GDPR Privacy Policy

Our Policy regarding the Proper Handling and Protection of Personal Data

1. We will strictly comply with GDPR and all applicable laws, regulations and other social standards concerning the protection of personal data.
2. For ensuring proper protection of personal data, we will
   1. properly manage personal data by appointing a person responsible for overall control of personal data,
   2. grant only to persons and departments access to your personal data as far as they need it to fulfil the related purposes,
   3. implement appropriate, reasonable and possible organizational, physical, technical, and operational measures to ensure to protect your personal data from accidental or intentional manipulation, loss, destruction or access by unauthorized persons, and,
   4. educate our officers, employees and other personnel.
3. We will collect, use and provide personal data in an appropriate manner which includes the following:
   1. We will collect personal data in an appropriate and fair manner, clearly stating the intended use at the time of collection;
   2. We will use personal data only for the purposes specified in notices or public announcements before or at the time of collection, except in cases where permissible by applicable laws;
4. We will not collect special categories of personal data, except in cases where advance explicit consent of the person concerned has been obtained or where permissible or required by applicable laws.
5. From time to time, we will review this Privacy Policy and related company regulations and operating procedures, making revisions and improvements on an ongoing basis. Our security measures are continuously revised in line with technological developments.
6. With respect to provision of personal data to third parties:
   1. We will not provide personal data to third parties other than to our service providers, except in cases where you give advance consent to us or where it is allowed or required by applicable laws;
   2. In cases where personal data is provided to third parties, or received from third parties, we will keep appropriate records of such providing or receiving in compliance with applicable laws; and

What does this Privacy Policy apply to?

1. This Privacy Policy applies to all your personal data collected by 4COLORS, whether through our websites, use of our PIP-Maker services (“our Services”, or otherwise communicated to us.
2. Our websites may contain links to other websites of third parties. Please note that, these websites may have their own privacy policies and that we do not accept any responsibility or liability for your access to these websites.

What information we collect, why we collect it, and how it is used

We collect and use the following information:

The principal legal grounds for use of your personal data

We will only use your personal data where we are permitted to do so by applicable law. Under GDPR, the use of personal data must be justified under one of a number of legal grounds. The principal legal grounds that justify our use of your personal data are:

1. Contract performance:
   where your information is necessary to enter into or perform our contract with you.
2. Legal obligation:
   where we need to use your information to comply with our legal obligations.
3. Legitimate interests:
   where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
4. Legal claims:
   where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
5. Consent:
   where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).

How will we retain your personal data?

1. We retain personal data only for as long as necessary for the purposes described herein. We delete personal data without unreasonable delay when such retention is no longer necessary.
2. However, in some circumstances, we may keep your personal data for a longer period of time in order to satisfy legal, accounting or reporting requirements.

The rights and choices you have with respect to your personal data

1. Under certain circumstances, you have the following rights in relation to your personal data:
   

   Right to access: the right to obtain access to your personal data we possess;

   Right to correct: the right to have your personal data rectified if your personal data is inaccurate or incomplete;

   Right to deletion: the right to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it, provided, however, that this right does not apply if the processing of the personal data is necessary for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest or for the pursuit, exercise or defense of rights;

   Right to restriction of processing: the right to suspend the usage of your personal data or limit the way in which we process it, on the basis of: (a) inaccuracy of data; (b) where our processing is unlawful and you don’t want your personal data erased; (c) you need it for a legal claim; or (d) if we no longer need to use the personal data for the purposes for which we hold it;

   Right to data portability: the right to receive your personal data from us in a structured, common, and machine-readable format or to request transmission to another responsible person such personal data, insofar as this is technically feasible;

   Right to objection: the right to object to our processing of your personal data including where we process it for our legitimate interests, direct marketing;

   Right to withdraw consent: the right to withdraw or revoke your consent provided in the processing of data, with effect for the future, at any time, provided, the withdrawal or revocation of consent does not affect the lawfulness of the processing carried out on the basis of your consent until the withdrawal or revocation.

2. We will respond reasonably and appropriately to the above requests from individuals regarding their own personal data, upon confirming their identities.
3. Please note that, deletion or termination of usage of part or the entirety of the personal data may hinder us from providing you satisfying services.
4. Please also be aware that, we may not be able to delete or terminate usage of the information we possess under certain legal requirements.
5. To exercise your above rights, please contact us, by e-mail or by post. Please see the contact details below.

Sharing personal data

We may share personal data with our group entities and with third-parties in accordance with the GDPR. Where we share personal data with a data processor, we will put the appropriate legal framework in place in order to cover data transfer and processing (Articles 26, 28 and 29 of the GDPR). Furthermore, where we share personal data with any entity outside the EEA, we will put appropriate legal frameworks in place, notably controller-to-controller and controller-to-processor Standard Contract Clauses approved by the European Commission, in order to cover such transfers.

Outsourcing

1. We may outsource all or part of the personal data processing for carrying out the purposes set forth herein including providing our Services.
2. When executing an outsourcing agreement, we will review the eligibility of a third party as an outsourcee with which we made the outsourcing agreement. Safety management measures, confidentiality, conditions for the outsourcee to outsource to another party, and other matters regarding the appropriate processing of personal data are prescribed in the outsourcing agreement, and our outsourcee will be appropriately supervised by implementing monitoring, of the outsourcing conditions.

Supervisory Authority

You always have the right to approach the competent data protection authority with your request or complaint.

Cookies – General information

1. Cookies are files stored on your computer by a website that you visit; they enable future re-identification of your browser. We and our third-party service providers may use cookies and other similar technologies (“Cookies”) to provide our services and ensure that they perform properly, to analyze our performance and marketing activities, and to track your use of our website or services and personalize your experience. This, for example, prevents you having to re-enter required form data each time you use the website. The information stored in cookies can also be used to identify preferences and tailor content to your areas of interest.
2. First-party Cookies are set by our website. Only our website may read information from such Cookies. Third-party Cookies are set by organizations other than us. These Cookies are used by marketing companies, for example.

A. Strictly Necessary Cookies

These Cookies are necessary for our website or our Services to function and cannot be switched off. You can set your browser to block or alert you about these cookies, but some parts of our website or services will not work.

B. Performance Cookies

These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around our website. All information these Cookies collect is aggregated and therefore anonymous. If you do not allow these Cookies we will not know when you have visited our website and will not be able to monitor its performance.

C. Targeting Cookies

These cookies may be set through our website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other websites. They are based on uniquely identifying your browser and internet device.

Google Analytics

We may use third-party Service Providers to monitor and analyze the use of our websites. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. For information on the privacy practices of Google, please visit the Google Privacy Terms web page at https://policies.google.com/privacy?hl=en.

Updates to privacy policy

In order to comply with amendment of laws or for any other reasons, this Privacy Policy may be revised without any notice. The latest version of this Privacy Policy shall be applied, at all times, to the personal data collected by us. If you use or access our website or our Services after this Privacy Policy is revised, you shall be deemed to agree to the revised Privacy Policy. The revised Privacy Policy will be posted on our Website and shall become effective on the posting date.

How to contact us?

1. Please contact us at https://www.pip-maker.com/wp/test1/en/contact/ for any inquiries on your personal data or any questions regarding the Privacy Policy.
2. As a general rule, an answer to an inquiry will be in writing.
3. For certain information, we may ask you to fill out our corresponding forms. In such case, we will send such forms to you, so please fill them out and send same back to us.