Some browsers have a Do-Not-Track (“DNT”) feature that lets you tell websites that you do not want to have your online activities tracked. When you choose to turn on the DNT setting in your browser, your browser sends a signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity online tracking technologies. Those features are not all uniform. Where available, you may choose to enable an online tool that automatically communicates your universal opt-out preferences, such as the Global Privacy Control (“GPC”). You may need to use a specific browser or an extension that supports these tools and universal signals. When detected, we will process such a signal as a request to opt out of tracking and as a request to opt out of “sale” or “sharing” of your data as explained in the “Your Privacy Rights” section below. If you have questions, please contact us via one of the methods listed in the “Contacting Us” section at the end of this Privacy Statement.
COMPANY GROUPÂ AS DATA CONTROLLER
This Section of our Privacy Statement applies to persons located in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland. This Section describes how we collect, use, disclose or otherwise process personal data of persons within the scope of the EU General Data Protection Regulation (“EU GDPR”), the UK Data Protection Act, and the Swiss Federal Act on Data Protection. For purposes of this Section, the term “personal data” means any information relating to an identified or identifiable natural person.
Legal Bases for Processing
We may collect or process personal data as set forth in this Privacy Statement for the following legal bases:
- To provide you  with information and materials that you request from us.
It is in our legitimate  interests to respond to your queries and provide any information and  materials requested in order to generate and develop business. To ensure we  offer an efficient service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.
- To personalize our services and products and the Services to you.
It is in our legitimate  interests to market our services and products. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
For  direct marketing sent by email to new contacts (i.e. individuals who we  have not previously engaged with), we need your consent to send you unsolicited direct marketing.
- To send you  information regarding changes to our policies, other terms and conditions and other administrative information.
It is in our legitimate interests to ensure that any changes to our policies, other terms and  administrative information are communicated to you. We consider this  use to be necessary for our legitimate interests and will not be prejudicial  or detrimental to you.
- To administer the Services including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To help keep the Services safe and secure.
For all these categories, it is in our legitimate interests to continually monitor and improve our Services and your experience of the Services and to have network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.
- To measure or understand the effectiveness of any marketing we provide to you and others, and to deliver relevant marketing to you.
It is in our legitimate interests to continually improve our offering and to develop our business. We consider this use to be necessary in order to effectively generate business and will not be prejudicial or detrimental to you.
- To enforce the terms and conditions and any contracts entered into with you or to assert or enforce our legal rights or those of others.
We may process your personal data where necessary to perform a contract with you or to take steps to enter a contract or to comply with law or to assert or protect a legal right or obligation.Â
We may also process your personal data with your consent.Â
Your Rights and Choices
You may be able to exercise the following rights in relation to the personal data about you that we have collected (subject to certain limitations and exceptions at law):
- Right of access: you have the right to access and obtain a copy of your personal data.
- Right of portability: you have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
- Right to rectification: you have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
- Right to erasure: you have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
- Right to restriction: you have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of information in this way is not justified, such as where the accuracy of the personal data is contested by you.
- Right to object: you have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
- Right to withdraw your consent: you have the right to withdraw your consent to our processing of your personal data at any time, if such processing was based on consent. Â
If you do not wish to provide us with your personal data and processing such data is necessary for the performance of a contract with you and to fulfil our contractual obligations to you, we may not be able to perform our obligations under the contract between us. Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal.  No withdrawal of consent will be effective until we receive it and have had a reasonable period of time to act on it. You can update your details or change your privacy preferences by contacting us as provided in “Contacting Us” below.
To review, correct, update, delete, object or otherwise limit our use of your personal data that has been provided to us, or request portability and/or details of your personal data that is held by us, please contact us using the contact information listed below in the “Contacting Us” section and clearly describe your request.
If you have registered for an account with us, you can help to ensure that your personal data is accurate and up to date by logging into your account and updating your personal data.
You may unsubscribe from marketing communications at any time by clicking the “Unsubscribe” button available at the bottom of any electronic communication we may send to you. You may also unsubscribe from any medium of communication by contacting us using the information set out in the “Contacting Us” section below.
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Company Group as Data ProcessorÂ
In certain cases, we also operate as a data processor and we collect, process, and transfer personal data on behalf of our business customers in the provision of our services and products. In these circumstances, Vertus Group is acting as a data processor or service provider and our business customers remain the data controller in respect of personal data they provide to us.
To the extent that we are acting as data processor, we act in accordance with the instructions of such customers regarding the collection, processing, storage deletion and transfer of customer data, as well as other matters such as the provision of access to and rectification of personal data. We will only use such personal data for the purposes of providing the services and products for which our business customers have engaged us.
Disclosure of Personal Data to Third Parties
We may share your personal data with our group companies, affiliates, subsidiaries or contractors as appropriate to carry out the purposes for which the information was supplied or collected (i.e., to provide the services and products you have requested from us) or as otherwise provided in this Privacy Statement. Personal data will also be shared with our third-party service providers and business partners who assist with the running of the Services and our business and products (including hosting providers, email service providers and payment processing partners). Our third-party service providers and business partners are subject to security and confidentiality obligations and are contractually only permitted to process your personal data for specified purposes and in accordance with our instructions.
In addition, we may disclose personal data about you when we believe that such use or disclosure is reasonably appropriate to: comply with any legal or regulatory obligation; enforce the terms of our agreements; establish exercise or defend the rights of Company Group, our staff, customers or others protect our rights, property, safety or vital interests, or the rights property, safety or vital interests of our users or other third parties; and implement the purchase of all or substantially all of our assets, a merger, or other similar transaction that results in a change of control.