DATA PRIVACY POLICY
DATA PRIVACY POLICY
1. INTRODUCTION
1.1 Purpose
This Data Privacy Policy ("Policy") establishes how YOUR EMPLOYER ("we," "us," or "our") collects, uses, discloses, transfers, stores, retains, and protects personal information.
1.2 Scope
This Policy applies to all personal information processed by us, regardless of the medium on which that information is stored or whether it relates to past or present employees, workers, customers, clients, suppliers, website users, or any other data subject.
1.3 Policy Statement
We are committed to protecting the rights and freedoms of data subjects and safely processing their data in accordance with all of our legal obligations.
2. DEFINITIONS
Personal Data: Any information relating to an identified or identifiable natural person ('data subject').
Data Controller: The entity that determines the purposes and means of the processing of personal data.
Data Processor: The entity that processes data on behalf of the Data Controller.
Processing: Any operation performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction.
Data Subject: The identified or identifiable individual to whom personal data relates.
3. DATA COLLECTION
3.1 Types of Information We Collect
We may collect the following categories of personal information:
Identity Information: Name, username, employee ID, title, date of birth, and other identifiers.
Contact Information: Email address, telephone numbers, postal address, and other contact details.
Technical Data: IP address, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access our systems.
Usage Data: Information about how users use our website, products, and services.
Marketing and Communications Data: Preferences in receiving marketing and communications.
Financial Data: Payment information, purchase history, credit information.
Special Categories of Personal Data: Information about health, biometric data, racial or ethnic origin, political opinions, religious beliefs, or criminal records (collected only when necessary and with explicit consent or as required by law).
3.2 Methods of Collection
We collect personal information through:
Direct interactions with data subjects
Automated technologies or interactions
Third parties or publicly available sources
Cookies and similar tracking technologies
3.3 Lawful Basis for Processing
We will only process personal data where we have a lawful basis to do so:
Consent of the data subject
Performance of a contract
Compliance with a legal obligation
Protection of vital interests
Performance of a task carried out in the public interest
Legitimate interests pursued by the controller or a third party
4. USE OF PERSONAL INFORMATION
4.1 Purposes for Processing
We may use personal information for:
Providing and managing services or products
Processing and fulfilling orders
Managing customer relationships
Personalizing user experience
Marketing and promotional activities
Improving our products, services, and website
Detecting fraud and ensuring security
Compliance with legal obligations
Employee administration and management
Business analytics and research
4.2 Marketing Communications
We may send marketing communications to customers and prospects where:
They have provided explicit consent
They are existing customers and the marketing relates to similar products or services
The marketing is conducted in a business-to-business context where appropriate
All marketing communications will include an option to opt-out of future communications.
5. DATA SHARING AND DISCLOSURE
5.1 Categories of Recipients
We may share personal information with:
Service providers and processors acting on our behalf
Professional advisors (lawyers, bankers, auditors, insurers)
Regulatory authorities, government agencies, law enforcement
Business partners for joint offerings
Purchasers or potential purchasers of our business
Other third parties with the data subject's consent
5.2 International Transfers
When we transfer personal data outside the country of collection, we ensure adequate safeguards are in place through:
Data transfer agreements incorporating standard contractual clauses
Adherence to recognized frameworks (e.g., EU-US Privacy Shield, where applicable)
Binding corporate rules for intra-group transfers
Explicit consent from the data subject
Necessity for contract performance or conclusion
6. DATA SECURITY
6.1 Security Measures
We implement appropriate technical and organizational measures to protect personal data, including:
Encryption of personal data where appropriate
Ability to ensure ongoing confidentiality, integrity, availability, and resilience of processing systems
Regular testing and evaluation of security measures
Regular backups and protocols for restoring access to personal data
Access controls and authorization procedures
6.2 Data Breach Response
In the event of a data breach that poses a risk to the rights and freedoms of individuals, we will:
Notify the relevant supervisory authority without undue delay and within 72 hours, if feasible
Notify affected data subjects when the breach is likely to result in a high risk to their rights and freedoms
Document all breaches including facts, effects, and remedial action taken
7. DATA RETENTION
7.1 Retention Periods
We retain personal data only for as long as necessary for the purposes for which it was collected, including:
Satisfaction of legal, accounting, or reporting requirements
Enforcement of our agreements
Resolution of disputes
Protection against legal claims
Specific retention periods are defined in our internal data retention schedule.
7.2 Destruction of Data
After the retention period expires, personal data will be securely deleted or anonymized unless further retention is required by law.
8. DATA SUBJECT RIGHTS
8.1 Rights of Data Subjects
Data subjects have the following rights regarding their personal data:
Right to be informed about the collection and use of their personal data
Right of access to their personal data
Right to rectification of inaccurate personal data
Right to erasure (the "right to be forgotten")
Right to restrict processing of their personal data
Right to data portability to obtain and reuse their personal data
Right to object to processing based on legitimate interests or direct marketing
Rights related to automated decision making and profiling
8.2 Exercising Rights
To exercise any of these rights, data subjects may contact our Data Protection Officer or Privacy Team at YOUR COMPANY HR EMAIL. We will respond to requests within [30] days unless complexity requires an extension.
9. COOKIES AND TRACKING TECHNOLOGIES
9.1 Use of Cookies
Our website uses cookies and similar tracking technologies to distinguish users and improve our website. Types of cookies we use include:
Strictly necessary cookies
Performance cookies
Functionality cookies
Targeting cookies
9.2 Cookie Control
Users can control cookies through their browser settings and our cookie consent tool. Blocking certain cookies may impact website functionality.
10. CHILDREN'S PRIVACY
We do not knowingly collect personal information from children under the age of [13/16/18, depending on jurisdiction]. If we discover we have collected personal information from a child, we will promptly delete that information.
11. THIRD-PARTY WEBSITES
Our website may contain links to third-party websites. This Privacy Policy does not apply to third-party websites, and we are not responsible for the privacy practices of such sites.
12. GOVERNANCE
12.1 Data Protection Officer
We have appointed a Data Protection Officer (DPO) responsible for overseeing questions regarding this Policy. Contact details for the DPO: oliver@lcdkiosk.com
12.2 Employee Training
All employees who access personal data receive regular training on data protection principles and requirements.
12.3 Privacy by Design
We integrate data protection considerations into our business operations through Privacy by Design and Privacy Impact Assessments.
13. CHANGES TO THIS POLICY
We may update this Policy from time to time. Material changes will be notified to data subjects by email or through a notice on our website.
14. CONTACT INFORMATION
Questions, comments, and requests regarding this Data Privacy Policy should be addressed to:oliver@lcdkiosk.com
15. EFFECTIVE DATE
This Policy is effective as of your employment date.
