Privacy Statement
(Version July 2024)

Through the website, Zalkian will receive, collect and process personal information of our users (“You”). But also, when You subscribe to our newsletter, phone us, send us a letter or communicate with us using email or social media, We receive and process your personal information.

This privacy statement (“Statement”) explains which personal information We collect, for which purpose We do this and what We will do with the collected information, what your rights are and how You can contact us.

This Statement applies to all personal information We process about You whether You visit our Website, subscribe to our newsletter or otherwise interact with us.

This Statement does not apply to third-party websites connected to our Website through links. If You follow these links or interact with third party services, You will exit our Website. We do not accept any liability for the use and/or any damages resulting thereof of your personal information by these third-party websites and companies. Your use of these third-party websites is at your own risk. For more information on how these third-parties treat your personal information, please check their privacy policies on their respective websites.

This Statement is effective as of 2024. We will keep our Statement under review and may revise it from time to time. We will notify You of any changes by posting the revised Statement on our Website. However, We recommend that You review our Statement regularly, so that You keep up to date of any changes. By continuing to visit our Website, subscribe to our newsletter or otherwise interact with us after those changes become effective, You agree to be bound by our revised Statement.

If you are 13 years old or younger, please ask your parent/guardian’s permissioned beforehand and ask them to help you whenever you provide us with any personal information. We reserve the right to get in touch and verify your parent’s consent.

Please read this Statement carefully and if You have any question about this Statement contact us by email.

Which personal information do We process?

We collect and process personal information you have provided us with.

General data:

• Your first and last name, gender and date of birth, city of residence.
• Your contact details: your telephone number and email address.
• Your location data
• We will register your communication with us when You send us an email or letter, chat with us online or via social media or call us. For training purposes or to prevent or combat fraud, We may also record telephone calls.
• Your use of our Website and/or other digital media: We will register your IP address, browser type, operating system, referring website and web-browsing behaviour when You visit our Website. When You open our newsletter, or click on a link in such newsletter, We will receive an automatic notification of this action.
• Shared information: We will register information You choose to share with us, for example by leaving a comment for us on Facebook or submit an entry for a contest.

Sensitive data:

We do not collect and/or use personal information that can be considered as ‘sensitive personal data’ under the GDPR directive, such as information about race, religion or health.

Cookies and similar technologies:

By visiting our Website We collect information via cookies and similar technologies. For more information please read our cookie statement.

Specific services or events:

We may collect other types of information and use such information for different purposes than described in this Statement for specific services or events. We will inform You about this when You register for a service or an event.

Automated decision-making and profiling

Not applicable

Why are We collecting your personal information?

Your personal information will be used for the purposes specified in this Statement. We may use your personal information to:

• administer our Website;
• improve your browsing experience by personalizing our Website;
• enable your use of the services available on our Website;
• send to You downloads requested via our Website;
• send to You general (non-marketing) commercial communications;
• send to You email notifications which You have specifically requested;
• send to You our newsletter and other marketing communications (relating to activities We organize or otherwise engage in which We think may be of interest to You) by email or similar technology;
• provide third-parties with statistical information about You for research – but this information will not be used to identify any individual user. Statistical research helps us to develop better services and to improve the design and content of our Website; and
• deal with enquiries and complaints made by You.

What is the lawful basis for processing your personal information?

We collect and process your personal information

• You have given us your consent to process your personal information. Please note that you can withdraw your consent at any time by sending a written notice.
• in order to enter into or perform a contract with you and in connection with pre-contractual relations with you;
• following our obligation to comply with a legal obligation to which we are subjected;
• on the basis that such processing is necessary for the performance of tasks carried out by a public authority or private organization acting in the public interest;
• On the processed on the basis that we have a legitimate interest in processing those data,

What will We do with your personal information?

Retention

Your personal information will be retained for as long as necessary for the purposes described in this Statement or in so far as such is necessary for compliance with statutory obligations and for solving any disputes. We do not keep your personal information for any longer than is necessary for the purpose for which they were submitted. This means that:

1. As long as you have an account on the Website, your personal information will be collected, stored and processed in order to perform the agreement with you.
2. Once you have terminated your account, we are allowed to retain your personal information on the basis of legitimate interest and for as long as required to fulfil such purposes;
3. We may retain your personal information for a longer period, if there are any operational needs to do so;
4. If you have given your consent to a longer retention period. Please note that you can withdraw such consent at any time.

Upon expiration of the retention period, your personal information will be deleted.

Disclosure to third-parties

For certain purposes we will disclose or share your personal information with third-parties:

• Klibansky service providers: we use other (third party) companies, agents, contractors to perform services on our behalf or to assist us to deliver the services to You. In relation to providing such services those parties may have access to Your Personal Information.
• Protection of Klibansky: unless it is necessary for provision of the requested service or if this is required by law or if you have given your explicit consent. In the event of suspicion of fraud or misuse of our Website We may hand over personal information to the competent authorities.

Place and international transfer of your personal information

All your personal information is processed at cloud service providers that are based in The United States. Data transfers are necessary to provide the services to you described in this Privacy Policy. Depending on your location, this may result in transfer of your personal information to other countries within and/or outside the European Union. Countries outside the European Union may not have equivalent data protection laws. This may occur because our group companies, partners or the controller’s service providers have operations in countries across the world. We will ensure, where necessary, that adequate safeguards are in place to comply with the requirements for the international transfer of personal information under applicable privacy laws.

Security

We will take appropriate technical and organizational measures to protect your personal information against loss or unlawful use. Between others We take the following measures:

• We perform regular malware scans.
• We implement security measures when You enter, submit or access the information.
• Your personal information is encrypted by using TLS certificates from Let’s Encrypt and stored with an RSA key with 4096 bit encryption.

How can you exercise your rights?

You have the right of access, rectification, erasure, restriction of processing, data portability or to object data processing.

You are able to review, update, correct, complete and amend your personal information through your profile at the Website or by sending an email. You may object to the processing of your personal information, request the restriction of the processing of your personal data. You may request us to provide you with a portable data file, to erase all your personal information at any time. We will comply with your request within one (1) month.

At all times you can revoke your consent or opt-out for receiving marketing communications at any time by following the instructions in the relevant marketing communication or by sending an email.

Although, legally you have rights in relation to automated decision making and profiling, please note that we do not apply automated decision making and profiling.

If You:

• have any questions, remarks in relation to this Statement;
• have any questions, remarks or complaints about the processing of your data; or
• would like to update, amend or delete any personal information We have about You, You can contact us by email.