- Categories of Personal Data Processed and Purpose of Processing
- In the context of the business relationship with CardoNews, CardoNews processes personal data for the following purposes:
- Communicating with Partners about CardoNews’s products and services;
- Responding to the inquiries or requests of our Partners;
- Performing and managing the (contractual) relationship with Partners; e.g. by performing transactions, providing the products or services, processing payments, performing accounting, auditing, billing and collection activities and providing support services;
- Performing customer surveys, marketing campaigns and marketing analysis, obtaining customer feedback and performing other promotional activities or events;
- Maintaining and protecting the security of our products, services and websites, preventing and detecting security threats, fraud or other criminal or malicious activities;
- Ensuring compliance with CardoNews’s legal obligations (such as record keeping and tax obligations), CardoNews policies and industry standards, including performing Partner screening (to prevent white-collar or money laundering crimes); and
- Solving disputes, enforcing our contractual agreements and exercising or defending legal claims.
- For the purposes mentioned above, CardoNews processes the following categories of personal data:
- Contact information, such as full name, work address, work telephone number, work mobile phone number, work fax number and work email address;
- Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
- Further information necessarily processed in a contractual relationship with CardoNews or voluntarily provided by a Partner Contact including the contents of emails and other communications.
- It is important to note that you are under no obligation to provide CardoNews with any personal data, however, if you do not, the purposes described above cannot be performed by CardoNews.
- Legal Basis for the Processing of Personal Data
CardoNews relies on a number of legal basis to process the personal data of Partners and Partner contacts.
Firstly, the processing of personal data is necessary to perform the contractual relationship with Partners and CardoNews relies on this basis to process such personal data in accordance with Article 6(1)(b) of the GDPR.
Secondly, some of the purposes for processing noted above reflect CardoNews’s legitimate interest, including, for the purpose of preventing fraud and for direct marketing purposes in connection with our existing business relationship. For these purpose, CardoNews relies on Article 6(1)(f) of the GDPR.
Lastly, some of the purposes noted above are necessary for CardoNews to comply with its legal obligations under law (including for tax purposes), and CardoNews relies on Article 6(1)(c) of the GDPR to process personal data for such purposes.
- Details of Recipients and Transfers of Personal Data
- Details of Recipients
- CardoNews may transfer personal data to other CardoNews companies, but only if and to the extent such transfer is strictly required for the purposes mentioned above.
- If legally permitted to do so, CardoNews may transfer personal data to courts, law enforcement authorities, regulators or attorneys if necessary to comply with the law or for the establishment, exercise or defense of legal claims.
- CardoNews also uses service providers (data processors) such as cloud hosting, cloud services such as AWS, IBM Cloud, Microsoft Azure and dedicated hosting servers and back up servers to perform services in order for CardoNews to perform the purposes of processing mentioned above. These service providers are contractually bound to act upon the instructions of CardoNews and in accordance with applicable data protection laws.
- Transfers of Personal Data
Recipients of personal data may possibly be located in countries outside of the European Economic Area
(the “Third Countries”), in which applicable laws do not offer the same level of data protection as the laws of the respective individual’s home country. In such cases and unless permitted otherwise by applicable law, CardoNews takes measures to implement appropriate and suitable safeguards for the protection of personal data by other means.
- We share personal data with CardoNews companies in Third Countries to the extent that they have signed on the CardoNews intra-group data transfer agreement which includes the EU Standard Contractual Clauses.
- We transfer personal data to external recipients in Third Countries only in case the respective recipient (i) has entered into EU Standard Contractual Clauses with CardoNews, (ii) is located in a country which is approved by the European Commission as ensuring an adequate level of protection, (iii) in case of US recipients – the recipient is certified under the Privacy, or (iv) the transfer falls within a permitted derogation under the GDPR.
If you wish to find out more information about these transfers, please contact us at the details below.
- Retention Periods
Unless explicitly indicated otherwise, at the time of the collection of Partner Contact’s personal data (e.g. within a consent form accepted by the Partner Contact), we erase personal data if the retention of the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed and no statutory retention obligations under applicable law (such as tax or commercial law) require us to further retain personal data.
- Right to Withdraw Consent
In case a Partner Contact declared its consent for the processing of certain personal data by CardoNews, the Partner Contact has the right to withdraw the consent at any time. In case consent is withdrawn, CardoNews will only process the personal data where there is another legal ground for the processing, for example and without limitation, the processing is necessary for CardoNews’s performance of a contract, compliance with CardoNews’s legal obligation or for CardoNews’s legitimate interests (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject).
- Your Rights
Under applicable data protection law an affected Partner Contact may – provided that the respective legal pre-conditions are met – have the right to obtain from CardoNews:
- confirmation as to whether or not personal data concerning the Partner Contact are being processed, and where that is the case, access the personal data;
- the rectification of inaccurate personal data;
- the erasure of Partner Contact’s personal data;
- the restriction of processing regarding the Partner Contact’s personal data; and
- a copy of personal data, which the Partner Contact provided, in a structured, commonly used and machine-readable format and to request from CardoNews that it transmits the data to another recipient selected by the Partner Contact.
In addition, the Partner Contract may object, on grounds relating to the Partner Contact’s particular situation, to processing of personal data to the extent that CardoNews’s processing is based on CardoNews’s legitimate interests (as explained above). CardoNews shall no longer process the personal data unless it has compelling demonstrable legitimate grounds for the processing which override the interests, rights and freedoms of the Partner Contract, or the processing is required for the establishment, exercise or defense of legal claims.
- Contact Details for Privacy Matters
However, please note that applicable EU data protection laws provide you with a right to lodge a complaint with the competent supervisory authority as well.
You can contact CardoNews at:
Email Address: email@example.com