This Policy applies as between you, the User of this Web Site and CookieHub ehf the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and our Services. This Policy was last updated on the April 1st 2021.
This Data Protection Policy applies to the services of CookieHub ehf. If you live in or outside the European Economic Area, Regulation (EU) 2016/679 (General Data Protection Regulation) is the applicable regulation and in Iceland, it is Act no. 90/2018 on Data Protection and the Processing of Personal Data.
CookieHub ehf with Company Number 6801211090 of Hafnargata 18, 230 Reykjanesbæ, Iceland is the Controller of your personal data.
The Supervisory Authority
The Data Protection Commissioner (DPC) in Iceland is the for us relevant authority in matters of data protection. You have the right to make a complaint at any time to the DPC (www. personuvernd.is). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.
What is personal data?
Personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”).
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Our website is not intended for children and we do not knowingly collect data relating to children.
What data do we collect?
We may collect data or ask you to provide certain data when you use our website and services. The sources from which we collect Personal Data are:
Data collected directly from you or your device relating to an identified or identifiable natural person (“Data Subject”) and may include direct identifiers such as name and email address. Optional are business name, tax no, registration no, business address. For premium services we also ask for payment details.
Data collected online or through indirect identifiers such as login account number, login password, payment details, or IP address.
Data collected that is linked, for example if you have used our service and later choose us again, we will link your data and treat that linked data as Personal Data.
We organise collected Personal Data as Account Data and Billing Data.
Account Data is everything we need to set up your account and includes your email address and username, and information connected with our services, such as your First and Last Name, your address and phone number.
Billing data is everything we need to set up your payment including your name, email address, masked credit card number and in certain circumstances, your billing address and your phone number if this is not already collected.
As described above, we link data and if we have already collected some of your data, we will only ask you for the remaining data that is necessary to carry out the service contracted for.
On what grounds do we use Personal Data?
We use your Personal Data for the following purposes and on the following grounds:
- On the basis of fulfilling our contract (when you use our services)
- On the basis of your consent (when you contact us)
- On the basis of legal obligations (for obligations such as tax, accounting, anti-money laundering, or when a court or other authority asks us to)
- On the basis of our legitimate interest (for communications about security, privacy and performance improvements of our services. Or for establishing, exercising or defending our legal rights.) Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
When do we disclose your Personal Data?
We disclose your Personal Data in response to your business enquiry or your request for information within our Company in order to provide the best service possible and within our legitimate interest.
We may share your information with organisations that help us provide the services described in this Data Protection Policy and who may process such data on our behalf and in accordance with this Data Protection Policy, to support this website and our services. For example, with our legal other professional advisors.
We may also share information with our secure payment gateway provider Borgun, and you may need to provide credit card information directly to the provider in order to process payment details and authorise payment following a secure link. The information which you supply to in such cases is not within our control and is subject to the payment gateway provider’s own Privacy Notice and Terms and Conditions. Click the following to read Borgun`s Privacy Notice and Terms and Conditions.
In relation to information obtained about you from your use of our website, we may share a cookie identifier and IP data with analytic and advertising network services providers to assist us in the improvement and optimisation of our website which is subject to our Cookies Policy.
We may disclose personal information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the website and its users.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for seven years after they cease being customers, for tax purposes.
You can learn how long your information is held and when it is destroyed from our Data Retention Policy which you can request using firstname.lastname@example.org
You have the right to:
- information about the processing of your personal data
- obtain access to the personal data held about you
- ask for incorrect, inaccurate or incomplete personal data to be corrected
- request that personal data be erased when it’s no longer needed or if processing it is unlawful
- object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation
- request the restriction of the processing of your personal data in specific cases
- receive your personal data in a machine-readable format and send it to another controller (‘data portability’)
- request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision
- Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time through email@example.com.
If you feel that your request is not satisfactorily resolved by us, you may approach your local data protection authority. The Data Protection Commissioner (DPC) is the supervisory authority in Iceland and relevant to CookieHub ehf.
How do we protect your Personal Data?
We protect your data using state of the art technical, and physical safeguards and operate a firm system of policies, confidentiality agreements, digital safeguards and procedures to ensure the highest level of administrative protection.
We use cutting edge antivirus and anti-malware software and up-to-date firewall protection. Moreover, authorised personnel must have a legitimate need to know interest such as being your point of contact or service your user account.
The data we collect from you may be stored, with appropriate technical and organisational security measures applied to it, on our servers in Netherlands. In all cases, we follow generally high data protection standards and advanced security measures to protect the personal data submitted to us, both during transmission and once we receive it.
To exercise any of your rights, or if you have any questions or complaints about our use of your Personal Data and this policy, please contact us using firstname.lastname@example.org.
We do not transfer your personal data outside the European Economic Area (EEA).
Automated decision-making and profiling
We do not use automation for decision-making and profiling
This Data Protection Policy and our commitment to protecting the privacy of your personal data can result in changes to this Data Protection Policy. Please regularly review this Data Protection Policy to keep up to date with any changes.
Queries and Complaints
Any comments or queries on this policy should be directed to us using the following contact details.
Hafnargata 51-55, 230 Reykjanesbæ, Iceland
If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us. You can also make a referral to, or lodge a complaint with, the Data Protection Commissioner.