Shasso respects the data subject’s privacy and works hard to safeguard the privacy of the data subject’s personal data. We realize that the exciting growth of the Internet and online services raise questions concerning the nature, use and confidentiality of information collected about consumers. We want the data subject to know that we apply our long-standing commitment of safeguarding privacy to our online and Internet activities.
By providing Personal Information to us, the data subject isconsenting to this Privacy Statement and the collection, use, access, transfer, storage and processing of the data subject’s personal information as described in this Privacy Statement.
The use of the Internet pages of Shasso is possible without any indication of personal data; however, if a data subject wants to use our services on the Portals, including, without limitation, reselling and retailing online games and related merchandises or games publishing, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we will obtain the data subject’s consent.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Shasso. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, Shasso has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through the Portals. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
In addition to GDPR, please note that we collect, store and handle personal information of individuals in accordance with the Personal Data Protection Act 2010 (“PDPA”) and the laws of Singapore. We are also in full compliance with the Lei Geral de Proteção de Dados (LGPD), which means the data subject can follow the LGPD process if the data subject want us to provide the data subject with a copy, make correction or remove the data subject’s data. Since we process data of individuals who are within the territory of Brazil, the Brazilian LGPD applies to our processing of the data subject’s Personal Data.
The data protection declaration of Shasso is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and partners. To ensure this, we would like to begin by explaining the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
- Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by Shasso.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of Shasso.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
- Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of Shasso or processor, are authorised to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Other capitalized terms not defined above, shall have the meaning granted to it in our Terms of Services.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection this is:
50 Tagore Lane,
#04-11C Entrepreneur Centre,
Phone: +65-3158 3145
3. Information We Collect From You
We value each data subject’s trust in providing us their personal information.
A customer's name, address (postal and e-mail) and telephone number are the most important pieces of information, but we might request other information, based on, for example, the Service(s) being ordered or promoted.
Sharing, Disclosure, and Sale of Personal Data
Shasso does not share, disclose or sell any personally-identifiable information (such as the data subject’s name, address, telephone number or e-mail address) collected online on Shasso' Portals with other unaffiliated companies or organizations for non-Shasso marketing purposes. Because this information is a critical part of our business, it would be treated like our other assets in the context of a merger, sale or other corporate reorganization or legal proceeding.
We will only provide personally-identifiable online information in response to subpoenas and other legal demands, and where we believe that disclosing this information is necessary to identify, contact or bring legal action against individuals who may be endangering public safety or interfering with Shasso' services, or with our customers' or others' use of them.
Disclosure of the Data Subject’s Information (If Needed)
When the data subject has provided personal information to us for a particular purpose, we may disclose the data subject’s information to other companies that we have engaged to assist us in fulfilling the data subject’s request. This may include, but is not limited to, fulfillment houses, billing services, transaction managers, credit verification services, and other third-party service providers. We may also disclose any of the data subject’s personal information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem necessary in our sole discretion, in order to protect the legitimate legal interests of Shasso.
Information of Children and Underage Adolescents
Children and underage adolescents may be users of our products and Services, provided that they are duly authorized by their parents or guardians or that their parents or guardians act on their behalf. In the event that their parents or guardians of these children become aware of an unauthorized data processing, they may submit their inquiries or complaints to firstname.lastname@example.org.
When Do We Collect the Data Subject’s Personal Information?
We may collect personal information directly from data subjects when they:-
- communicate with us (for example when the data subjects submit an application form to become our customer, or when they contact us for any enquiries including by calling our customer service,registering for an Account, using our Portals' Services or receiving our publications (for example, newsletters);
- participate in any of our surveys;
- enter into or participate in any competitions, contests or loyalty programs run/organized by Shasso;
- register interest and/or request for information of (through our online portals or other available channels) or subscribe to our products and/or Services;
- respond to any marketing materials we send out;
- visit or browse our Portals;
- lodge a complaint with us; and/or
- provide feedback to us (for example via our Portals or in hard copy).
Other than personal information obtained from the data subject directly (as detailed above), we may also obtain data subject’s personal information from third parties we deal with or are connected with the data subject (credit reference agencies or financial institutions), and from such other sources where the data subject has given their consent for the disclosure of information relating to the data subject, and/or where otherwise lawfully permitted.
How Do We Collect the Data Subject’s Personal Information?
Shasso collects information online by asking the data subject for it, for example, when the data subject orders a Service, applies for a job, or responds to a survey, offer or other promotion.
Cookies:Shasso may also use "cookies" and similar technology to obtain information about the data subject’s visits to our Portals or the data subject’s responses to e-mail from us - both individually and in aggregated data that does not identify the data subject. These reporting tools tell us the parts of our Portals or e-mails in which the data subject showed an interest or took some action, and help us improve the quality and usefulness of our Portals.
Content: Data subjects also provide us information in content they post to the Portals. The data subject’s content (such as reviews, photos and videos) and metadata about the data subject’s content will be viewed by other users. Shasso can, but has no obligation, to monitor the content data subjects post on the Portals. We can remove any information data subjects post for any reason or no reason.
Payment Method: Data subjects will also be asked to submit Personal Information depending on the payment method data subjects choose when accessing, purchasing or subscribing to one of our products or Services. For example, if the data subject chooses to pay for a product/service by credit card, the data subject will be required to provide us the name of the data subject’s credit card issuer, credit card number, billing address, CVV number, and expiration date.
Log Files: When data subjects use the Portals, our servers automatically record certain information sent by the data subject’s web browser. These server logs may include information such as the data subject’s web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how the data subject interacts with links on the Portals, domain names, landing pages, pages viewed, mobile carrier, and other such information.
Geo-Location Information: When data subjects use the Portals by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of the data subject’s mobile device.
How Do We Use the Data Subject’s Information
Shasso uses the personally-identifiable information collected online principally to provide data subjects with the service(s) data subjects have ordered and to let data subjects know about other offerings which may be of interest to data subjects. Postal and e-mail address information, for example, enables communication about services offered and ordered, as well as the proper provisioning and billing of those services. At any point of time, should the data subject feel the need to opt-out of future communications with Shasso, options are given within the data subject’s Account to exclude those communicated messages to the data subject.
What We Request From Data Subjects
We request for data subjects to provide us accurate and complete information about themselves and any other person whose personal information the data subject provides us. We further request that data subjects update the information that they have provided us when it becomes incorrect or out of date by contacting us. This obligation is a condition to the provision of our Services to data subjects and/or any other person authorized or permitted by the data subject or the data subject’s organization/company to use the products and/or Services.
We Promise Privacy & Security
Both of us together play an important role in protecting against online fraud. The data subject should be careful that any information including their User ID, Password, or Security Code are not compromised by ensuring that each data subject does not knowingly or accidentally share, provide or facilitate unauthorized use of it. Do not share;
- User ID – each data subject and every account user will receive a unique identifier.
- Password - is the passphrase that each data subject uses to access our Services.
- Security Code - sent to each data subject to verify the data subject’s access to our Services.
At Shasso, we use encryption, firewalls and other technology and security procedures to help protect the accuracy and security of the data subject’s personal information and prevent unauthorized access or improper use. For example, data subjects will note that while using some features of the Shasso's Portal, data subjects will need to submit a password or some other type of authenticating information.
Notices to the Changes in Privacy Policies
4. Data protection provisions about the use of Shasso
We use a tracking pixel. A tracking pixel is a miniature graphic embedded in a web page to enable log file recording and log file analysis to subsequently perform a statistical analysis. Shasso also sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. The setting of the cookie enables us to analyze the usage of our Portals. Using the data obtained, usage profiles are created. The usage profiles are used for the purpose of analyzing visitor behavior and enabling an improvement of our Internet offer. Data collected through the Shasso component are not used to identify the data subject without first obtaining a separate and explicit consent from the data subject. These data will not be merged with personal data or with other data which contains the same usage profile. By default, Shasso identifies the companies, not the individuals, who are accessing the Portals, and presents firmographic information. Personal information is only collected and stored based on opt-in preferences.
With each call-up to one of the individual pages of the Portals, the Internet browser on the information technology system of the data subject is programmatically requested to submit data for the purpose of online analysis to the Shasso component. During the course of this technical procedure, Shasso gains knowledge of visitor information, such as the requesting IP address, which inter alia, serves to understand the origin of visitors and clicks.
The cookie is used to store anonymized information, such as the access time, and the frequency of visits to our Portals. With each visit of our Internet pages, these visitor data, including the IP address of the Internet access used by the data subject, are logged and stored by the Shasso server.
The data subject may prevent the setting of cookies through our Portals at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Shasso from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Shasso may be deleted at any time via a web browser or other software programs.If Shasso chooses “Shasso” as lead identification option for their website, we might transmit personal data of the data subject to our processors. By implementing this lead identification option, the data subject agrees to the transfer of personal data required for lead identification. The personal data transmitted to Shasso is usually first name, last name, email address, IP address, telephone number, mobile phone number, or other data necessary for lead identification processing. The transmission of the data is aimed at lead identification. Shasso can transfer personal data to our processors, in particular, if a legitimate interest in the product or Service is given.
The data subject may, at any time, prevent the setting of cookies through our Portals by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our Portals may be entirely usable.
6. Collection of general data and information
The Portals of Shasso collects a series of general data and information when a data subject or automated system calls up the Portals. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our Portals (so-called referrers), (4) the sub-websites, (5) the date and time (so-called timestamp) of access to the Internet site, (6) an Internet protocol address (IP address), (7) the internet service provider (ISP) of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, Shasso does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our Portals correctly, (2) optimize the content of our Portals as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Shasso analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
7. Registration on our Portals
The data subject has the possibility to register on the Portals with the indication of personal data. Which personal data are transmitted Shasso is determined by the respective sign-up form used for the registration which can be obtained from https://www.shasso.com/sso/login. The personal data entered by the data subject are collected and stored exclusively for internal use by Shasso, and for his own purposes. Shasso may request transfer to one or more processors that also uses personal data for an internal purpose which is attributable to Shasso.
By registering on the Portals of Shasso, the IP address—assigned by the internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our Services, and, if necessary, to make it possible to investigate committed offenses. Shasso stores such data only insofar, the storage of this data is necessary to secure Shasso. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable Shasso to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of Shasso.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. A Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of Shasso’s employees are available to the data subject in this respect as contact persons.
8. Subscription to our newsletters
On the Portals of Shasso, users are given the opportunity to subscribe to our newsletter. The input section used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from Shasso.
Shasso informs its customers and partners regularly by means of a newsletter about product offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of Shasso.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link (‘unsubscribe’) is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on our Portals, or to communicate this to us in a different way.
The newsletter of Shasso contains tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Shasso may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up (clicked on) by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by Shasso in order to optimize the shipping of the newsletter, as well as to continuously adapt the content of future newsletters to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by Shasso. Shasso automatically regards a withdrawal from the receipt of the newsletter as a revocation.
10. Contact possibility via the Portals
The Portals of Shasso contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts Shasso by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
11. Subscription to comments in the blog on the Portals
The comments made in the blog of Shasso may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to the comments following his comments on a particular blog post.
If a data subject decides to subscribe to the option, Shasso will send an automatic confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address decided in favor of this option. The option to subscribe to comments may be terminated at any time.
12. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which Shasso is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
13. Rights of the data subject
- Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from Shasso the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of Shasso.
- Right of access
Each data subject shall have the right granted by the European legislator to obtain from Shasso free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from Shasso rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of Shasso.Pauline Chua,
Data Protection Officer
Tel: +65 98628773
- Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from Shasso without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.<.li>
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of Shasso.
- Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from Shasso the erasure of personal data concerning him or her without undue delay, and Shasso shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which Shasso is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Shasso, he or she may at any time contact our Data Protection Officer or another employee of Shasso. The Data Protection Officer of Shasso or another employee shall promptly ensure that the erasure request is complied with immediately.
Where Shasso has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, Shasso, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of Shasso or another employee will arrange the necessary measures in individual cases.
- Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from Shasso restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling Shasso to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- Shasso no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of Shasso override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Shasso, he or she may at any time contact our Data Protection Officer or another employee of Shasso. The Data Protection Officer of Shasso or another employee will arrange the restriction of the processing.
- Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from Shasso to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Shasso.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by Shasso or another employee.
- Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Shasso shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If Shasso processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Shasso to the processing for direct marketing purposes, the data subject could inform Shasso to exclude the subject from any direct marketing approach and Shasso will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Shasso for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of Shasso or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
- Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which Shasso is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Shasso shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of Shasso, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of Shasso or another employee of Shasso.
- Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer of Shasso or another employee of Shasso. In the event that such withdrawal of consent would mean that Shasso is unable to provide its Services to the data subject, such data subject will be notified of the same before any termination of the Services.
14. Data protection provisions about the application and use of Google Analytics
On the Portals, Shasso has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to Portalss. A web analysis service collects, inter alia, data about the Portals from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a Portals and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of the Google Analytics component is to analyze the traffic on our Portals. Google uses the collected data and information, inter alia, to evaluate the use of our Portals and to provide online reports, which show the activities on our Portals, and to provide other services concerning the use of our Portals for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our Portals. With each call-up to one of the individual pages of this Internet site, which is operated by Shasso and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our Portals by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our Portals at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following link https://www.google.com/analytics/.
15. Data protection provisions about the application and use of Google Remarketing
On this Portals, Shasso has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.
The operating company of the Google Remarketing services is the Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other Portalss, which are based on individual needs and matched to the interests of Internet users.
Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our Portals if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behaviour of the user, which Google uses, inter alia, for the insertion of interest relevant advertising.
The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our Portals at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject.
Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
16. Data protection provisions about the application and use of Google-AdWords
On the Portals, Shasso has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
The purpose of Google AdWords is the promotion of our Portals by the inclusion of relevant advertising on the Portalss of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our Portals.
If a data subject reaches our Portals via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our Portals. Through the conversion cookie, both Google and Shasso can understand whether a person who reached an AdWords ad on our Portals generated sales, that is, executed or canceled a sale of goods.
The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our Portals. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our Portals, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
17. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of Shasso (Recital 47 Sentence 2 GDPR).
18. The legitimate interests pursued by Shasso or by a third party
Where the processing of personal data is based on Article 6(1) of GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders, while maintaining our obligations;
- to preventing fraud by using personal information to prevent and detect fraud and abuse in order to protect the security of our customers, Shasso, and others. We may also use scoring methods to assess and manage credit risks;
- to ensure anti-money laundering compliance through verification to minimize fraud and also to prevent the creation and the use of fraudulent accounts;
- to ensure network and information security by utilizing a wide variety of programs that validate our security controls;
- to identifying criminal or suspicious transactions or threats to public safety;
- to improve or enhance the operations of Shasso, and the Services provided by Shasso to data subjects; and
- to learn about and understand the data subject’s behavior or any other customers of Shasso in relation to our Services.
20. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
21. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data may be required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
22. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.