Privacy Notice
Last Updated: 22.09.2023

In accordance with applicable laws, we are obligated to adhere to personal data protection and processing procedures. Our commitment is to maintain the secure storage and processing of your data while respecting and safeguarding your rights as a data subject.
We take these responsibilities seriously and have put in place appropriate technical and organizational measures to ensure the privacy and security of your data.
Any processing of your personal data as described in this Privacy Notice will be conducted in compliance with Regulation (EU) 2016/679 of The European Parliament And of The Council of 27 April 2016 On The Protection of Natural Persons With Regard to The Processing of Personal Data And On The Free Movement of Such Data, And Repealing Directive 95/46/EC.
This Privacy Notice is an addition to Our Terms and Conditions and should be read in conjunction with the Terms and Conditions.
By using this website, you agree to be bound by the terms of this Privacy Notice.
We review our Privacy Notice from time to time and reserve the right, at our discretion, to amend this Notice at any time without any notice other than posting the amended Privacy Notice on Our Website. Amendments to our Privacy Notice will take effect immediately once posted on our Website. Your continued use of our services following the posting of an amended Privacy Notice will be deemed as acceptance of those amendments.
It is your responsibility to ensure that you keep up-to-date with the current Privacy Notice.
You should review this page periodically so that you are updated on any changes to the Notice.
Data controller: this refers to the individual or entity, whether a natural person or a legal entity, a public authority, an agency, or another body, who, either on their own or in collaboration with others, determines the purposes and methods of processing personal data. When the objectives and methods of this processing are established by European Union or Member State law, the controller, or the specific criteria for their appointment, may be specified by European Union or Member State law.
Data processor: data processor is a natural or legal person, public authority, agency, or other entity that carries out the processing of personal data on behalf of the data controller.
Data subject: this refers to an identifiable natural person who can be distinguished through direct or indirect identifiers.
GDPR: means EU Regulation 2016/679 – the General Data Protection Regulation;
Personal data: is any information relating to an individual, called the data subject, that us to identify him. This information may be directly or indirectly associated with an individual, through identifiers such as physical, genetic, or social characteristics.
Processing: encompasses any operation or series of operations performed on personal data or sets of personal data, whether by automated means or not. These operations include collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of personal data.
Alanbase, Supplier We, Us, Website: the following terms collectively represent the party responsible for providing the Software.
You, Client: means Instance administrator
How we collect Personal Data
We will collect personal data only according to lawful and fair means.
We collect your personal data directly from you unless it is unreasonable or impracticable to do so. We may collect this information when you:
  • access or use our website;
  • register an account with us;
  • use our products and services;
  • participate in our competitions, giveaways and other promotions;
  • contact us directly via any medium including SMS, MMS, instant messaging, email, social media platforms, postal mail and telephone;
  • provide feedback through our website/app feedback links.
Why do we collect, hold, use and disclose personal data
We collect and process your personal data based on the following legal grounds:
Legal Requirement: We may process your personal data as mandated by European Union or Member State laws applicable to us.
Contractual Necessity: Your personal data may be processed as necessary to fulfill obligations under a legally binding contract between you and us.
Legitimate Interest: We may process your personal data when there is a legitimate business or commercial reason for doing so. Prior to relying on our legitimate interest, we assess it in relation to your interests and ensure that our interest is substantial and that pursuing it will not unreasonably infringe upon your rights and interests.
We collect, hold, use and disclose personal information for purposes including the following:
  • to provide products and services to you;
  • to enable us to perform our obligations to you and to ensure that you perform your obligations under the Terms and Conditions and the Agreement;
  • for communicating with you, including sending you information about our products and services;
  • for planning, research, promotion and marketing of our goods and services, including conducting competitions or promotions;
  • to create aggregate data about Instance Administrators and it’s Partners through demographic profiling and statistical analysis of our database to optimise our products and services and /or allow for more efficient operation of our business;
  • to prove your good faith;
  • for the investigation of suspected unlawful, fraudulent or other improper activity connected with the use of our products and services.
To whom Personal Data is disclosed
By using our Website and Software and providing personal data you consent to your personal data being used by us.
We may disclose your personal data to third parties as follows:
  • to our contractors and external service providers associated with the operation of our business and provision of our services including, without limitation, associated data centres, web hosting providers, payment service providers, advertising agencies, mailing houses, printers, call centres, market research analysts, IT consultants, professional advisors and consultants;
  • to law enforcement agencies to assist in the prevention of criminal activities;
  • to government and regulatory authorities and other organisations as required or authorised by law or otherwise;
  • controlling bodies where such controlling bodies request information to protect and maintain the integrity of services provided or where we consider any activity to be suspicious or unusual; and
  • to a successor entity in the event of a business transition, such as a merger, corporate reorganisation or to a purchaser of part of or all of Our assets.
Should the information be transferred to a third party, we will use reasonable measures to ensure that the information disclosed is protected by the third party under contractual arrangements.
What are your rights?
The rights mentioned in this paragraph applies to all users visiting our website, and specifically to users from the European Union, United Kingdom and Switzerland.

You have the following rights regarding the processing of your personal data, given to you through General Data Protection Regulation (GDPR):
The right to be informed:You have a right to be informed about how your personal data is processed in a concise, transparent, intelligible and easily accessible manner, written in clear and plain language, that is free of charge. This is the purpose of this Privacy Notice.
The right of access:You have the right to obtain confirmation that your data is being processed and to have access to that personal data.
The right to rectification:You have the right to have your personal data rectified if it is incorrect or incomplete and we must notify any third parties that we have shared your data to do the same.
The right to erasure:You have a “right to be forgotten”, or to have your personal data erased and to prevent processing. The right is not absolute and in certain circumstances, this may not be possible (for example where we have to keep your personal data for legal or regulatory reasons). We must notify any third parties that have been shared your data of your request.
The right to restrict processing:You have the right to ‘block’ or suppress the processing of your personal data. This does not stop the storing of your personal data, as it may be required to restrict processing in the future. We must notify any third parties that have shared your data of your request.
The right to data portability:You have the right to obtain and reuse your personal data for your own purposes across different services in a safe and secure way, without hindrance to usability.
The right to object:You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.
Rights in relation to automated decision making and profiling:You have a right to object to automated decision making, to express your point of view, ask for human intervention, and to be provided with an explanation of the decision with your option to challenge it.
The right to withdraw consent: If you have given us explicit consent to process your personal data you have a right to withdraw that consent at any time, including but not limited to the removal of consent to be contacted for marketing purposes.
The right to lodge a complaint with a supervisory authority:You have the right to lodge a complaint with us directly and / or with a supervisory authority. You can find their contact details here.
Security of Personal Data
Your information is held on secured servers. We may also store personal data in telephone recordings and in hard copy or paper files.
We will take reasonable steps to protect the personal data we collect and ensure that it is accurate, complete and up-to-date.
Our employees, agents, contractors are required to maintain the confidentiality of all personal data.
Access to and correcting Personal Data
We take reasonable measures to ensure that the personal data we collect about you is accurate, up-to-date and complete. We also take reasonable steps to ensure that the personal data we use or disclose is accurate, up-to-date, complete and relevant.
If we are under the impression that your personal data should be corrected, we will take reasonable steps to correct it – this may include contacting you to ask you to provide your most current information.
You may request access to and correction of the personal data we hold about you. We will require you to verify your identity and to specify what information you require.
We will exert reasonable efforts to maintain the confidentiality of your Personal Data required for using the Services. We will promptly notify you upon discovering any potential or actual compromise of the security of your personal data.
Personal Data retention
We understand the importance of security and techniques needed to secure information. We store all of the Personal data we receive directly from you in a protected database residing within our secure network, behind active state-of-the-art firewall software. Moreover, we do not store or process credentials of payment cards.

The amount of time we hold your information depends on the reason it was provided. Your data will not be kept indefinitely and will only be kept for as long as is required for legitimate business reasons (for example to provide you with our Services or for the other reasons we explained above) and in order for us to comply with our legal and regulatory obligations.
The personal data we receive when you make an application (whether on our website or which comes to us via one of the websites of our affiliates) is kept for a minimum of five years, which will commence at the end of the relationship. We are required to do so to ensure that if any disputes or complaints are raised, we have your information to enable us to address the complaints or disputes.
If you request that we do not contact you for advertising and marketing reasons, we will need to keep your information as this would reflect your preferences.
Data processing clause
While utilizing our software, you will assume the role of a personal data controller, defining the limits on the collection of personal data for your Partners and Advertisers. In such cases, we would act as a data processor. The specific boundaries and purposes of this processing will be outlined in the respective Data Processing Addendum (DPA).
The party that initially obtains personal data from a data subject bears the responsibility for obtaining any necessary consents from the data subject (to the extent required by Data Protection Laws) and for providing information to the data subject prior to collecting their personal data, as mandated by Data Protection Laws. This does not absolve the other party of its obligations under Data Protection Laws, such as the duty to provide information to the data subject in connection with the processing of personal data.
You also have the option to appoint subcontractors, including Affiliates, to process personal data within our software ("Sub-Processors"). These appointed subcontractors must uphold a level of protection for personal data that is equivalent to the standards outlined in this Privacy Notice and Data Protection Addendum. It is your sole responsibility to ensure compliance with these requirements.
You will be solely liable for the actions or omissions of any Sub-Processors appointed by you.
Any party that has access to or processes Personal Data shall:
  • Process the Personal Data strictly in accordance with the requirements of Data Protection Laws applicable to Data Controllers. They should also maintain accurate written records of all Personal Data processing activities as necessitated by Data Protection Laws.
  • Be responsible for providing data subjects with any information required under Data Protection Laws, as well as enabling data subjects to exercise their rights as stipulated by Data Protection Laws. Additionally, they should provide the other party with reasonable cooperation and assistance to fulfill these obligations.
  • Implement and maintain commercially reasonable and appropriate physical, technical, and organizational security measures to safeguard Personal Data. This includes protection against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data during transmission, storage, or any other form of processing, in compliance with Data Protection Laws.
  • Adhere to any obligations concerning the notification of personal data breaches to the supervisory authority and the communication obligations to data subjects, as mandated by Data Protection Laws.
  • Promptly notify the other party, without undue delay and within twenty-four (24) hours, upon becoming aware of a breach incident.
All notices and requests concerning your personal data shall be sent to the following email address:
Once we receive your request, we will acknowledge its receipt within ten (10) business days. We will respond to your verifiable consumer request within thirty (30) days of receiving it. If additional time is required (up to 90 days), we will notify you in writing, providing the reason for the extension.
We do not charge a fee for processing or responding to your verifiable consumer request, unless it is excessive, repetitive, or manifestly unfounded. If we determine that a fee is warranted, we will provide an explanation for the decision and estimate the cost before completing your request.

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