Section A: Overview
1. The reason for this policy
- You have legal rights with regard to the way your personal data is handled. Depending on your citizenship and residency, you may be subject to legal rights under the scope of European or United States applicable law.
- You have the right to complain under Article 77 of the GDPR to the supervisory authority of Company.
- In the course of our business activities we collect, store and process personal data about our customers, suppliers and other third parties, and therefore in order to comply with the law and to maintain confidence in our business, we acknowledge the importance of correct and lawful treatment of this data.
- All people working in or with our business are obliged to comply with this policy when processing personal data.
- This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, for example, customers and business contacts, or that is provided to us by data subjects or other sources.
- It also sets out our obligations in relation to data protection under the European General Data Protection Regulation (“the Regulation” or "GDPR") as well as under the United States Privacy Act of 1974.
- This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer and store personal data.
- The procedures and principles set out herein must be followed at all times by us and our employees, agents, contractors, or other parties working on behalf of the Company.
- We aim to ensure the correct, lawful, and fair handling of your personal data and to respect your legal rights.
3. The meaning of key Data Protection terms
- Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.
- Data subjects for the purpose of this policy include all living individuals about whom we holds personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.
- Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.
- Data controllers are the people who or organizations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Act. We are the data controller and data processor of personal data used in our business for our own commercial purposes.
- Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
4. Summary of the Data Protection Principles
This Policy aims to ensure compliance with the Regulation and United States privacy laws. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:
- (Processed fairly and lawfully) processed lawfully, fairly, and in a transparent manner in relation to the data subject;
- (Processed for limited purposes and in an appropriate way) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- (Adequate, relevant and not excessive for the purpose) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
- (Accurate) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
- (Not kept longer than necessary for the purpose) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
- (Processing in line with data subject's rights) personal data must be processed in line with data subjects' rights, in particular your right to:
- request access to any data held about them by a Data Controller.
- prevent the processing of their data for direct-marketing purposes.
- ask to have inaccurate data amended.
- prevent processing that is likely to cause damage or distress to themselves or anyone else.
- (Security) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
- (Transfers outside EEA) not transferred to people or organizations situated in countries without adequate protection.
5. Our use of personal data and our purpose
- We collect, hold, and process the personal data referred to in Schedule 1 (and the purpose for which we process that personal data is also set out in Schedule 1).
- The personal information we collect from the people that visit our blog, website or app: When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.
- When we collect information: We collect information from you when you register on our site, subscribe to a newsletter, respond to a survey, fill out a form or enter information on our site.
- Amazon's Application Programming Interface: HelloProfit will also connect to Amazon's Web Services through their own API to give users full transparency about their Amazon business. HelloProfit is built for sellers and we realize that confidentiality is critical. HelloProfit is built in an SSL secured environment. For complete security and privacy, our support team requires specific user approval before logging in for user assistance.
- How we use your information: We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To personalize user's experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To improve our website in order to better serve you.
- To allow us to better service you in responding to your customer service requests.
- To administer a contest, promotion, survey or other site feature.
- To send periodic emails regarding your subscription, Company's services or other products and services.
- How we do not use your information: your personal data is never bought, sold, traded or bartered for. Any information obtained by us is because you expressed interest in our Services and took explicit action to give us certain information. Please see other clauses in this Policy for further details.
- Which information of yours we use: your business related information is never used for our own interest nor that of third parties. We do not access your Amazon Seller Central account. We do not allow employees, contractors or other persons working on behalf of Company to access your business related data without your express prior written consent. In the event of such consent, access to business related data is kept to an utmost minimum needed to resolve the issue at hand.
The minimum amount of data related to your HelloProfit account is made accessible to HelloProfit employees, contractors and other persons via the secure platform Intercom, which displays the following personally related data: time zone, country of log in, number of logins during account lifetime, name or business name, email address, phone number (if given).
Business related data includes the following, but is not limited to:
- customer data
- Sponsored Products campaigns, ad spend, keywords
- organic keywords tracked and their ranking
6. Our data protection measures
When we are working with personal data we take every reasonable measure possible to ensure that both personal data and business data remains strictly protected, confidential and where possible, encrypted and/or anonymously rendered. Your privacy is taken very seriously.
Section B: Data Protection Principles
1. Lawful, Fair, and Transparent Data Processing
The Regulation is not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The processing of personal data is lawful if one (or more) of the following applies:
- (consent) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
- (contract) processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
- (legal obligation) processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
- (protection) processing is necessary to protect the vital interests of the data subject or of another natural person;
- (public interest) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
- (legitimate interests) processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
2. Processed for Specified, Explicit and Legitimate Purposes
- The Company collects and processes the personal data set out in Schedule 1 of this Policy. This may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with us) and can include data received from third parties though this is not our intention, as laid out in this Policy.
- The Company only processes personal data for the specific purposes set out in Schedule 1 of this Policy (or for other purposes expressly permitted by the Regulation). The purposes for which we process personal data will be informed to data subjects at the time that their personal data is collected, where it is collected directly from them, or as soon as possible (not more than one calendar month) after collection where it is obtained from a third party.
3. Adequate, Relevant and Limited Data Processing
The Company will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects as under Part 5, above.
4. Accuracy of Data and Keeping Data Up To Date
The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is initially collected upon signing up for HelloProfit or our marketing services, respectively. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
5. Timely Processing
The Company shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required or there is no foreseeable use for such data in future or upon the explicit request of the User to erase said personal data, all reasonable steps will be taken to erase it without delay.
6. Secure Processing
The Company shall ensure that all personal data collected and processed is kept secure and protected against unauthorized or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organizational measures which shall be taken are provided later in more detail throughout this Policy.
Section C: Data Subject Rights
1. The Rights of Data Subjects
The Regulation sets out the following rights applicable to data subjects:
- The right to be informed;
- The right of access;
- The right to rectification;
- The right to erasure (also known as the ‘right to be forgotten’);
- The right to restrict processing;
- The right to data portability;
- The right to object;
- Rights with respect to automated decision-making and profiling.
2. Keeping Data Subjects Informed
- The Company shall ensure that the following information is provided to every data subject when personal data is collected:
- The purpose(s) for which the personal data is being collected and will be processed (as detailed in Schedule 1 of this Policy) and the legal basis justifying that collection and processing;
- Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
- Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed, as are outlined in Company's Terms of Service;
- Where the personal data is to be transferred to one or more third parties, details of those parties, as are outlined in Company's Terms of Service;
- Where the personal data falling under jurisdiction of the Regulation is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer upon explicit request of the Data Subject, including but not limited to the safeguards in place;
- Details of the length of time the personal data will be held by the Company or, where there is no predetermined period, details of how that length of time will be determined as laid out previously in this Policy;
- Details of the data subject’s rights under the Regulation as mentioned above;
- Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time, resulting in the immediate cancellation of the data subject's subscription on the grounds of needing said personal data for maintenance of one's membership;
- Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;
- The information set out above shall be provided to the data subject at the following applicable time:
- Where the personal data is obtained from the data subject directly, at the time of collection, i.e. signing up for Company's services;
- Where the personal data is not obtained from the data subject directly (i.e. from another party such as Google):
- If the personal data is used to communicate with the data subject, at the time of the first communication; or
- If the personal data is to be disclosed to another party, before the personal data is disclosed; or
- at the time when the data subject is made aware of the exchange of data, such as when visiting Company's website and agreeing to the use of tracking cookies.
- Where the personal data is obtained from the data subject directly, at the time of collection, i.e. signing up for Company's services;
3. Data Subject Access
- A data subject may make a subject access request (“SAR”) at any time to find out more about the personal data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt (this can be extended in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
- All subject access requests received must be forwarded to Nakisha Muhammad, the Company’s data protection officer, at support[at]helloprofit.com.
- The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
- SARs and personal data made portable will be made available in widely acceptable formats, such as .jpg, .png, .pdf and .xlsx.
4. Rectification of Personal Data
- If a data subject informs the Company that personal data held by the Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification within a reasonable amount of time after receipt of the data subject’s notice (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
- In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.
5. Erasure of Personal Data
- Data subjects may request that the Company erases the personal data it holds about them in the following circumstances:
- It is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed;
- The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
- The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so);
- The personal data has been processed unlawfully;
- The personal data needs to be erased in order for the Company to comply with a particular legal obligation.
- Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure within a reasonable amount of time after the receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
- In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
6. Restriction of Personal Data Processing
- Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.
- In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
7. Data Portability
- The Company processes personal data using automated means. This includes, but is not limited to, gathering the data subject's name, contact information and billing information via the third party billing service Stripe for means of processing the data subject's subscription payments.
- Where data subjects have given their consent to the Company to process their personal data in such a manner or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the legal right under the Regulation to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other Data Controllers, e.g. other organizations).
- To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the widely accessible formats listed previously.
- All requests for copies of personal data shall be complied with within a reasonable amount of time upon receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests in the case of complex or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
8. Objections to Personal Data Processing
- Data subjects have the right to object to the Company processing their personal data based on legitimate interests (including profiling) and direct marketing (including profiling).
- Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.
- Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing forthwith.
- However, in the event that a data subject does submit such an objection and wishes to maintain his or her subscription of Company's services, then the Company reserves the necessary right to contact said data subject regarding billing, services, changes to services and terms, and other matters strictly regarding the contractual agreement of both parties for Company to offer services to the data subject.
- Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Regulation, ‘demonstrate grounds relating to his or her particular situation’. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
Where the Company uses personal data and not anonymously rendered personal data such as Facebook tracking cookies for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organizational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see further parts of this Policy for more details on data security in accordance with EU GDPR and U.S. and California laws).
Section D: Our Other Obligations
- The Company’s data protection officer is Nakisha Muhammad, support[at]helloprofit.com.
- The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
- The name and details of the Company, its data protection officer, and any applicable third party Data Controllers;
- The purposes for which the Company processes personal data;
- Details of the categories of personal data collected, held, and processed by the Company;
- and the categories of data subject to which that personal data relates;
- Details (and categories) of any third parties that will receive personal data from the Company;
- Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
- Details of how long personal data will be retained by the Company; and
- Detailed descriptions of all technical and organizational measures taken by the Company to ensure the security of personal data.
2. Organizational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
- All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
- Only employees, agents, subcontractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
- Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
- The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
- All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation;
- Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
3. Transferring Personal Data to a Country Outside the EEA
- The Company hold the right to occasionally transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA if it is absolutely necessary.
- The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
- The transfer is to a country, territory, or one or more specific sectors in that country (or an international organization), that the European Commission has determined ensures an adequate level of protection for personal data;
- The transfer is to a country (or international organization) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Regulation); contractual clauses agreed and authorized by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
- The transfer is made with the informed consent of the relevant data subject(s);
- The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject); The transfer is necessary for important public interest reasons;
- The transfer is necessary for the conduct of legal claims;
- The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
- The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.
3. Data Breach Notification
- All personal data breaches must be reported immediately to the Company’s data protection officer Nakisha Muhammad.
- In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described previously) to the rights and freedoms of data subjects, the data protection officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
- Data breach notifications shall include the following information:
- The categories and approximate number of data subjects concerned;
- The categories and approximate number of personal data records concerned;
- The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
- The likely consequences of the breach;
- Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
- After being made aware of the data breach, Company shall notify the data subjects in relation to and/or affected by the breach within 72 hours.
5. Implementation of Policy
This Policy shall be deemed effective as of May 25th, 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
6. Third Party Disclosure
- We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners, tracking cookie partners and other parties who assist us in operating our website, conducting our business, conducting marketing to your on our behalf, or servicing you and account maintenance, so long as those parties agree to keep this information confidential.
- We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety.
- However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
7. Third Party Links
At our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. More information can be found by following the link below:
- Google AdSense & AdWords
We retain the right to use Google AdSense and AdWords Advertising on our website at any given time.
We have implemented or hold the right to implement for future use the following Google services including, but not limited to:
Remarketing with Google AdSense
Google Display Network Impression Reporting
Demographics and Interests Reporting
DoubleClick Platform Integration
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.
- Opting out
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
9. California Online Privacy Protection Act
- See more about the CalOPPA by following the link below:
- In accordance with CalOPPA we agree to the following:
- Users can visit our site anonymously;
- Users are able to change their personal information by logging into their account.
- Our website honors do-not-track signals.
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
- Our website allows the use of third party behavioral tracking.
10. COPPA (Children Online Privacy Protection Act)
- When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
- We do not specifically market to children under 13. Neither do we intend to market to children under the age of 18.
11. Fair Information Practices
- The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
- In order to be in line with Fair Information Practices we will take the following responsive actions as aforementioned in accordance with both United States and European data privacy laws, should a data breach occur.
12. CAN SPAM Act
- The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
- We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions;
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred;
- Contact you about any other Company-related services or products.
- To be accordance with CANSPAM we agree to the following:
- NOT use false, or misleading subjects or email addresses,
- Identify the message as an advertisement in some reasonable way,
- Include the physical address of our business or site headquarters
- Monitor third party email marketing services for compliance, if one is used,
- Honor opt-out/unsubscribe requests reasonably quickly,
- Allow users to unsubscribe by using the link at the bottom of each email.
- If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email or simply reply to the email sent with "please remove me from your mailing list" in the subject line and/or email text body.
13. Contact Information
13400 S. Route 59
Schedule 1: Our Use Of Personal Data And Our Purpose
The following personal data may be collected, held, and processed by the Company:
- Full given / legal name
- Billing information such as address
- Contact information such as email and phone number
- Further information offered freely by the data subject under no obligation
Last edited, revised and updated on 22 May 2018.