Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and
service users.

1.2 This policy applies where we are acting as a data controller with respect to
the personal data of our website visitors and service users; in other words,
where we determine the purposes and means of the processing of that
personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly
necessary for the provision of our website and services, we will ask you to
consent to our use of cookies when you first visit our website.

1.4 In this policy, "we", "us" and "our" refer to Retinize Limited. For more
information about us, see Section 13.

2. Credit

2.1 This document was created using a template from SEQ Legal
(https://seqlegal.com/free-legal-documents/privacy-policy).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you,
the source and specific categories of that data;

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services ("usage
data"). The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit,
page views and website navigation paths, as well as information about the
timing, frequency and pattern of your service use. The source of the usage
data is our analytics tracking system. This usage data may be processed for
the purposes of analysing the use of the website and services. The legal basis
for this processing is consent OR our legitimate interests, namely monitoring
and improving our website and services.

3.3 We may process any of your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure. The
legal basis for this processing is our legitimate interests, namely the
protection and assertion of our legal rights, your legal rights and the legal
rights of others.

3.4 We may process any of your personal data identified in this policy where
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice. The legal basis for this
processing is our legitimate interests, namely the proper protection of our
business against risks.

3.5 In addition to the specific purposes for which we may process your personal
data set out in this Section 3, we may also process any of your personal data]
where such processing is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital
interests of another natural person.

3.6 Please do not supply any other person's personal data to us, unless we
prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional
advice, or the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure.

4.2 Your personal data held in our website database will be stored on the servers
of our hosting services providers identified at retinize.com.

4.3 In addition to the specific disclosures of personal data set out in this Section
4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person. We
may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which
your personal data may be transferred to countries outside the European
Economic Area (EEA).

5.2 The hosting facilities for our website are situated in the USA. The European
Commission has made an "adequacy decision" with respect to the data
protection laws of each of these countries. Transfers to each of these
countries will be protected by appropriate safeguards, namely the use of
standard data protection clauses adopted or approved by the European
Commission, a copy of which you can obtain from
https://ec.europa.eu/info/law/law-topic/data-protection

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept
for longer than is necessary for that purpose or those purposes.

6.3 Notwithstanding the other provisions of this Section 6, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.

7. Your rights

7.1 In this Section 7, we have listed the rights that you have under data
protection law.

7.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal
data and to complete incomplete personal data;

(d) the right to restrict processing - you can ask use to restrict the
processing of your personal data;

(e) the right to object to processing - you can object to the processing of
your personal data;

(f) the right to data portability - you can ask that we transfer your
personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain
about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our
processing of your personal data is consent, you can withdraw that
consent.

7.3 These rights are subject to certain limitations and exceptions. You can learn

more about the rights of data subjects by visiting https://ico.org.uk/for-
organisations/guide-to-data-protection/guide-to-the-general-data-protection-
regulation-gdpr/individual-rights/.

7.4 You may exercise any of your rights in relation to your personal data by
written notice to us, using the contact details set out below].

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that
is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.

8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set

expiry date, unless deleted by the user before the expiry date; a session
cookie, on the other hand, will expire at the end of the user session, when the
web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a
user, but personal data that we store about you may be linked to the
information stored in and obtained from cookies.

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.

10.2 We use Google Analytics. Google Analytics gathers information about the use
of our website by means of cookies. The information gathered is used to
create reports about the use of our website. You can find out more about
Google's use of information by visiting
https://www.google.com/policies/privacy/partners/ and you can review
Google's privacy policy at https://policies.google.com/privacy.

10.3 We use wix.com to host our website. This service uses cookies for monitoring
usage. You can view the privacy policy of this service provider at
https://www.wix.com/about/privacy.

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies.
The methods for doing so vary from browser to browser, and from version to
version. You can however obtain up-to-date information about blocking and
deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-
website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-
explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-
website-data-sfri11471/mac (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-
privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many
websites.

11.3 If you block cookies, you will not be able to use all the features on our
website.

12. Amendments

12.1 We may update this policy from time to time by publishing a new version on
our website.

12.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.

13. Our details

13.1 This website is owned and operated by Retinize Limited.

13.2 We are registered in Northern Ireland under registration number NI663613,
and our registered office is at 112-114 Lisburn Road, Belfast, BT9 6AH, UK.

13.3 Our principal place of business is at 112-114 Lisburn Road, Belfast, BT9 6AH,
UK.

13.4 You can contact us:

(a) by post, to the postal address given above;

(b) by email, using the email address published on our website.

14. Data protection officer

14.1 Our data protection officer's contact details are:
David Morrow
Retinize Limited
112-114 Lisburn Road
Belfast
BT9 6AH
UK

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