SE1 8RT
   https://www.webreathemedia.com/privacy-policy
 * Click Laboratories Limited    91 Waterloo Road   London, SE1 8RT
   https://www.clicklabsgroup.com/privacy-policy-2
 * We Breathe Media | Privacy Policy https://www.webreathemedia.com/
 * We Breathe Media | Client List https://www.webreathemedia.com/client-list
 * Click Labs Group | Privacy Policy https://www.clicklabsgroup.com/
 * Click Labs Group | Client List https://www.clicklabsgroup.com/client-list
 * Monetise Media Ltd | Performance Marketing Network https://monetise.co.uk/
 * Monetise Media Ltd | Privacy Policy
   https://www.monetise.co.uk/privacy-policy/
 * Monetise Media Ltd | Client List https://www.monetise.co.uk/client-list/
 * Verisure Services (UK) Ltd | Privacy Notice
   https://www.verisure.co.uk/privacy-notice
 * Pharmacy2U Limited | Privacy Policy
   https://www.pharmacy2u.co.uk/about/privacy-policy


8. RIGHTS OF INTERESTED PARTIES

Users may exercise the rights guaranteed to them by the Applicable Regulations
by contacting the Controller in the following ways:
‍

 * By sending a registered letter with return receipt to the registered office
   of the Holder (Demalia OÜ): Tornimäe tn 5, Tallinn, Harju maakond, 10145,
   Estonia;
 * By sending an e-mail message to: info@demalia.com;

Pursuant to the Applicable Legislation, the Data Controller informs that Users
have the right to obtain information on (i) the origin of personal data; (ii)
the purposes and methods of processing; (iii) the logic applied in case of
processing carried out with the aid of electronic instruments; (iv) the
identification details of the data controller and data processors; (v) the
subjects or categories of subjects to whom the personal data may be communicated
or who may become aware of them in their capacity as data processors or persons
in charge of processing.

In addition, Users have the right to obtain:
‍

 * access, update, rectify or, when they have an interest, supplement the data;
 * the cancellation, transformation into anonymous form or limitation of data
   processed in violation of the law, including data whose retention is not
   necessary in relation to the purposes for which the data were collected or
   subsequently processed;
 * certification that the operations referred to in letters a) and b) have been
   brought to the attention, also as regards their content, of those to whom the
   data have been communicated or disseminated, except where this proves
   impossible or involves the use of means manifestly disproportionate to the
   protected right.

 * in whole or in part, for legitimate reasons to the processing of personal
   data concerning them, even if relevant to the purpose of collection;
 * in whole or in part, to the processing of personal data concerning them for
   the purpose of sending advertising or direct sales material or for carrying
   out market research or commercial communication;
 * where personal data are processed for direct marketing purposes, at any time
   to the processing of their data carried out for that purpose, including
   profiling insofar as it is related to such direct marketing.

d.  should they believe that processing concerning them violates the Regulation,
the right to lodge a complaint with a Supervisory      Authority (in the Member
State in which they normally reside, in the Member State in which they work, or
in the Member State      in which the alleged violation occurred). The Italian
Supervisory Authority is the Garante per la protezione dei dati personali,
     based at Piazza di Monte Citorio n. 121, 00186 - Rome
(http://www.garanteprivacy.it/).
‍

The Owner is not responsible for updating all links viewable in this Policy, so
whenever a link is not working and/or updated, Users acknowledge and agree that
they should always refer to the document and/or section of the websites referred
to by that link.



Demalia OÜ is not responsible for updating all links displayed in this Cookies
Policy, so whenever a link is not working and/or updated, Users acknowledge and
agree that they should always refer to the document and/or section of the
websites referred to by that link.