Goldex Technologies Limited
Goldex Technologies Limited understands that your privacy is important to you and that you care about how your Personal Data is used and shared. We respect and value the privacy of everyone who visits our Goldex App (“Our App”) and our website www.goldexapp.com (“Our Website”) and (subject to the limited exceptions in section 6, below) We do not collect Personal Data about you unless you contact Us (see section 5, below). Any Personal Data We do collect will only be used as permitted by law.
1. Definitions and Interpretation
In this policy, the following terms shall have the following meanings:
“Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means Personal Data that you give to Us via Our App. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Goldex Technologies Limited, a private limited company registered in England under company number 09249940, whose registered address is 60 Gracechurch Street, London, EC3V 0HR.
2. Information About Us
2.1 Our App and Our Website is operated by / hosted at a major cloud service operator in Europe.
2.2 Our App and Our Website is maintained by Us.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this policy and Our use of Personal Data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the Personal Data We hold about you (see section 12);
4.1.3 The right to rectification if any Personal Data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any Personal Data We hold about you (We only hold your Personal Data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13) and we will consider whether we are legal entitled to do so;
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your Personal Data to re- use with another service or organisation);
4.1.7 The right to object to Us using your Personal Data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Depending upon your use of Our App and Our Website, We may collect some or all of the following personal and non-personal data:
5.2 date of birth;
5.4 contact information such as email addresses and telephone numbers;
5.5 demographic information such as full address, preferences, and interests;
5.6 identification information;
5.7 IP address;
5.8 web browser type and version;
5.9 operating system; and
5.10 a list of URLs starting with a referring site, your activity on Our App, and the site you exit to.
6. How Do We Use Your Data?
6.1 All Personal Data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your Personal Data will always have a lawful basis, for example because it is necessary for Our performance of a contract with you, because you have consented to Our use of your Personal Data, or because it is necessary in Our legitimate interests (or those of a third party) and Your interests and fundamental rights do not override those interests. Generally we do not rely on consent as a legal basis for processing Your Personal Data other than where we are required to do so in order to send direct marketing communications via email or text message.
6.3 Specifically, We may use your data for the following purposes (and on the following lawful bases):
6.3.1 Supplying commodities or services to you (please note that We require your Personal Data in order to enter into a contract with you) (Performing (or preparing to enter into) a contract);
6.3.2 Personalising and tailoring Our services for you (Our and Your legitimate interests);
6.3.3 Replying to messages or emails from you (Our and Your legitimate interests);
6.3.4 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the Unsubscribe link at the bottom of the email) (Consent); and
6.3.5 Market research (Our legitimate interests).
6.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on services. We will ensure that We fully protect your rights and comply with Our obligations under the GDPR (and national legislation which may replace it) and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.5 Where we use your Personal Data on the basis of your consent, You have the right to withdraw your consent to Us using your Personal Data at any time, and to request that We delete it.
6.6 We do not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Once our relationship with you has come to an end (, we will only retain your Personal Data for a period of time that is calculated depending on the type of Personal Data, and the purposes for which we hold that information.
6.7 We will only retain information that enables us to:
6.7.1 maintain business records for analysis and/or audit purposes;
6.7.2 comply with record retention requirements under the law;
6.7.3 defend or bring any existing or potential legal claims;
6.7.4 maintain records of anyone who does not want to receive marketing from Us;
6.7.5 deal with any future complaints regarding the commodities or services We have delivered or facilitated;
6.7.6 assist with fraud monitoring; or
6.7.7 assess the effectiveness of marketing that We may have sent You.
6.8 We take steps to ensure information is only held for the correct period. We then delete or de-identify your data. The retention period is generally linked to the amount of time available to bring a legal claim, which in many cases is six or seven years following the end of our relationship with You. We will retain your Personal Data after this time if We are required to do so to comply with the law, if there are outstanding claims or complaints that will reasonably require your Personal Data to be retained, or for regulatory or technical reasons. If We do, We will continue to make sure Your privacy is protected.
7. How and Where Do We Store Your Data?
7.1 We only keep your Personal Data for as long as necessary to meet legal, regulatory and business requirements.
7.2 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our App and Our Website.
7.3 Steps We take to secure and protect your data include:
8. Do We Share Your Data?
8.1 We may sometimes contract with third parties to supply commodities and services to you on Our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.2 We may sometimes contract with third parties that undertake research and data analytics for us in order to improve our general sector marketing and advertising. Where any of your data is used for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. Your data will neither be used for direct making, nor sold to third parties.
8.3 We may compile statistics about the use of Our App including, usage patterns, user numbers, sales and purchases, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors and advertisers. Data will only be shared and used within the bounds of the law.
8.4 We will only store Your data within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). We may however sometimes use third-party data processors that are located outside of the EEA. Where we transfer personal data outside the EEA we take all reasonable steps to ensure that your data will be treated as safely and securely as it would be within the UK and under data protection laws. We will always take steps to ensure that any international transfer of information is managed carefully and in accordance with data protection laws to protect your rights and interests. These measures include:
8.4.1 transfers of your Personal Data to countries which are recognised as providing an adequate level of legal protection for personal data;
8.4.2 We have obtained the consent of data subjects to the international transfer of their personal data;
8.4.3 transfers to organisations where We are satisfied about their data privacy and security standards and protected by contractual commitments such as signing the EU Standard Contractual Clauses and, where available, further assurances such as certification schemes; and
8.4.4 if transferred to the United States of America, the transfer will be to organisations that are part of the Privacy Shield.
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will, however, be given a choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit Personal Data via Our App, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
11. Your Right to Withhold Information
11.1 You may access certain areas of Our App and Our Website without providing any data at all. However, to use all features and functions available on Our App and Our Website you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
12.1 You have the right to ask for a copy of any of your Personal Data held by Us (where such data is held). Under the GDPR, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com, or using the contact details below in section 13.
13. Contacting Us
2. A cookie is a small file of letters and numbers that We store on Your browser or the hard drive of Your computer and mobile phone if you agree. Cookies contain information that is transferred to your electronic device’s hard drive.
3. We use the following cookies:
3.1 Strictly necessary cookies. These are cookies that are required for the operation of Our App and Our Website. They include, for example, cookies that enable you to log into secure areas of both Our App and Our Website, or complete an application.
3.2 Analytical/performance cookies. They allow us to recognise and count the number of users or visitors and to see how users or visitors move around Our App and Our Website when they are using it. This helps Us to improve the way Our App and Our Website work, for example, by ensuring that users are finding what they are looking for easily.
3.3 Functionality cookies. These are used to recognise you when you return to Our App and Our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
3.4 Targeting cookies. These cookies record your visit to Our App and Our Website, the pages you have visited and the links you have followed. We will use this in order to make the information displayed on our website and app more relevant to your interests. We may also share this information with third parties for this purpose.
5. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of Our App and Our Website.
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