Personal data policy

1. general description

1.1. This personal data policy (the Policy) is adopted by Hamilton Apps. This policy contains a general description of how personal data is processed by hamiltonapps.com (the website).

1.2 Hamilton Apps is a legal entity governed by the legislation in force in France.

1.3. The policy of Hamilton Apps with regard to the processing of personal data is to process personal data only in the cases and according to the procedure provided for by the applicable laws and, at the same time, Hamilton Apps considers the respect and protection of the rights and legal interests of the data subjects as its main priority. Personal data is processed only on a lawful and fair basis.

1.4. This policy is publicly available on the website and always accessible for review.

2. purposes and lawfulness of data processing

2.1 This is an international website for users worldwide who are interested in Hamilton Apps business applications. Users are deemed to include representatives of legal entities and any private person accessing the website.

2.2. Users have the right to access all parts or sections of the website without registration. Personal data of users may be collected and processed when users fill in a feedback form or other forms on the website or use the website in any other way.

2.3. In any case, Hamilton Apps will only process personal data with the explicit consent of the user. The user has the right, at any time and free of charge, to withdraw his consent to the processing of his personal data by Hamilton Apps by sending a notice to contact@safeware.fr or to the postal addresses specified in this policy. User should note, however, that such withdrawal may mean that Hamilton Apps will not be able to respond to User's messages or otherwise serve User. In addition, the user may no longer be able to use all of the features of the website, as personal data processing activities that depend on the user's consent are an integral part of those features.

2.4. Hamilton Apps never collects personal data without the knowledge of the user. Personal data is always processed for the purpose for which it was provided.

2.5. Hamilton Apps may process personal data via the website for the following purposes:
- Responding to users' messages; and
- Informing users about Hamilton Apps, commercial applications and advertising.

2.6. Consent clauses incorporated in a web form should indicate the specific purposes of the data processing.

3. collection of personal data

3.1 Hamilton Apps always collects personal data by means of web forms under the assumption that
- All personal data belong exclusively to the data subject who has filled in a web form;
- The user has followed the instructions of the web form and, among other things, has entered the information in the appropriate sections;
- The user has reached the legal age of majority and is a person with legal capacity; and
- The user has provided authentic and factual personal data

3.2. Personal data collected by Hamilton Apps may include, but is not limited to, the following information
- your name, email address, phone number, message content, consent, feedback, IP address.

3.3 Hamilton Apps may ask users to change or clarify personal data and to confirm their authenticity if necessary.

3.4. Under no circumstances will the website be used to collect personal data concerning bank (credit) cards, or other personal financial information, or personal biometric or sensitive data (criminal convictions, political preferences, etc.).

4. general conditions for the processing of personal data

4.1. Hamilton Apps treats personal data as confidential information and takes all reasonable, necessary and appropriate measures to maintain secrecy and prevent unlawful access to and/or use of personal data. Hamilton Apps will not disclose personal data collected through the website unless the data subject personally requests (in writing) that the information be made public.

4.2. The scope and content of the personal data processed are limited to the declared purposes of the processing.

4.3. Hamilton Apps guarantees the accuracy, relevance and, if necessary, the factual nature of the personal data processed in view of the purposes of the processing. Incomplete or incorrect data are clarified or destroyed without delay.

4.4 Hamilton Apps processes personal data with and without the use of automation tools. If sets of personal data are processed for different purposes, they shall not be merged into one database. Personal data is not used to make automated decisions with legal or similar consequences for you.

4.5. The website is directly and solely used to collect personal data and transfer it to Hamilton Apps' computer systems and/or employees or to other parties specified in section 4.6 below. The website and its hosting servers do not perform any automatic (independent) actions to record, systematize, accumulate, store, clarify (update, modify) and retrieve personal data.

4.6. Hamilton Apps may provide personal data to third parties, including affiliates, partners and suppliers to achieve the purposes of the data processing. If necessary, Hamilton Apps mentions these third parties in the consent to data processing included in all web forms on the site. At the same time, Hamilton Apps ensures compliance with all applicable legal requirements and asks to strictly guarantee the secrecy of the personal data of all recipients of the data.

4.7. Hamilton Apps may make cross-border transfers of personal data also outside the European Union ("EU") or the European Economic Area ("EEA"). In such situations, Hamilton Apps ensures that an adequate level of data protection is maintained in accordance with the European Commission's standard clauses. Data subjects may receive a copy of the security measures by sending a notice to contact@safeware.fr.

4.8. Hamilton Apps takes the necessary care of the processing operations and the protection of personal data in its daily activities. Hamilton Apps only allows employees with appropriate functions to carry out operations with personal data and provided that they have been trained and their access rights are properly documented.

4.9. The retention of personalised data is limited to the period necessary to achieve the purposes of the data processing, unless otherwise provided for by the applicable law. The processed data must be destroyed or de-identified when the purposes of the processing are achieved or are no longer effective, unless otherwise provided by the applicable law.

5. users' rights regarding personal data

5.1. Data subjects have the following rights:

• To receive information about the processing of their personal data;
• To demand that their personal data be clarified, blocked or destroyed if it is incomplete, outdated, incorrect, unlawfully received or irrelevant to the stated purpose of the processing of personal data
  - To challenge the (negligent) actions of Hamilton Apps before the competent authorities;
  - To protect legal rights and interests, including the right to recover damages and/or subjective risk in a court of law or other action prescribed by applicable law; and
• Other rights established by the applicable law.

6.use of cookies and website analytics

6.1. A cookie is generally a small piece of data sent to your computer device from a website and stored in your web browser while you are browsing a website. When you return to the same website, the data stored in the cookie can be retrieved by the website to inform it of your previous activity.

6.2. From time to time a 'cookie' file may be placed on your computer to improve the effectiveness of this site and/or the Hamilton Apps services to you. Most browsers are set to accept cookies. You can change your settings to refuse all cookies or to notify you when a cookie is being sent.

6.3. This policy details how Hamilton Apps uses cookies and cookie-like files and various technologies on the website. If you visit the website and your browser settings accept cookies, Hamilton Apps takes this as explicit consent to the use of cookies by Hamilton Apps.

6.4. The use of certain cookies is necessary to perform basic functions on the website. These cookies are essential for the operation of the website and are necessary to provide you with a pleasant experience when visiting the website.

6.5. Hamilton Apps may also use cookies to provide you with better services and products. These cookies are used for example for site improvement, personalisation and advertising. From your perspective, this means that the site can remember, for example, the language and country choices you have made. Hamilton Apps may look at where content on the site is accessed to help Hamilton Apps organize the site for the best possible user experience. These cookies help to personalise the content of the site, for example by showing you targeted banners and recommendations. Hamilton Apps also examines the types of referrals used to reach the site in order to evaluate the effectiveness of Hamilton Apps' campaigns and promotions. Hamilton Apps uses these cookies to serve Hamilton Apps ads from Hamilton Apps.

6.6. When you visit our website, you may notice some cookies that are not related to Hamilton Apps. We use certain third party cookies to optimise your experience of our website ads and to help us deliver relevant content to you. If you go to a web page that contains embedded content, you may receive cookies from those websites. We do not control the setting of these cookies, so we suggest that you consult the third party websites for more information about their cookies and how to manage them.

6.7. The length of time information is stored depends on the type of cookie used. Session cookies expire when the browser is closed, while persistent cookies generally have expiration dates between two and eleven months.

6.8. The website uses a web analytics service provided, for example, by Google, Inc ("Google"). To read a statement about Google's web analytics service, please click here: http://www.google.com/analytics/terms/gb.html. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out in the above statement.

7. feedback

7.1. Hamilton Apps aims to communicate with users in order to prevent any violation of their legal rights and interests in a timely and efficient manner to the greatest extent possible. Any questions regarding the processing of personal data should be addressed to contact@safeware.fr or sent by mail to Hamilton Apps, 32 Bis Boulevard Haussmann, 75009 Paris, France.

8. third-party processors

Our carefully selected partners and service providers may process your personal information on our behalf as described below:

8.1. Digital Marketing Service Providers. We periodically appoint digital marketers to conduct marketing activities on our behalf, such activity may involve the compliant processing of personal information. Our appointed data processors include:

(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: Z123456, their data protection officer can be emailed at: dpo@sopro.io.

Annex. Information on compliance with data protection requirements

1. Hamilton Apps is continuously improving its personal data protection system and takes all necessary administrative, legal and technical measures to comply with international standards.
2. Hamilton Apps complies with the following data protection requirements and ensures that third party providers also comply with these requirements if and when necessary and taking into account the threats to the information systems used for the operation of the website and the processing of personal data:

- Ensure the security of the premises housing the information systems equipment used for the processing of personal data collected by the website, so as to prevent any person not having appropriate access rights from entering or remaining on these premises in an uncontrolled manner;

- Ensures the security of all personal data carriers;

- Establishes a list of employees whose job duties require access to personal data;

- Uses information protection tools, duly assessed and confirmed to be in compliance with the information protection requirements of the applicable laws, where such tools are necessary to counteract real threats;

- Designates an employee or department responsible for data protection;

- Ensure that any changes to personal data access rights are automatically recorded in the e-mail log;

- Provide access to the e-mail log only to employees or other authorised persons who need it for the performance of their duties; and

- Meets other requirements.

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