PE "Rossi S.V."
Kiev, Ukraine, O.Tyhogo 59a /120
Effective Date: August 26, 2021.
P.E. Rossi S.V. ("Conversion Club", "we", "our", or "us") is committed to respecting your privacy.
Who is responsible for your personal data?
For the purposes of the European Union ("EU") General Data Protection Regulation 2016/679 (the "GDPR"), the data controller for the data you provide or that we collect in connection with our website is P.E. Rossi S.V.
Are you required to provide your personal data?
You do not have to give us any personal data in order to use most of our websites, and in most instances you will provide us with your personal data voluntarily. However, there are circumstances in which we may not be able to assist you, or an organization with which you are associated, unless you provide us with your personal data. For example, your personal data may be required for to provide you with services, and for other reasons to allow you to access one of events. In these cases, without the relevant personal data, we may be unable to assist you or your organization, and we would inform you or your organization that this is the case. We also may collect some personal data about you automatically – further details below.
Which personal data do we collect?
When you use our website or when we interact with you, the personal data we collect may include:
Contact information, such as your name, job title, business address, mobile phone number, messenger contact details and email address
Professional information, such as job titles, previous roles, and professional experience and qualifications
For our services we may collect
In addition to all or some of the information listed above, information collected from publicly available sources or data sites for client due diligence purposes
Other personal data regarding your preferences, opinions and comments where it is relevant to our services
Information regarding the issue or matter in respect of which we have been engaged to provide services, which may contain personal information about you.
How we collect your personal data
We may collect personal data about you in a number of circumstances and ways, including:
When you or your organization seek our services
When you make an inquiry about our services or otherwise interact on our website
When you attend an event with us or a third party we are working with or sign up to receive publications from us
When you interact with us by telephone, email and other electronic communication, including the use of virtual conferencing facilities
Automatically in the ways we describe below.
Using cookies and other tracking software, we automatically collect personal data about you when you access and use our websites, mobile sites, sponsored content on social media sites (the "Online Information"), and information about the device you use to access the Online Information. Thus, we may collect information about how you view the Online Information (such as the pages you view, the links you click).
We use this information to determine news, alerts, and other products and services that may be of interest to you for marketing purposes; to monitor and improve our Online Information and business; and to help us develop new products and services.
Use of your personal information
We will use the personal data listed above if and to the extent necessary to achieve the following purposes:
To provide services, including online or event organization services as instructed or requested by you or your organization
To manage and administer you or your organization's relationship with us, including billing and collection, marketing and support services, and taking other steps linked to the performance of our business relationship
To analyze and improve our services and promote our business, such as by sending you publications and invites
To protect the security of and managing access to our IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities
To comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies
To comply with court orders and to exercise and/or defend our legal rights
To assist or enhance your experience at an event;
To personalize and foster the quality of our communications and interaction with you
For any other purposes related and/or ancillary to any of the above, or any other purposes for which your personal data was provided to us
Legal justification for our use of your personal data
We may process your personal data in connection with any of the purposes set out above on one or more of the following legal grounds:
Because it is necessary for us to do so to perform your instructions or another contract with you or your organization
To comply with our legal obligations, as well as to keep records of our data privacy compliance processes
Because our legitimate interests, or those of a third-party recipient of your personal data, make the processing necessary, provided that those interests are not overridden by your interests or fundamental rights and freedoms
Because you have expressly given us your consent to process your personal data in that manner
Legal basis in detail
Marketing. We will only provide you with marketing-related information after you have, where legally required to do so, opted-in to receive those communications. If you have not opted-in to our providing you with information promoting our business, we will use your personal information for our legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms. We will give you the opportunity to opt out at any time.
Services. If we are providing you (or your organization) with services, our processing will be necessary for the performance of a contract between you or your organization and us. Prior to entering into a contract and/or to taking steps at your request or at the request of your organization before we provide services, the processing is necessary for our legitimate interests and those of our clients or prospective clients to assist us in providing the services. In all cases in which our legal basis for processing is due to our legitimate interests or those of our clients or prospective clients, we will use your personal information for our legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms.
Business partners. If you are engaged by us to provide services or supplies, or if you wish to be, our processing of your personal data will be necessary for the performance of a contract, or for our legitimate interests.
We will not use your personal data for making any automated decisions affecting or creating profiles other than as described above.
How do we protect your personal information
We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process which included:
using secure shell protocol (SSH);
access control (physical and technical);
The protection of your personal information is important to us. We maintain appropriate safeguards and current security standards to protect your personal information from unauthorized access, disclosure, or misuse, such as using Secure Socket Layer (SSL) encryption of our website. However, no system can be completely secure, and we cannot ensure or warrant the security of any information you provide to us. While we take meaningful steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We do not accept liability for unintentional disclosure.
However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our webite is at your own risk. You should only access the services within a secure environment.
Sharing and transferring your personal information
Our servers and data are hosted on Amazon Web Services, USA and/or Ireland. You can read about Amazon’s security features and compliance from: https://aws.amazon.com/security/ & https://aws.amazon.com/compliance/. Any data transferred to and from our integrations is encrypted. Therefore, your information may be stored and processed in the locations stated above.
We may share information, including personal information, with third parties engaged by us to collect information or to provide services to you (for example, a tool designed for automatic notifications to us whenever we receive a new filled online form). We set out below further details of the ways we may share your personal data with:
Third parties, including certain service providers we have retained in connection with the services we provide, such as email notification services
Social media, on a confidential basis and without use of personally identifiable information, to help us measure our performance and to improve and promote our services
Service providers which we engage to process personal data for any of the purposes listed above on our behalf and in accordance with our instructions only
We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
How long do we keep your personal data?
Your personal information will be retained in accordance with our data retention policy, which categorizes all of the information held by Conversion Club, and specifies the appropriate retention period for each category of data. Those periods are determined by the purpose for which the information is collected and used, taking into account the applicable data protection laws in the jurisdictions concerned, legal and regulatory requirements to retain the information for a minimum period, and Conversion Club’s business requirements.
We will not store personal information for more than 24 months from the date of your last active session on our website or for more than 24 months from the date of termination of an agreement between us and you or your organization (whichever is earlier), however we may retain information you submit for prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
Data protection laws including but not limited to the GDPR provide certain rights for data subjects. Your rights will depend on the laws which apply to you and us, but you may have some of all of the following rights:
To request details of the information we hold about you and how we process it
To have the personal data we hold rectified or deleted, to restrict our processing of that information, to stop unauthorized transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organization
To lodge a complaint in relation to our use of your personal information with a local supervisory authority.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms. Withdrawal of consent to receive marketing communications will not affect the processing of personal data for the provision of our services.
We will process your requests to us within 45 days. We will also notify you and a relevant supervisory authority within 72 hours from a breach related to your Personal Information that we hold.
Conversion Club does not collect, maintain, or use personal information from individuals under the age of majority or at least 18 years old. If you have grounds to claim that anyone under the age of majority has provided us with personal information, you may contact us promptly. If Conversion Club becomes aware that it has collected any personal information from individuals under the age of majority Conversion Club will remove and delete such information without undue delay.
California privacy rights
Your rights under the CCPA
For purposes of this section, the term Personal Information means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including without limitation any information that is subject to applicable data protection laws, as defined under the California Consumer Privacy Act, California Civil Code section 1798.100 et seq., as amended (CCPA).
Please consider that we do not sell Personal Information as defined under the CCPA.
Access to specific information and data portability rights: You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information over the past 12 months. This right of access includes information about:
The categories of Personal Information we collected about you
The categories of sources for the Personal Information we collected about you
Our business or commercial purpose for collecting that Personal Information
The categories of third parties with whom we share that Personal Information
The categories of Personal Information that each recipient received
The specific pieces of Personal Information we collected about you
Deletion request rights: You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your Personal Information that it has collected from you and retained, subject to certain exceptions.
Exercising access, data portability, and deletion rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us via the information provided below.
The verifiable consumer request must:
Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected Personal Information. This may include requesting that you provide us with at least two or more pieces of Personal Information to match against Personal Information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.
Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Authorized Agent: Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (Authorized Agent) may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
If you wish to have an Authorized Agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information.
Non-discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.
In the preceding twelve (12) months, we have not disclosed any Personal Information to third parties for a business or commercial purpose.
In the preceding twelve (12) months, we have not sold any Personal Information to third parties for a business or commercial purpose.
How to submit requests or contact us with questions
To make a request regarding your rights under the CCPA, please send an email to our designated privacy administrator at email@example.com
For information on how the notary practice of Conversion Club in Germany processes personal data (if you are formally or materially involved in a notarial procedure) please read our information on data processing in the notary's offices.
Effective Date: August 26, 2021
What cookies do we use?
Our websites use four five of cookie: Necessary cookies, Marketing cookies, Analytics cookies and Functionality cookies.
These are essential to enable you to move around our websites and to allow the features of the sites to work correctly. Without these, services you request – such as navigating between pages – cannot be provided.
We use the following strictly necessary cookies on all our websites, unless specified otherwise:
These enable us to collect information about how you use our websites or read our publications, for instance which pages are viewed by visitors most frequently. They are also needed to send advertising to you for marketing purposes. All information collected in this way is used to improve how our websites work or the effectiveness of our client publications.
These cookies record information about choices you have made and allow us to remember your preferences. If you are known to us and we hold your details, we may use this information to help us build up your profile based on your web journey, and choices. For example, if you access our website from a link in an email we sent to you, these cookies will allow us to track your web journey.
These cookies are used exclusively for anonymous statistical purposes and they do not allow identification of any particular individual.
Consent to Cookies
If you continue to use our website we will assume that you are happy to receive all cookies from our website. However, if you would prefer to change your cookie settings, you can do so at any time—see below ‘Control’.
Most browsers automatically accept cookies unless you change your internet browser settings. If you wish to restrict, block or delete the cookies which are set by any of our websites, you can generally do this through your browser settings. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. If you set your internet browser preferences to block all cookies, you may not be able to access all or parts of our site.
If you delete cookies relating to this website we will not remember things about you, including your cookie preferences, and you will be treated as a first-time visitor the next time you visit the site.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit allaboutcookies.org.