Privacy Policy

Last updated: June 1st, 2021

The website www.kapadalay.com (hereinafter the “Website”), published by the company Kapadalay (hereinafter “Kapadalay” or “us”), is Kapadalay’s corporate website presenting in particular its solutions and services.

While you are accessing, browsing, navigating and using the Website and the services it provides, you communicate personal data related to you to Kapadalay.

These personal data are protected by law, and thus, Kapadalay, as data controller, has implemented appropriate security measures in order to protect your personal data.

Please read this privacy policy carefully as it explains how Kapadalay uses your personal data. This privacy policy supplements any documents or notices that may refer to this privacy policy.

Should you have any questions, you may directly contact Kapadalay by sending an email to info@kapadalay.com.

1. What kind of personal data are processed by Kapadalay?

All personal data provided by you through the Website or when you communicate with us are processed by Kapadalay, namely:

Also, the Website automatically collects the following data via cookies:

The provision of certain types of personal data may be necessary or optional, depending of the services you wish to receive. Mandatory data will be marked as such at the moment of collection of your personal data. If you refuse to provide mandatory data, Kapadalay may not be able to process your request (such as your request to participate in a Kapadalay’s event, your request to download a Website’s Resource, your subscription request to receive the latest marketplace news published on Kapadalay blog). 

2. For what purposes does Kapadalay use your personal data?

Kapadalay processes your personal data for the following purposes only:

3. Who can access your personal data?

Your personal data may be transmitted to the following recipients when you access, browse, navigate and use the Website and the services it provides: 

4. Will your personal data be transferred outside of the European Economic Area?

As far as possible, your personal data are processed within the European Economic Area (EEA). However, some of the companies of the Kapadalay Group, as well as our services providers being located outside of the EEA, your personal information may therefore be processed in those countries. Furthermore, Kapadalay may organise events with partners outside the EEA. In this case, you will be informed that your personal data will be transferred to the third country where the partner is established upon your registration.

When your personal data are transferred outside the EEA, Kapadalay will, in the absence of an adequacy decision and after having carried out an assessment of the level of protection of your rights on the territory of the third country where the recipient of your personal data is established, implement all necessary measures through the adoption of appropriate safeguards (such as standard contractual clauses). A copy of such safeguards can be obtained by sending an email directly to Kapadalay at info@kapadalay.com.

5. How does Kapadalay protect your personal data?

Kapadalay has implemented technical and organizational measures in order to protect your personal data, in particular against potential data breaches likely to cause, either by accident or unlawfully, the destruction, loss, modification, unauthorized access or divulgation of your personal data. These measures will guarantee a level of security adapted to the data and will take into account the state of the art and the cost of implementation in relation to the risks and nature of the data to be protected. 

Kapadalay uses SSL certificates to encrypt the Website and only a limited number of staff have access to the data.

Kapadalay guarantees that all members of its personnel and any other person processing your personal data will respect the internal rules and procedures related to the processing of personal data, including the technical and organizational security measures put in place to protect your personal data. In this context, Kapadalay reviews and updates its practices regularly to enhance your privacy and ensure that its internal policies are followed.

If you have found a vulnerability or would like to report a security incident, you may send an email to info@kapadalay.com.

6. For how long are personal data stored?

As a general rule, your personal data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected, or as necessary to fulfill legal or regulatory obligations.

In the absence of applicable exceptions: 

• the data collected via the collection forms on the Website(contact request/information request, access request for the Website’s resources, etc.) will be kept until the complete processing of your request;
• the data collected for your subscription in a Kapadalay’s eventwill be kept until the end of the event; 
• the data collected for your subscription to the marketing communications or the latest marketplace news published on Kapadalay blogwill be kept until your unsubscription ; 
• the data collected viathe recruitment form will be kept for a period of two (2) years after our last contact with you, except in the event of request for deletion of your file;
• your traffic datawill be kept for a period of thirteen (13) months from the connection date.

In addition to this, Kapadalay will keep your personal data for:

• three (3) yearsfor data processed for marketing purposes;
• five (5) yearsfor evidence purposes relating to legal claims; 
• ten (10) yearsfrom the end of the relevant fiscal year for personal data retained for accounting purposes as well as for commercial documents.

7. What are your rights regarding your personal data?

If you are based in the EU, EEA, or UK, you have the following rights over your personal data:

• you can request the accessto your personal data in order to obtain clear, transparent and understandable information on how Kapadalay processes your personal data and on your rights (as provided in this policy), as well as a copy of your personal data. 
• you can request the rectification of your personal data in order to obtain the modification of your personal data if theyare obsolete, inaccurate or incomplete ; 
• you can objectto the processing of your personal data when the processing is based on Kapadalay’s legitimate interest. Kapadalay will no longer process your personal data unless Kapadalay demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g. legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims.
• you can request the restriction of the processing during a limited period of time, in particular in order to carry out some verifications, where one of the following applies:
• you contest the accuracy of your personal data, the processing of which is thus restricted for the period necessary for Kapadalay to verify the accuracy of such personal data;
• the processing is unlawful and, rather than requesting their deletion, you prefer to restrict their use;
• Kapadalay no longer needs your personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims;
• you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of Kapadalay may override your interests, rights and freedoms.
• you can withdraw your consentwhen it has been obtained, without this withdrawal affecting the lawfulness of the processing operations previously carried out.
• you can ask to receive your personal data in a structured, commonly used and machine-readable format and also can request their transmission to another controllerwhere technically feasible. This right is not exercised in all circumstances, it applies only if it fulfils all the following conditions: 
• – your request is only related to your personal data (excluding anonymous or third-party data);
• – your request does not adversely affect the rights or freedoms of others, in particular those of Kapadalay (including trade secrets or intellectual property);
• – the processing is carried out by automated means (paper files are therefore not included);
• – the processing is based on consent or the performance of a contract (to check if it is the case, you can see the article 2 of this policy).
• – you can request the

deletion of your personal data (or right to be forgotten), where one of the following legal grounds applies:

– you object to the processing of your personal data and there are no overriding legitimate reasons justifying to maintain the processing of your personal data (such as an obligation for Kapadalay to keep certain personal data);

– you object to marketing activities;

– you decide to withdraw your consent on which the processing is based;

– your personal data are no longer useful for the original purposes for which they were collected or for any other type of processing;

– the use that is made of your data does not comply with the applicable legal or regulatory provisions.

• You candefine either general or specific guidelines regarding your personal data in the event of your death (for example, their deletion or transmission to any person of your choice). You may revoke your instructions at any time.

It is specified that the exercise of these rights is based on the legal basis of the processing as indicated in article 2 of this policy, as follows:

Under certain circumstances, Kapadalay may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it.

If you have any questions or wish to exercise your rights, you may directly contact Kapadalay by sending an email to info@kapadalay.com.

If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.

8. CHANGES TO THIS POLICY

This privacy policy may be amended from time to time, in particular to reflect the changes in the services provided by the Website or the applicable regulations. Therefore, we recommend you to review this privacy policy each time you visit the Website.