Privacy Policy

Last Updated: 8th January 2021

1. Introduction

Azeus and its affiliated companies (“Azeus”, “we”, “us” or “our”) respect the privacy rights of our customers, users, website visitors and business partners and we recognize the importance of protecting and handling information collected about you in accordance with both the law and best practice. This document (“Privacy Policy”) tells you how we use and disclose the personal information we collect via our services or when you otherwise interact with us. The provision of your personal data is voluntary. Please note that if you do not provide us with the required personal information, we may not be able to provide your requested information, products or services, or form a business or contractual relation with you.

2. Our Processing Activities

To find out more please go to the sections of this policy that are relevant to you (at Exhibit A):

3. Security

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any passively collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information. You may access your account information and our services only through the use of an individual username and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Our information security policy is supported by a number of security standards, processes and procedures and we store information in access-controlled premises or in electronic databases requiring logins and passwords. We require our third-party data storage providers to comply with appropriate information security industry standards. All partners and staff and third-party providers with access to confidential information are subject to confidentiality obligations.

4. Location of Processing

We may store and process personal information and content in the United States and other countries or cities which include but are not limited to the United Kingdom, Australia, Hong Kong, Singapore and the Philippines. As part of a global group of companies, Azeus has affiliates and third-party service providers within as well as outside of the European Economic Area (the “EEA”) and the United Kingdom (UK). We may transfer and disclose your personal information to our affiliates and third-party service providers for any of the purposes set out in this privacy policy. As a result, your personal information may be transferred outside the country where you are located. This includes countries outside the European Economic Area (EEA), the UK and countries that do not have laws that provide specific protection for personal information. Where we collect your personal information within the EEA or the UK, transfer outside these locations will be only:

• to a recipient in a jurisdiction approved by the European Commission (for personal information collected within the EEA) or approved by the applicable United Kingdom regulator (for personal information collected within the UK) as offering an adequate level of protection for personal data; or
• we ensure that the recipient of your personal information offers an adequate level of protection and security, for instance by entering into the standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 of the EU GDPR) or other applicable regulator.

We use resources and servers located in various countries around the world to process your personal information. Your personal information may also be transferred to third party service providers who process information on our behalf, including providers of IT and IT services such as website hosting and management, data back-up, security and storage services. Our third-party service providers may also use their own third parties (sub-processors). Our third-party service providers and their sub-processors are bound to maintain appropriate levels of security and confidentiality and to process personal information as instructed by us. If you have any questions in relation to the transfer of your personal information outside the jurisdiction of origin please send an email to dataprocessing@azeus.com.

5. Sharing Information with Third Parties

We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We do not sell your personal information to third parties. We may also disclose your personal information to third parties where:

• you have consented to us sharing your personal information in this way;
• we are under a legal, regulatory or professional obligation to do so (for example, in order to comply with anti-money laundering requirements) or in order to enforce or to protect the rights and interests, property, or safety of Azeus, our clients or others;
• if Azeus is involved in a merger, acquisition, or sale of all or a portion of its assets, or a bankruptcy proceeding, we may transfer your information to the acquiring company, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
• we may share aggregated or anonymized information with third parties that does not directly identify you.

6. Data Retention

We may retain your personal data for a period of time consistent with the original purpose of collection. We also may retain your personal data during the period of time needed for Azeus to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, enforce our agreements, if deemed necessary.

7. Your Rights

You have a right of access to personal data held by us as a data controller. We may charge for a request for access in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits. You have a right to have any inaccurate personal information corrected. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information. Where we process personal data based on consent, individuals have a right to withdraw consent at any time. You also have a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability. If you wish to exercise any of these rights, please send an email to dataprocessing@azeus.com. In case you want to complain about our use of personal data, please send an email with the details of your complaint to dataprocessing@azeus.com. We will look into and respond to any complaints we receive.

8. Changes to This Privacy Policy

We will update this Privacy Policy when necessary to reflect customer feedback and changes in our services. When we post changes to this Privacy Policy, we will revise the “Last Updated” date at the top of the Privacy Policy. Any changes will be effective upon posting the revised version of the Privacy Policy (or such later effective date as may be indicated at the top of the revised Privacy Policy). If in our sole discretion there are material changes to the statement or in how Azeus will use your personal information, we may notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Privacy Policy to learn how Azeus is protecting your information.

9. Contacting Us

Any questions, comments and requests regarding this Privacy Policy or the information that we hold about you should be addressed to dataprocessing@azeus.com. You may also contact our EU/EEA and UK Representatives at the below addresses: Convene Sociedad Limitada Address: Calle Balmes, nú-mero 173, 4° 2^a, 08006, Barcelona Email: dataprocessing@azeus.com Azeus UK Limited Address: Azeus Convene, 3.022, 3 Waterhouse Square, 138-142 Holborn, London, EC1N 2SW Email: dataprocessing@azeus.com