PRIVACY STATEMENT
1. General
1.1 This Privacy statement, hereinafter - the “Statement”, regulates processing and protection of personal data received from you “you”, hereinafter – “you”, “your” or “user”, by Elephant Step Solution LLC, a company duly registered under the Laws of Costa Rica, hereinafter - “we” or “us” or “our”, or “the Company”.
1.2 The Statement aims to provide you with information about the purpose of personal data processing, the legal basis, the extent of the processing, protection and processing period at the time of the personal data acquisition.
1.3 The Statement has been developed according to Law No. 7975, the Undisclosed Information Law, Law No. 8968, Protection in the Handling of the Personal Data of Individuals and regional acts enacted to regulate personal data protection.
1.4 The Statement is available on www.jumboline.net, hereinafter – the “Website”.
1.5 The Company is entitled to unilaterally amend the Statement at any time.
1.6 If you want to send us your question, please contact us by email at: enquiries@jumboline.net.
2. Data protection principles
2.1 Information contained in personal data must be:
2.1.1 obtained and processed fairly and lawfully: personal data should be collected and handled in a fair and legal manner;
2.1.2 used only for specified and lawful purposes: data should be processed solely for clearly defined and lawful objectives;
2.1.3 not disclosed incompatibly: data should not be used or shared in ways that are inconsistent with the stated purposes;
2.1.4 adequate, relevant, and not excessive: data collected should be sufficient and directly relevant to its intended purposes, without being excessive;
2.1.5 accurate and up-to-date: data should be kept accurate, and updated as necessary;
2.1.6 not retained longer than necessary: personal data should be retained only as long as needed for the specified purposes.
3. Purposes and legal basis
3.1 The processing of personal data for the following purposes takes place on a contractual basis - for the performance of a transaction:
3.1.1 your identification;
3.1.2 the supply of products and provision of services;
3.1.3 handling and processing of the objections, complaints;
3.1.4 invoicing administration.
3.2 The processing of personal data for the following purposes takes place on a consent basis:
3.2.1 advertising of services or commercial purposes;
3.2.2 satisfaction measurements;
3.2.3 data on your use of the Website.
3.3 The processing of personal data for the following purposes takes place on the legitimate interests:
3.3.1 in order to protect your and/or the Company`s interest;
3.3.2 to provide evidence relating to performance of the transaction (submitted documents and other information);
3.3.3 prevent, limit and investigate dishonest or unlawful use of the services and products provided by the Company;
3.3.4 conduct commercial activity.
4. Categories of personal data
4.1 Personal data may be collected from you and with your consent – from third parties.
4.2 Personal data categories which the Company may collect and process are:
4.2.1 your name and surname, date of birth, data regarding the identification document;
4.2.2 contact data such as email address;
4.2.3 data on exchange transaction;
4.2.4 communication data collected when you contact us.
4.3 If the required personal data is not provided, the Company will not be able to ensure providing of the services/products to you accordingly.
5. Recipients of personal data
5.1 Personal data is shared with other recipients, such as:
5.1.1 state and local authorities according to the regulations;
5.1.2 accountants, auditors, legal and financial consultants, or any other processor authorized by the Company;
5.1.3 other persons related to provision of services of the Company (product suppliers, financial institutions).
6. Storage period
6.1 The storage period may be based on relationship between the Company and you, legitimate interest of the Company or applicable law, such as laws related to bookkeeping, statute of limitations, civil law, etc.
6.2 After the circumstances specified in clause above are terminated, your personal data will be deleted.
7. Your rights on personal data processing
7.1 You have the following rights regarding your personal data processing:
7.1.1 require personal data to be corrected if it is inadequate, incomplete or incorrect;
7.1.2 require the erasure of personal data;
7.1.3 restrict the processing of personal data;
7.1.4 receive information if personal data is being processed by the Company and if so then to access it;
7.1.5 receive personal data that is provided by yourself and is being processed based on consent or in order to perform an agreement in written or commonly used electronical format and were feasible transmit such data to another service provider (data portability);
7.1.6 withdraw consent to process your personal data;
7.1.7 submit a request for the exercise of your rights regarding the processing of personal data, including information on possible personal data protection breaches.
7.2 Upon receiving your request for the exercise of rights, the Company verifies the identity, evaluates the request and executes it.
7.3 The Company will respond you in writing or by other means, including, if necessary, in electronic form.