PRIVACY POLICY:

ADDITIONAL INFORMATION FOR EEA+ CONSUMERS

Effective date: 5/26/2023

ADDITIONAL INFORMATION FOR EEA+ CONSUMERS

This Supplemental EEA+ Privacy Notice applies if you are located in, or resident of, the European Economic Area, the United Kingdom, or Switzerland. 

DATA CONTROLLER AND DATA PROCESSOR

For purposes of the Services, you are the data controller, and we are the data processor.

CATEGORIES OF PERSONAL DATA, PURPOSES OF PROCESSING AND SOURCE

See “Information we collect” and “how we use the information we collect” for categories of personal data that we collect, for the purposes we may process your personal data and, if applicable, the source from which the personal data originated.

SPECIAL CATEGORIES OF DATA

Special categories of personal data include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, data concerning an individual’s sex life or sexual orientation, genetic data, and biometric data processed for the purpose of identifying an individual. We do not collect any special categories of data.

LAWFUL BASES FOR PROCESSING

We rely on the following legal bases to process personal data of yours that does not fall within special categories, as appropriate:

  • According to your consent per Article 6(1)(a) GDPR (“Consent Legal Basis”)

  • Necessary for us to perform a contract with you or to take steps at your request prior to entering into a contract per Article 6(1)(b) GDPR (“Contract Performance Legal Basis”)

  • Necessary for us to comply with an applicable legal obligation per Article 6(1)(c) GDPR (“Legal Obligations Legal Basis”)

  • Necessary in order to protect the vital interests of the data subject or another natural person per Article 6(1)(d) GDPR (“Vital Interests Legal Basis”), or

  • Necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests per Article 6(1)(f) GDPR (“Legitimate Interest Legal Basis”), where the legitimate interests could be in particular:

    • open, maintain, administer, and manage profiles and accounts for registered users;

    • ensuring internal quality control and safety;

    • improving our Services;

    • managing and conducting our relationships with third parties in a business or professional capacity;

    • managing and administering our business; 

    • debugging to identify and repair errors with the Services; 

    • enforcing our agreements and policies; 

    • detecting security incidents; 

    • protecting against malicious, deceptive, fraudulent or illegal activity; and 

    • prosecuting those responsible for that activity; ensuring internal quality control and safety; protecting your safety or vital interests, or the safety or vital interests of others. 

We rely on the following legal bases to process personal data which falls within special categories:

  • Pursuant to your explicit consent 

  • Necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent

If we rely on your consent, you can withdraw your consent at any time with future effect by contacting us at the contact details listed below. For additional details regarding the lawful bases of processing your personal data specifically, please contact support@thronelabs.co.

CATEGORIES OF RECIPIENTS

See “how we share the information we collect” for information on the categories of recipients that we may share your personal data with.

INTERNATIONAL DATA TRANSFERS

By using the Services, personal data will be stored within the United States, where privacy rules differ and may be less stringent than those of the country in which you reside. We may transfer personal data to recipients located in countries for which the European Commission has not issued an adequacy decision in respect of the level of data protection.

We take measures to ensure that recipients in other jurisdictions provide an adequate level of data protection, for example, including by implementing EU standard contractual clauses and equivalent measures. You can receive more information on the measures we take by contacting us at the contact details listed below.

YOUR CHOICES

There is no law or contract between you and us stating that individuals in the EEA, UK, or Switzerland have to use our Services. We may ask you to provide your phone number and location information to verify your eligibility to receive certain Services from us.  In some cases, we cannot provide the Services to you unless you provide such information. You do not have to consent to our use of personal data for advertising purposes. If you do not allow us to collect the data we automatically collect from users of our Services, particularly via the App, some of our Services may not work properly or be as tailored to you as they could otherwise be, but they will still generally be usable via the Texting Service or Tap Card. 

To the extent that you have given consent, you can withdraw your consent at any time with future effect by contacting us as described below. Such a withdrawal will not affect the lawfulness of the processing prior to the withdrawal of consent.

YOUR RIGHTS

In the EEA, Switzerland and the UK you have the following rights relating to your personal data, subject to the conditions under the GDPR and/or applicable local data protection law: 

  1. Right to request access to personal data: You have the right to obtain from us confirmation as to whether your personal data is being processed, and, where that is the case, to request access to that personal data and details about how we process your personal data, including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients, the existence of automated decision-making, including profiling and you have the right to obtain copies of the personal data. However, this is not an absolute right and the interests of other individuals may restrict your right of access.

  2. Right to rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  3. Right to erasure (right to be forgotten): You have the right to ask us to erase your personal data.  

  4. Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time, to the processing of your personal data, including profiling, by us. This includes the right to object to our processing of your personal data where we are pursuing our legitimate interests or those of a third party. If we process your personal data based on our legitimate interests or those of a third party, you can object to this processing, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. 

    Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.

  5. Right to restriction of processing: In limited circumstances, you have the right to request restriction of processing of your personal data, in which case, it would be marked and processed by us only for certain purposes. 

  6. Right to data portability: You have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit the personal data to another entity without hindrance from us. 

  7. You also have the right to lodge a complaint with a supervisory authority (only for EEA and UK).

  8. In some jurisdictions such as France, if applicable pursuant to local law, you also have the right to provide us with guidelines as to the processing of your personal data after your death. 

You can exercise your rights by contacting us at support@thronelabs.co.

You may view a list of supervisory authorities in the EEA, UK and Switzerland and their respective contact information here (however, you have the right to lodge a complaint in the Member State of your habitual residence, place of work or an alleged infringement of the GDPR): 

Jurisdiction Data protection authority’s website

EEA https://edpb.europa.eu/about-edpb/board/members_en

United Kingdom https://ico.org.uk/global/contact-us/

Switzerland https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html 

CONTACT US

If you have any questions, comments, or concerns about our processing activities, please email us at support@thronelabs.co or write to us at 3415 Windom Rd. Brentwood, MD 20722.