We may source, use and otherwise process your personal data in different ways. In all cases we are committed to protecting your personal data. In each of the sections listed below, we describe how we obtain your personal data and how we treat it.

2.1. INDIVIDUAL CUTOMERS

We collect personal data related to current, prospective, and former customers (the “Users”) of our Services.


A. SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

a) from you directly (through the Website, the Demo or online forms); and/or
b) from other entities, service providers that are assisting us in providing you with the Services (including data analytics providers, operating systems, and internet services providers), or from your social networks accounts you used to find us (for example, Facebook, Google).


B. PERSONAL DATA THAT WE COLLECT AND PROCESS

We may collect the following categories of personal data relating to our Users:

a) Contact information (such as name or nickname or email, phone number you submit as part of your register for “Booking a consultation” in respect to our Services);

b) Your IP address and unique mobile device identification numbers (such as your device ID, advertising ID, MAC address);

c) Data about your device, such as manufacturer, operating system, CPU, RAM, browser type and language, current time;

d) Broad location data (e.g. country or city-level location);

e) Precise geolocation data (GPS, with your consent);

f) Usage data, such as data we collect with cookies and similar technologies Cookie Notice;

g) Data (such as your nickname, email, profile picture) we receive if you link another provider’s tool with the Service (such as Facebook, Google);

h) Data for advertising and analytics purposes, so we can provide you a better Service;

i) Your email address and your messages to the Services (such as chat logs and support tickets sent by email or through “Book a consultation” service (or another service we can use in the future), any feedback you submitted about your experience with us; and/or

j) Other data you choose to give us.


C. WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT

C.1:

Usage:

• We may use your personal data to provide you with our products or Services.

Lawful Basis:

• Our lawful basis for doing so is contract.

C.2:

Usage (we may use your personal data to):

• Establish and manage our relationship (including maintaining or servicing accounts, providing customer Service, and making your experience with us personalized);
• Learn about how our products and Services are or may be used to verify or maintain the quality of, and improve, our products and services (for example, when we ask you to fill out surveys about the experience you had with us);
• Security (ensuring confidentiality of personal data, preventing unauthorized access and modifications to our systems and otherwise maintaining the security of personal data);
• Website advertising or marketing services, including letting you know about our products, Services and events that may be of interest to you by email or other forms of electronic communication.

Lawful Basis:

• Legitimate Interest: our legitimate interests in doing so are: (i) management reporting (including at an intra-group level), (ii) exercise or defend legal claims, (iii) learn about how our products and Services are or may be used to verify or maintain the quality of, and improve, our products and Services (for example, when we ask you to fill out surveys about the experience you had with us), (iv) understand the market in which we operate, (v) managing security, risk and fraud prevention, (vi) perform advertising or marketing services, including letting you know about our products, Services and events that may be of interest to you by email or other forms of electronic communication, (vii) promote our Services.

C.3:

Usage:

• We may use your personal data to send you marketing communications via email.

Lawful Basis:

• Our lawful basis for doing so is your consent.

If you object to us using your personal data for the above purposes, including direct marketing, please let us know using the email address provided in Section 1 above.
Where we use your email to communicate marketing information to you, we will seek your prior consent where required to do so by law.
We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 18 or knowingly allow such persons to use our Services. If you are under 18, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 18 may provide any personal data. If we learn that we have collected personal data about a child under age 18, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 18, please contact us, using the email address provided in Section 1 above.


D. HOW LONG DO WE KEEP YOUR PERSONAL DATA

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of Service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.


2.2. REPRESENTATIVES OF OUR EXISTING OR PROSPECTIVE CORPORATE CUSTOMERS, BUSINESS PARTNERS AND VENDORS

We may collect personal data related to employees, directors, authorized signatories or other individuals associated with existing or prospective corporate customers, business partners, and vendors.

A. SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

a) from you directly;
b) from a company that employs you, if you are an employee of our existing or prospective customer, business partner, or vendor;
c) during networking events that we have either hosted, or sponsored, or attended, including from entities conducting network events; and/or
d) from publicly available sources and social media networks (for example, your company website or social media sites, such as LinkedIn).

B. PERSONAL DATA THAT WE COLLECT AND PROCESS

We may collect the following categories of personal data relating to our existing or prospective customers’, business partners’ and vendors’ employees, officers, authorized signatories, and other associated individuals:

a) name;
b) business address;
c) business email address;
d) business telephone number; and/or
e) job title.

C. WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT

Usage (we may use your personal data to):

• Provide you with our products or services or receive products or services from you;
• Establish and manage our relationship;
• Learn about how our products and services are or may be used;
• Security; and
• Let you know about our products, Services and events that may be of interest to you by email or other forms of electronic communication.

Lawful Basis:

• Our lawful basis for doing so is legitimate interest. Our legitimate interests in doing so are: (i) Efficiently fulfil our contractual and legal obligations; (ii) Management Reporting (including at an intra-group level); (iii) Understand the market in which we operate; (iv) Exercise or defend legal claims; (v) Managing security, risk and fraud prevention.

If you object to us using your personal data for the above purposes, including direct marketing, please let us know using the email address provided in Section 1 above.
Where we use your email to communicate marketing information to you, we will seek your prior consent where required to do so by law.
We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 18 or knowingly allow such persons to use our Services. If you are under 18, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 18 may provide any personal data. If we learn that we have collected personal data about a child under age 18, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 18, please contact us, using the email address provided in Section 1 above.

D. HOW LONG DO WE KEEP YOUR PERSONAL DATA

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of Service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.



2.3. WEBSITE VISITORS


A. SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

a) from you directly (for example, when “Booking a consultation” at the Website); and/or
b) from your device or browser through internet service providers, operating systems and platforms, and data analytics providers.

If you contact us, we may keep a record of that correspondence.


B. PERSONAL DATA THAT WE COLLECT AND PROCESS

We may collect the following categories of your personal data:

a) browser type;
b) information on the use of our website (for example, pages visited, geographical location, time spent on the website, online transactions);
c) cookie data (for more information please see our Cookie Notice);
d) preferences regarding online marketing; and/or
e) IP address.

C. WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT

Usage (we may use your personal data to):

• Provide our Website services to you;
• Establish and manage our relationship;
• Learn about our Website(s) visitors’ browsing patterns and the performance of our Website, including to verify or maintain the quality of, and improve, our Website, products and services;
• Security (including ensuring confidentiality of personal data, preventing unauthorized access and modifications to our systems and otherwise maintaining the security of personal data);
• Perform advertising or marketing services, including letting you know about our products, services and events that may be of interest to you by email or other forms of electronic communication; and
• Learn about how our products or services may be used, including to verify or maintain the quality of, and improve, our products and Services.

Lawful Basis:

• Legitimate Interest ((i) Website Management, (ii) Promote our goods and services, (iii) Managing security, risk and crime prevention. (iv) Management Reporting (including at an intra-group level).

If you object to us using your personal data for the above purposes, including direct marketing, please let us know using the email address provided in Section 1 above.
Where we use your email to communicate marketing information to you, we will seek your prior consent where required to do so by law.
We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 18 or knowingly allow such persons to use our Services. If you are under 18, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 18 may provide any personal data. If we learn that we have collected personal data about a child under age 18, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16, please contact us, using the email address provided in Section 1 above.

D. HOW LONG DO WE KEEP YOUR PERSONAL DATA

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of Service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.


2.4. VISITORS TO OUR PREMISES

A. SOURCES OF PERSONAL DATA

We may obtain your personal data from you directly and from our records in our operating systems and platforms.


B. PERSONAL DATA THAT WE COLLECT AND PROCESS

We may collect the following categories of your personal data:

a) name;
b) business contact details;
c) organization;
d) role;
e) time and date of your visit; and/or
f) image (for example, from CCTV cameras at our premises).


C. WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT

Usage (we may use your personal data to):

• Provide security;
• Maintain records of visitors to our premises.

Lawful Basis:

• Legitimate Interest (managing security, risk and crime prevention);
• Legitimate Interest (Management Reporting).

If you object to us using your personal data for the above purposes, including direct marketing, please let us know using the email address provided in Section 1 above.
Where we use your email to communicate marketing information to you, we will seek your prior consent where required to do so by law.

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 18 or knowingly allow such persons to use our Services. If you are under 18, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 18 may provide any personal data. If we learn that we have collected personal data about a child under age 18, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 18, please contact us, using the email address provided in Section 1 above.


D. HOW LONG DO WE KEEP YOUR PERSONAL DATA

We keep your personal data for as long as necessary to ensure security of visitors to our premises and as soon as it is no longer necessary, usually after 90 days, we delete it.

3.1.1. Our Partner Organizations and Service Providers:

We may disclose information about you to organizations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.

We may share your information with the following types of service providers:

a) technical support providers who assist with our website and IT infrastructure,
b) software providers, including “software as a service” solution providers, where the provider hosts the relevant personal data on our behalf;
c) professional advisers such as solicitors, accountants, tax advisors and auditors;
d) providers that help us generate reviews in relation to our Services;
e) our advertising and promotional agencies and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf;
f) service providers that assist us in providing our Services.

1.1.2. Law enforcement or government bodies

We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violating our Privacy Policy, Terms of Use or other agreements, or as required by law.

We share your personal data with our affiliates and partners in the EU/EEA and outside the EU/EEA. Where a data transfer outside the EU/EEA is not covered by an EU Commission adequacy decision, we rely on lawful safeguards referred to in Article 46 GDPR. This mainly includes EU Commission-approved Standard Contractual Clauses which we enhanced by supplementary security measures such as ancillary individual risk-assessments, additional contractual safeguards and technical safeguards including additional encryption or pseudonymization, to enable international transfers with PLR affiliates and partners outside the EU/EEA. You will find the full text of the EU Commission-approved Standard Contractual Clauses through this link (https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en). Please feel free to contact us at hello@anynumbers.eu for additional information on third country data transfers as well as our safeguards and supplementary security measures.

We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organizations that they only process personal data in accordance with our instructions and in order to provide the agreed Services and protect the integrity and confidentiality of your personal data entrusted to them.

We may also disclose personal data to our advisers, consultants, law enforcement and other public authorities (such as tax and social security bodies), the police, prosecutors, courts and tribunals. All these recipients are themselves responsible to comply with the EU data protection rules.

Some of the vendors that we engage to are located outside the European Economic Area. Where the EU Commission did not recognize them as locations providing adequate protection for personal data, we rely on lawful safeguards as described above.

Should you have any questions, please contact us at: hello@anynumbers.eu for additional information and/or clarifications.

Under the CCPA, among other rights, California consumers have the right to: (i) request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers; (ii) request that a business delete any personal data about the consumer that a business has collected; (iii) request that a business that sells a consumer's personal data, not sell the consumer's personal data. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at hello@anynumbers.eu.

You are entitled to obtain information from us on how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected or deleted from our systems. You can also limit, restrict or object to the processing of your personal data.

If you gave us your consent to use your data, e.g. so that we can send you marketing emails or display personalized ads, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdrew your consent.

If you would like to exercise any of your above rights, you may contact us at: hello@anynumbers.eu.

This Privacy Policy and any disputes relating to it shall be governed by and construed in accordance with the laws of Germany, applicable EU laws, and other local applicable laws and regulations.

Additional policies related to specific services can be issued by Anynumbers. Please also see our (i) Terms of Use and (ii) Cookies Notice.

YOU AGREE THAT YOUR USE OF THE WEBSITE, THE DEMO, INFORMATION, CONTENT OR SERVICES ACKNOWLEDGES THAT YOU HAVE READ THIS PRIVACY POLICY, UNDERSTAND IT, AND AGREE TO BE BOUND BY ITS TERMS AND CONDITIONS.

If you have any questions or comments, please contact us at hello@anynumbers.eu.