Your personal data may be stored and processed by us for the purposes listed below and in accordance with the lawful bases listed below.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful bases we are relying on to process your personal data where more than one ground has been set out below.

Purpose/activity

To provide the site and to ensure that content from the site is presented in an effective and user-friendly manner for you and for your device.

To investigate and address any comments, queries or complaints, or to fix any problems, notified to us by you or other users of the site.

To use cookies and other tracking technologies to monitor user behaviour on our site, and to use this behavioural data within our online advertising strategies.

In order to comply with and/or assess compliance with applicable laws, rules and regulations, and our internal policies and procedures, which includes processing personal data as reasonably required in order to establish, exercise or defend legal claims or for the purpose of legal proceedings.

For the administration and maintenance of databases storing personal data.

MARKETING

If you have given permission, we may contact you by email about our content, releases, products, services, promotions and special offers (or those of selected third parties) that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to use your data for such purposes. If you prefer not to receive any direct marketing communications from us, you are free to decline, or if you give permission and change your mind later, you can opt out at any time (see further below).

If you have bought goods, content and/or services from us, we may also contact you by email with marketing information about similar goods, content and/or services that we think might interest you, unless you have asked us not to (and we will notify you of this and give you the opportunity to opt out when we collect your personal data). Again, if you change your mind, you can opt out at any time (see further below).

HOW WE SAFEGUARD YOUR INFORMATION

We have extensive controls in place to maintain the security of our information and information systems. Files are protected with safeguards according to the sensitivity of the relevant information, including hashing or data encryption where appropriate. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal data are gathered, processed or stored is limited to authorised employees.

As a condition of employment, our employees are required to comply with all applicable laws and regulations, including in relation to data protection law. 

If you contact us about your information, you may be asked for some personal data for identification purposes. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your information.

INTERNET RISKS

Despite the safeguards set out in this Privacy Policy, unfortunately the transmission of information by online or mobile means is not completely secure. Pupus cannot guarantee the security of information transmitted to this site, and for that reason any transmission you make is at your own risk. We recommend that you use anti-virus, firewall and/or other security protections according to your own analysis of your security requirements. Once we have received your personal data, we will use the procedures and security features set out in this Privacy Policy to try to prevent unauthorised access to, or loss or destruction of, your personal data.

HOW LONG WE KEEP YOUR PERSONAL DATA

How long we will hold your personal data for will vary and will be determined by the following criteria:

• the purpose for which we are using it (as further described in this Privacy Policy) – we will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulations may set a minimum period for which we have to keep your personal data.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR RIGHTS

Where we collect, use or store your personal data under this Privacy Policy, you may, depending on your circumstances, have the following rights:

• the right to obtain information regarding the processing of your personal data (including whether or not we are holding and/or processing your personal data, the extent of the personal data we are holding and the purposes and extent of the processing) and access to the personal data that we hold about you, if any;
• where we are relying on consent for a particular purpose, the right at any time to withdraw your consent to the processing of your personal data for such purpose;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible – which is sometimes known as the right to “data portability”, and please note that (a) this right only applies to personal data which you have provided directly to Pupus and which we are processing either on the basis of consent or because the processing is necessary in order for us to perform our contractual obligations to you and (b) if you request the right to data portability and it is not available to you, we will let you know;
• the right to request that we rectify your personal information if it is inaccurate or incomplete;
• the right to request that we erase your personal data in certain circumstances – please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it, in which case we will let you know;
• the right to object to, or request that we restrict, our processing of your personal data in certain circumstances – again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request and, if so, we will let you know;
• the right to object to decisions based solely on automated processing, including profiling, which produce legal effects or otherwise significantly affect you (for example, where a computer algorithm, rather than a person, makes decisions that affect your contractual or other rights) – please note that we do not currently carry out any such automated decision-making processes; 

COOKIES POLICY

Our website use cookies and other tracking and monitoring software to distinguish you from other users of our site and to collect technical information about the services that you use and how you use them. This information helps us to provide you with a good experience when you browse our sites, allows us to improve our sites and our services, and allows us to compile statistical reports on site visitors and site activity. Cookies do not affect your security, since a cookie cannot read data off your system or read cookie files created by other sites.

The information that we collect through our use of cookies, to the extent that you are individually identifiable from it, constitutes personal data, and we will protect it according to the standards and processes set out in this Privacy Policy.

Please note that we have implemented some third party services  parties (including, for example, advertising networks and providers of external services like web traffic analysis services) and such third parties may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You will have the option to reject non-essential cookies should you wish to, via an initial prompt when you first visit the page and you can revisit your choices at any time by clicking the cookies settings button in the left hand corner of the page, but please note that some of our site features may not function if you remove cookies from your system.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email.

Please check back frequently to see any updates or changes to our Privacy Policy.