Privacy Policy
Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.
Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.
What information do we need to provide the Website?
If you use the Website we will need to collect your statistics information, device data and location data. More Information.
How will we use your information?
We use your information to provide the many functions on the Website and to improve the Website. We do not share your information with any third parties, except where we need to in order to provide the Website (e.g., for tracking purposes and to report Website traffic), or where we are instructed to by a court, authority or compelled by law. More Information.
Who do we share your information with?
We use some third parties to help us deliver the best possible experience (e.g., for tracking purposes and to report Website traffic). When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the Website and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.
Where do we process your information?
Our servers are located in Singapore. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore. More Information.
How long do we keep hold of your information?
Unless otherwise specified in this Privacy Policy, we generally retain your information for 2 months unless you request to delete such data, in which case, the data will be deleted within 30 days upon your request. More Information.
How can I exercise my rights over my information?
Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.
How will we notify you of changes?
Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.
Data Controller: Proxima Beta Pte. Limited. Email: dpo_contrareturns@proximabeta.com
Turkey Data Controller Representative: Özdağıstanli Ekici Avukatlık Ortaklığı. Email: proximabeta@iptech-legal.com (Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as Website conduct, bans, investigations, civil or criminal complaints.
This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Contra Returns Website (the “Website”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.
If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Website. By using the Website you are acknowledging our rules regarding your personal information as described in this Privacy Policy.
This Website has been developed by Proxima Beta Pte. Limited (“we”, “us”, “our”).
For the purpose of data protection laws, the data controller of your personal information in relation to the Website is Proxima Beta Pte. Limited. The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore.
Our representative in the EU for the purpose of EU data protection laws is Proxima Beta Europe B.V., which is a Dutch company within our corporate group. The registered address of Proxima Beta Europe B.V. is Gustav Mahlerplein 2, 1082 MA, Amsterdam. Our representative in the EU can be contacted at dpo_contrareturns@proximabeta.com.
Our data protection officer can be contacted at dpo_contrareturns@proximabeta.com.
Our representatives for data protection purposes in certain jurisdictions are as follows:
Jurisdiction | Representative | Address | Contact details |
EU | Proxima Beta Europe B.V. | Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands | |
UK | Image Frame Investment (UK) Limited | Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB | |
Serbia | Karanovic & Partners o.a.d. Beograd | Resavska 23, Belgrade, 11000, Serbia | |
Turkey | Özdağıstanli Ekici Avukatlık Ortaklığı. | Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey |
Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at dpo_contrareturns@proximabeta.com.
This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How We Use Your Personal Information” below.
The following is a high-level summary of the types of personal information we use:
Information about you generated as part of the Website
We automatically collect certain data from you when you use the Website, namely:
Statistics information: Your total time spent on the Website, the number of times you spend on each page of the Website and the order in which the pages were visited (page view (“PV”) and user view (“UV”)), the internal links clicked based on the URL of the next page view (PV and UV), user agent string and initial page inspection and the referring site.
Device data: Your operating system information (such OS version on iOS, Android, Windows or MAC device), browser information (Chrome, Safari, IE, Firefox, Opera), screen size and whether Flash or Java is installed.
Location data: country/region you are located in and IP address.
Please note that such personal data will be collected and processed via our third party partner (Google Analytics) for analytics purposes. We only process and store such personal data in the form of aggregated data.
Children must not use the Website for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).
By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries we have listed the relevant minimum age in the table below.
Country in which the user is located | Minimum age of the user |
Algeria | 19 |
Argentina | 18 |
Australia | 18 |
Bangladesh | 18 |
Brazil | 18 |
Colombia | 18 |
Canada | 13 |
Egypt | 18 |
European Economic Area/ Switzerland | 16 |
Kingdom of Saudi Arabia | 18 |
Kuwait | 21 |
Mexico | 18 |
Morocco | 18 |
New Zealand | 16 |
Qatar | 18 |
Russia | 14 |
South Africa | 18 |
Tunisia | 18 |
Turkey | 18 |
United Arab Emirates | 21 |
United Kingdom | 13 |
United States | 13 |
We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo_contrareturns@proximabeta.com and we will delete such information.
This section provides more detail on the types of personal information we collect from you, and why. For users who live in the EEA, Switzerland, UK, Brazil or Turkey (each a “Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.
Personal Information | Use | Legal Basis (only relevant if you are located in a Relevant Jurisdiction) |
Information generated as part of the Website | ||
Statistics information (via Google Analytics): total time spent on the Website, the number of times you spend on each page of the Website and the order in which the pages were visited (page view (“PV”) and user view (“UV”)), the internal links clicked based on the URL of the next page view (PV and UV), user agent string and initial page inspection and the referring site. | We use this information for tracking purposes and to report Website traffic. | It is in our legitimate interest to use this information to monitor your use of the Website, e.g. views, clicks and engagement with the Website. |
Device data (via Google Analytics): operating system information (OS version on iOS, Android, Windows or MAC device), browser information (Chrome, Safari, IE, Firefox, Opera), screen size and whether Flash or Java is installed. | We use this information for tracking purposes and to report Website traffic. | It is in our legitimate interest to use this information to monitor your use of the Website, e.g. views, clicks and engagement with the Website. |
Location data (via Google Analytics): country/region you are located in and IP address.
| We use this information for tracking purposes and to report Website traffic and to deliver the appropriate language version of the Website to you. | It is in our legitimate interest to use this information to monitor your use of the Website, e.g. views, clicks and engagement with the Website. |
Our corporate group operates around the world. Pursuant to our contract with you to provide you with the Website, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for the Website are located in Singapore.
In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore.
Only where necessary will we share your personal information with third parties. Situations where this occur are:
Third parties that provide services in support of the Website, including providers of analytics services (Google Analytics). All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.
Companies within our corporate group who process your personal information in order to operate the Website. All related group companies may only use your personal information in accordance with this Privacy Policy.
Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
oenforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
odetect, prevent or otherwise address security, fraud or technical issues; or
oprotect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.
Personal Information | Retention Policy |
Statistics information Device data Location data | Stored for 2 months unless you request to delete such data, in which case, the data will be deleted within 30 days upon your request |
If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.
Some jurisdictions’ laws grant specific rights to users of the Website, which are set out in this section.
This section entitled “Your Rights” applies to users that are located in a Relevant Jurisdiction. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.
The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, Argentina and Russia.
You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We will respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances).
Where we act as a data controller for your personal information, to exercise any of your rights, please contact us at dpo_contrareturns@proximabeta.com.
Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo_contrareturns@proximabeta.com.
Portability
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
Correction
You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_contrareturns@proximabeta.com.
Erasure
You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us at dpo_contrareturns@proximabeta.com.
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Website and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Objection
You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo_contrareturns@proximabeta.com.
To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo_contrareturns@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Website for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo_contrareturns@proximabeta.com.
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo_contrareturns@proximabeta.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.
If we make any material changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.
Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.
Some jurisdictions’ laws contain additional terms for users of the Website, which are set out in this section.
If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.
By using this Website, you give us your consent for the collection, storage, treatment and use of your personal information, and transfer of your personal information to a third party (third party partners or our affiliates around the world to help us deliver the Website) located in Singapore (as described in the Privacy Policy) where it is manually and electronically treated.
Overseas Recipients
We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.
Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo_contrareturns@proximabeta.com.
Correction
You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_contrareturns@proximabeta.com.
Children
If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Website.
Transacting Anonymously
Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Website. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Website.
Your Rights
If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).
Data Transfers
This section applies to users located in Brazil:
Language
This Privacy Policy is provided in Portuguese for users located in Brazil. In case of dispute, the Portuguese version of this Privacy Policy shall prevail.
Consent Revocation
Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact dpo_contrareturns@proximabeta.com. This may affect our provision of the Website to you.
Parental and Guardian Consent
If you are under the age of 18, you should not use the Website for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.
BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:
Internet or other electronic network activity information, such as your information regarding your use of the Website, including time spent on Website, your clicks, page views, device’s operating system, browser information. This information is collected directly from you and your device.
Geolocation data such as your region location and your IP address. This information is collected directly from you.
We collect your personal information for the following purposes:
To improve our services.
To track and report Website traffic.
For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.
We disclose personal information to the following types of entities:
Other companies within our corporate group who process your personal information in order to operate the Website.
Other companies that provide services on our behalf in support of the Website and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
Regulators, judicial authorities and law enforcement agencies
Entities that acquire all or substantially all of our business.
In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.
Rights under the CCPA:
If you are a California resident, you have the right to:
Request we disclose to you free of charge the following information covering the 12 months preceding your request:
othe categories of personal information about you that we collected;
othe categories of sources from which the personal information was collected;
othe purpose for collecting personal information about you;
othe categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
othe specific pieces of personal information we collected about you;
Request we delete personal information we collected from you, unless CCPA recognises an exception; and
Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.
We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
How to Exercise Your Rights
If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at dpo_contrareturns@proximabeta.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.
Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.
Language
This Privacy Policy is provided in Spanish for users located in Colombia. In case of dispute, the Spanish version of this Privacy Policy shall prevail.
How We Use Your Personal Information
From the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.
Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conducts that allow us to reasonably conclude that your authorization was granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.
Your Rights
As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information.
You can contact us if you want to exercise any of these rights through our contact information in the section ‘Contact & Complaints’ of this Privacy Policy.
Proceedings For The Exercise Of Your Rights
Queries (rights to access): You can file queries regarding the processing of your personal data by us. Queries will be attended to within a maximum term of ten (10) business days from the date of receipt. When it is not possible to attend the query within the said term, you will be informed of the reasons for the delay and we will indicate the date on which the consultation will be attended to, which may, in no case, exceed five (5) business days following the expiration of the first term.
Claims (right to correction and erasure): You have the right to file claims in relation to the processing of your personal data by clearly describing the facts that give rise to your claim. The term to attend to the claim will be fifteen (15) business days from the date of receipt. When it is not possible to attend to the claim within the said term, you will be informed of the reasons for the delay and the date on which the claim will be handled, which may, in no case, exceed eight (8) business days following the expiration of the first term.
This Privacy Policy is provided in Arabic for users located in Egypt. In case of dispute, the Arabic version of this Privacy Policy shall prevail.
By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. If you do not consent to this Privacy Policy, you must not use the Website.
You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular Singapore.
If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.
As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.
France
Your Rights
Instructions for the processing of your personal data after your death
You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.
The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.
You may amend or revoke your instructions at any time.
You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.
When you wish to make such instructions, please contact us at dpo_contrareturns@proximabeta.com.
You represent that you are at least 21 years old, or 18 years old and have obtained parental/guardian consent and, therefore, legally capable of contracting under the applicable laws and regulations in Kuwait.
By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.
Mexico
The protection of your privacy is an important principle for us. We collect information for purposes strictly necessary for the proper use of the Website.
By accepting these conditions of use, you explicitly accept that your personal data may be subject to processing by the Website.
Kindly note:
the identity of the Data Controller is Proxima Beta Pte. Limited, email: dpo_contrareturns@proximabeta.com.
the purposes of the processing for which the data is intended are set out in the table in the section “How we use your personal information”.
recipients or categories of recipients are set out in the second paragraph of the section “How We Store and Share Your Personal Information”.
whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to the section “How we use your personal information” and the section “Your Rights” (sub-paragraph “Objection”).
New Zealand
This section applies to users located in New Zealand:
Overseas Recipients
We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.
Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo_contrareturns@proximabeta.com.
Correction
You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_contrareturns@proximabeta.com.
Children
If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Website.
Your Rights
If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).
Data Transfers
While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.
Peru
You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Data Protection Law (the “Law”).
You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.
Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Law.
You can also withdraw your consent or demand a suspension of the personal information processing at any time.
If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.
Contact
To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.
Data Protection Team, responsible for the management and safety of your personal information
Contact: dpo_contrareturns@proximabeta.com
If you are using the Website in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.
The Website is not directed at Russian users or Russian market and, in particular, is not available in the Russian language. However, if you happen to be using the Website in Russia, by using the Website you consent to:
for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations, the processing of your information in accordance with this Privacy Policy; if legitimate interests, optimisation of the Website or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent); this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law);
the cross-border transfer of your information to any country where we have databases or affiliates, in particular Singapore; and
for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy.
The sub-sections “Access”, “Correction”, “Erasure”, “Restriction of Processing to Storage Only”, “Objection” of the section “Your Rights” above apply to users in the Russian Federation.
We will notify you of any material changes and may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Website after the notification.
As regards the representative for Russia, you can contact us at dpo_contrareturns@proximabeta.com. Please include the word “Russia” in the subject line of your email.
Separate consent for using certain data
By using the Website you also consent to the sharing of your personal information with certain third parties for the purposes set out under section 3 “How We Store and Share Your Personal Information”.
You determine, in your discretion, the terms of processing of your personal information (and, if applicable, you consent to the provision of access to your personal data to the general public), including by choosing to use certain features of the Website and by choosing the appropriate privacy settings in respect of your personal information in the Website.
We process your personal information subject to the terms of this Privacy Policy.
This consent is granted for as long as you use the Website. The consent may be withdrawn by you (and you may set any restrictions on processing of your relevant personal information) at any time by contacting us (dpo_contrareturns@proximabeta.com): please include the word “Russia” in the subject line of your email.
Serbia
Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.
Name: Karanovic & Partners o.a.d. Beograd
Address: Resavska 23, Belgrade, 11000, Serbia
Telephone Number: +381 11 3094 200
South Africa
You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.
Our Data Controller Representative in Turkey for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted at proximabeta@iptech-legal.com. Please include the word “Turkey” in the subject line of your email.
You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):
learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL; and
object to certain processing of data, and seek certain remedies in accordance with the DPL.
By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries other than Ukraine, to the extent and for the purpose provided by this Privacy Policy.
You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information, as described in the Privacy Policy.
We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.