12. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from Us

You will receive marketing communications from Us if you have requested information from Us or services from Us and you have not opted out of receiving such marketing.

Third-party marketing

We will get your express opt-in consent before We share your personal data with any third party for marketing purposes.

Opting out

You can ask Us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting Us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to Us as a result of a product/service purchase, warranty registration, product/service experience or other transaction.

13. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies We use, please see Our Cookie Policy as per www.gsxgroup.global. 

14. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which We collect it, unless We reasonably consider that We need to use it for another purpose and that purpose is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us.

If We need to use your personal data for an unrelated purpose, We will notify you and We will explain the legal basis which allows Us to do so.

Please note that We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

15. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal information within the GSX Group in order to provide you with Our services.  Access to your personal information is limited to those employees, agents and contractors of the GSX Group who need access to it in order to provide you with Our services and to carry out legal or regulatory obligations.

We may also employ the services of third party service providers to help Us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive your information, We will remain responsible for the use of your personal information. We take appropriate steps to ensure that such third parties treat your personal information with the same consideration that We do.

We may from time to time be required to disclose your personal information to law enforcement bodies, regulators, agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.

We may have to share your personal data with third parties to whom We may choose to sell, transfer or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to Our business, then the new owners may use your personal data in the same way as set out in this website Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow Our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with Our instructions.

16. CROSS-BORDER TRANSFERS OF YOUR PERSONAL INFORMATION

We share your personal data within the GSX Group of companies. Some of Our external third parties are based outside the EEA and the UK and their processing of your personal data will involve a transfer of data outside these areas. The EEA has granted the UK an equivalence standing in regards to data protection standards, but if any of Our external third parties are outside of the UK or EEA, they may be deemed as not offering an equivalent level of data protection for your personal information. As such whenever We transfer your personal data out of the EEA or the UK, We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is applied in accordance with applicable law (including Articles 44 to 50 of the EU General Data Protection Regulation).

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where We use certain service providers, We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where We use providers based in the Us, We may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

By providing Us with your personal information, you expressly consent to Our transferring your personal information to countries or jurisdictions which may not provide the same level of data protection as your home country, including without limitation countries or jurisdictions outside the EEA.

Please contact Us if you want further information on the specific mechanism used by Us when transferring your personal data out of the EEA.

17. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where We are legally required to do so.

18. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as is reasonably necessary in order that We may fulfil the purposes We collected it for and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with you.

To determine the appropriate retention period for personal data, We consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We apply a general rule of keeping your personal information for as long as is required in order that We may fulfil the purposes for which it was collected.  However, in some circumstances, We may retain personal information for longer periods of time (for instance, where We are required to do so in accordance with legal, tax or accounting obligations).

In specific circumstances, We may also retain your personal information for longer periods of time so that We have an accurate record of your dealings with Us in the event of any complaints or challenges.

We maintain a retention procedure which We apply to records in Our care.  In all cases, where your information is no longer required We will ensure it is disposed of in a secure manner and, where required by applicable law, We will notify you when such information has been disposed of.

In some circumstances, you can ask Us to delete your data.

In some circumstances, We will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

19. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, as follows:

Data subject access request. This will enable you to receive a copy of the personal data We hold about you and to check that We are lawfully processing it.

Request correction of the personal data that We hold about you. This will enable you to have any incomplete or inaccurate data We hold about you corrected, though We may need to verify the accuracy of the new data you provide to Us.

Request deletion of your personal data. This will enable you to request Us to delete or remove personal data where there is no good reason for Us continuing to process it. You also have the right to request Us to delete or remove your personal data where you have successfully exercised your right to object to processing. This may occur in instances where We may have processed your information unlawfully or where We are required to erase your personal data to comply with local law. Note, however, that We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where We are processing your personal data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to request Us to suspend the processing of your personal data in the following scenarios:

• If you want Us to establish the data’s accuracy.
• Where Our use of the data is unlawful but you do not want Us to erase it.
• Where you need Us to hold the data even if We no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to Our use of your data but We need to verify whether We have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or to a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Us to use or where We used the information to perform a contract with you.

Withdraw consent at any time where We are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, We could refuse to comply with your request in these circumstances.

What We may need from you

We may need to request specific information from you to help Us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up Our response.

These rights are not absolute and they do not always apply in all cases.

20. GLOSSARY

Lawful basis

Legitimate Interest means the interest of Our business in conducting and managing Our business to enable Us to give you the best service/product and the best and most secure experience. We make sure We consider and balance any potential impact on you (both positive and negative) and your rights before We process your personal data for Our legitimate interests. We do not use your personal data for activities where Our interests are overridden by the impact on you (unless We have your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess Our legitimate interests against any potential impact on you in respect of specific activities by contacting Us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that We are subject to.