We are pleased that you are visiting www.sereno.lat (our “website”) and/app.sereno.lat (our “Platform”). Data protection and data security when using our website/Platform are very important to us. We would therefore like to inform you which of your personal data we collect when you visit our website and for what purposes it is used.
Background
This Privacy Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to make sure you understand the information provided. However, to achieve this objective we would like to explain to you the following concepts.
a) What is Personal Data?
Personal Data is any includes information relating to an individual who can be identified or who is identifiable, directly from the information in question; or who can be indirectly identified from that information in combination with other information.
b) What is Processing?
«Processing» means and covers virtually any handling of data.
What law applies
We will only use your Personal Data in accordance with the applicable data protection laws, in particular Delaware’s Privacy Data Protection Act (“DPDPA”) and the EU’s General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.
Who is responsible
The person responsible in the sense of the DPDPA and the GDPR is Sereno (“Sereno”, “we”, “us”, or “our”). Please direct any questions you may have to [email protected]
Data collection
All Personal Data that we obtain from you will only be processed for the purposes described in more detail below. In particular, we collect Personal Data only if:
Data retention
We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with Delaware’s Commercial Law and Fiscal Code and others for up to 6 years). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
Data we collect automatically
a) Provision and use of the website
When you visit our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your device as well as the name of your access provider. The legal basis is our legitimate interest.
b) Hosting
The hosting services used by us for the purpose of operating our website is Cloudflare Inc. In doing so Cloudflare processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests.
c) Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the DPDPA and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
d) Cookie consent
Our website uses a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
e) Economic analyses and market research
For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use Google Analytics. The legal basis is our legitimate interest and your consent. For further information, please refer to our Cookie Policy.
Data we collect directly
a) Contacting Us
We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. We also offer to contact us via the messaging services of WhatsApp. If you contact us via WhatsApp we store and use the mobile phone number, you use and – if provided – your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request. The legal basis is both your consent and contract.
b) Our Telegram Community
We process the Personal Data that arises when you use our community services. In particular, this requires you to join our server and community on Telegram. If you contact or connect with us via Telegram, we and Telegram are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a membership, if any
c) User account
To use our services, you can register and log in. Here, too, we store data in order to create an account for you: Your Full Name, E-mail address, chosen password. We store this data as long as you are registered with us. If you delete your account, we will delete your data unless there is a legal retention period on our part. In this case, we must store your data for longer. The legal bases for processing are contract and our legitimate interest.
d) Using our services
We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. This includes:
The data processed includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contractual data (e.g., services used, contents of the contract, contractual communication etc.). Accordingly, the data is processed on the basis of fulfilling our contractual obligations, legitimate interest, your consent,and our legal obligations.
e) Administration
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
f) Promotional use of your data
We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions, services and offers. In addition, we may draw your attention to comparable offers and services by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.
Data sharing
In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.
a) Internal
If necessary, we transfer your Personal Data within Sereno. Of course, we comply with the DPDPA and GDPR and ensure that your data is processed properly. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.
b) External bodies
Personal Data is transferred to our service providers in the following instances:
c) International transfers
We may transfer your Personal Data to our overseas remote employees and/or other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
Data security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Social Media
a) General
We are present on social media on the basis of our legitimate interest (currently, Facebook, Instagram, and X (formerly Twitter)). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
b) Market research and advertising
In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. You can find more information about our advertising on social media in our Cookie Policy. The legal basis is our legitimate interest.
c) When you visit our profiles and interact with us and others
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
Marketing
Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
Advertising
We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website – for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.
We also analyze this data to evaluate the relevance of the advertisements and to optimize the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following Personal Data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website (e.g., orders placed, products clicked on). The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.
Your rights and privileges
a) Privacy rights
Under the DPA and the GDPR, you can exercise the following rights:
b) Updating your information, withdrawing your consent, objection to legitimate interest processing
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.
c) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
d) COPPA (Children Online Privacy Protection Act)
When it comes to the collection of Personal Information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.
e) CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CAN SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.
f) Telephone Consumer Protection Act (TCPA)
If we process your Personal Information for the purpose of sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’ if you receive our SMS communications. In this respect, the data processing is carried out solely on the basis of our consent in personalized direct advertising per SMS.
g) Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy.
h) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Delaware is: Attorney General of Delaware (https://attorneygeneral.delaware.gov/). We would, however, appreciate the chance to deal with your concerns before you approach the AG or any other supervisory authority.
i) What we do not do
Changes
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will revise the effective date.
Effective Date
Friday, 12th of April, 2024
Questions
If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.
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