1. Introduction
With this notice we inform individuals who arecustomers of OZZO about the processing of their personal data and the rights towhich they are entitled under the Albanian Data Protection Legislation (“DPL”). We may amend this notice at any timeand post the amended version on our website.
2. Whois the Controller of your personal data?
We, OZZO(“OZZO”, “we”, “our”, “us”),Rruga Ismail Qemali 32, Kati -1, 1019 Tirane, Shqipëri (address), are the controllerof your personal data in connection with our business relationship. If you haveany questions or wish to exercise your rights (see section 11 below) regardingyour personal data, you may contact us by email at legal@ordo.eu.
3. How do wecollect your personal data?
We collect your personal data directly from you (e.g., when youcommunicate with us in relation to our products and services, register ascustomer through our electronic platforms, submit an order, register to receiveour newsletter, participate in our customer surveys) or from third parties(e.g., your representatives, our salespersons, business development agents). If you do not provide us with your personalinformation, we will be unable to provide you with the requested products orservices. If youare under 16 years of age, please make sure that you get your parent/guardian’spermission before you share your personal data with us. We will not processyour personal data without such consent.
4. Whichcategories of personal data does of OZZO process?
We collect the following categories of personal data:
a. Identification andcommunication data, such as full name, jobtitle, address (street, number, postal code, city, region, country), copy of IDor passport, mobile and fixed-line phone, email, tax number, mobile device unique identifier and the IP address ofyour computer if you use our websites, online platforms or apps. b. Commercial and financial data, suchas transaction value, payment methods, credit card number, bank account number,e-money digital wallets, information on your financial status, your transactionand payment history as customer of OZZO.
5. Forwhich purposes does OZZO process yourpersonal data?
We may process your personal data for any of thefollowing purposes:
a. register you as our customers;
b. conduct due diligence or other background or credit screening activities;
c. process your applications, orders and payments, and facilitating delivery requests;
d. assess, process or track your use and requests of our products and services;
e. provide maintenance services for our products and services;
f. carry out your instructions correspond to your queries;
g. contact or communicate with you in relation to our products or services;
h. prevent or investigate any fraud, unlawful activity or omission or misconduct;
i. facilitate or administer any internal or external audit of our business;
j. comply with any applicable laws and order of a court or regulatory body, including legal and regulatory disclosure and record-keeping requirements;
k. conduct research, market-surveys, analysis and/or business development activities (including data analytics, surveys and/or profiling) to improve and promote our products and services;
l. produce statistics and research for internal and statutory reporting;
m. facilitate a business transaction such merger, sale, acquisition, lease, or purchase;
n. operate, develop, and maintain our IT systems, including storage and processing of personal data in computer databases and servers.
If we must process your personal data for anyother purpose that is incompatible with the foregoing purposes, we will provideyou prior notice.
6. On which legal bases do we base the processing of your personal data?
The processing of your personal data must be premised on one of thelegal bases provided in the DPL, as amended, as well as pursuant to thedirectives of the Commissioner for Right to Information and Personal DataProtection. We base the processing ofyour personal data on the following legal bases, as appropriate from time totime: (a) performance of the contract betweenyou and us (e.g., to deliver the materials you have purchased from us), (b) compliancewith our legal obligations (e.g.,conduct sanctions and anti-corruption screening before you become ourcustomer), (c) pursuit of our legitimateinterests (e.g., collection of amounts due to us from you).
7. Whohas access to your personal data? Your personal data areaccessible to our employees, who need such access to carry out their duties,and to other OZZO
/StartUp Ventures/ORDO GmbH entities [NB1] both in and outside the EEA. Your personal data may also be accessible to the following parties whomay be based inside or outside the EEA:
a. law enforcement or administrative authorities in orderto comply with our legal obligations or a court order;
b. credit reference agencies and othercompanies for use in credit decisions, for fraud prevention and to pursuedebtors;
c. service providers for the operation,maintenance and technical support of our electronic systems;
d. other service providers (e.g. a cloudprovider) to process your personal data on our behalf and in accordance withour instructions;
e. any prospective seller or buyer of anybusiness or assets we might sell or purchase, in which case one suchtransferred asset will be the personal data held by us about customers.
8. Do wetransfer your personal data outside the European Economic Area (ΕEA)?
We maintain and process your personal data within theEEA. When required by law or necessary for OZZO business needs, we share yourpersonal data with other companies of Start-up Ventures or third parties (seesection 7 above), located in countries outside the EEA. When we transfer yourpersonal data to companies of Start-up Ventures outside the EEA, we do so onthe basis of intra-group contracts that ensure your personal data will remainas protected as they are in the EEA. When we transfer your personal data tothird parties that are outside the EEA, we make sure your personal data willremain as protected as they are in the EEA, because those third parties either(a) are located in countries which the European Commission considers secure forpersonal data or (b) undertake contractual commitments with us to protect yourpersonal data. 9.Protection and security of your personal data We implement the appropriate technical andorganizational measures to protect your personal data against any loss, misuse,unauthorized access, disclosure, alteration and destruction. Our informationsystems are protected with strong passwords and security control mechanisms atvarious levels. Electronic transfer of personal data is done by using encryptedmessages and strict criteria for identifying the recipient. We implementprocedures to deal with breaches of personal data security. Your personal dataare stored in a secure database, located in the EEA. That database isaccessible only by specialists residing in the EEA solely for repair andmaintenance purposes. 10.Retention time of your personal data We will retainyour personal data in our customer records throughout our business relationshipwith you. After the end of our businessrelationship with you we will keep your personal data in our archives for themaximum claims period under DPL, to use them, if necessary, solely for thepurpose of establishing, exercising or defending any related legal action thatmay arise. When this period ends, we will keep only your personal data whichappear in documents that form part of the historic and operational continuityof the company, such as contracts, invoices, minutes of meetings, transactiondocuments. 11. Yourrights in respect of your personal data Dependingon the legal basis we rely upon to process your personal data you have thefollowing rights in connection with your personal data (restrictions apply tosome of those rights) and you may exercise them by contacting us in any of theways mentioned in section 2 above: a. Right of Access: You have the right to request from us a free copy ofyour personal data we process and information on the processing activities(e.g., which personal data we process, how and for what purpose). b. Right to Rectification: You have the right to request from us therectification, completion or update of your personal data, if they areincorrect, incomplete or have changed. c. Right to Erasure: You have the right to request from us to erase yourpersonal data, if among other reasons, the processing is no longer necessary orlegitimate or if you have revoked your consent in case the processing is basedon it. d. Right to Object: If we have processed your personal data for theperformance of a task carried out in the public interest or for the pursuit ofour legitimate interest, you have the right to object to the processing of yourpersonal data, on grounds relating to your particular situation. If youexercise such right, we will cease processing your personal data, unless wedemonstrate compelling legitimate grounds to continue processing your personaldata or for the establishment, exercise or defense of legal claims.You may also object if we use your personal data for direct marketing purposes. e. Right to Restriction: You have the right toask us to restrict the processing of your personal data, if you contest theiraccuracy, the processing is illegal or no longer necessary or you have objectedto the processing. f. Right to Data Portability: Youhave the right to ask us to provide you with your personal data in astructured, commonly used and machine-readable format to be transferred by youor by us to another controller. g. Right to file a Complaint: If you have anyconcern or wish to raise a complaint about our handling of your personal data,you may contact us by email at
legal@ordo.eu. If you are notsatisfied with our response or believe we are not processing your personal datain accordance with the law, you have the right to file a complaint with theCommissioner for Right to Information and Personal Data Protection. If youreside in the EEA, you may file a complaint with the data protection authorityin the country of your residence or the data protection authority in thecountry where the violation of your personal data occurred. You can find the relevant supervisoryauthority’s name and contact details under http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Informationabout cookies & similar technologies What are cookies and similartechnologies? A cookie is a small text file that is placed on yourcomputer, mobile phone, or other device when you visit a website. The cookiewill help website providers to recognise your device the next time you visittheir website. There are other similar technologies such as pixel tags, webbugs, web storage and other similar files and technologies that can also do thesame thing as cookies. OZZO uses the term "cookies" in this policy torefer to cookies and all such similar technologies that collect information in thisway. How we use cookies We use cookies for the purposes, as explained in thischart: Cookie TypePurposeEssential OperationalThese cookies are necessary to allow us to operate the OZZO service as you have requested. For example, they let us recognise what type of subscriber you are and then provide you with services accordingly.Performance/AnalyticsWe use these cookies to analyse how the OZZO is accessed, used or is performing. We use this information to maintain, operate and continually improve the OZZO Service. We may also obtain information from our e-mail newsletters, to learn whether you opened or forwarded the newsletter or clicked on any of the content. This information tells us about our newsletters' effectiveness and helps us ensure that we're delivering information that you find interesting.FunctionalThese cookies let us operate certain functions of the OZZO in line with the choices you make. These cookies mean that when you continue to use or come back to the OZZO Service, we can provide you with our services as you have asked for them to be provided, such as knowing your username, remembering how you have customised our services and reminding you of music you have enjoyed.Targeting/advertisingWe use these cookies to serve you with advertisements that may be relevant to you and your interests. The information may also be used for frequency capping purposes and to help us regulate the advertisements you receive and measure their effectiveness.Third PartyWe may allow our business partners to use cookies on the OZZO for the same purposes identified above. We may also use service providers acting on our behalf to use cookies for the purposes identified above.OZZO AdsWe work with web publishers, advertising networks and service providers to deliver OZZO ads on other web sites. Cookies may be used to serve you with advertisements that may be relevant to you and your interests on other web sites and to regulate the advertisements you receive and measure their effectiveness. Manage your preferences Most web browsers allow you to manage your cookiepreferences. You can set your browser to refuse cookies, or delete certaincookies. Generally you should also be able manage similar technologies in thesame way that you manage cookies – using your browsers preferences. Thefollowing links show how to adjust the browser settings of commonly usedbrowsers:§ Internet Explorer§ Firefox§ Safari§ ChromePlease note that if you choose to block cookies, thismay impair or prevent due functioning of the OZZO.Two of the third party services we use to trackactivity related to the Service, e.g. by placing cookies are Google Analyticsand Googel Adsense, Google AdManager, Google Cloud, Upay, Stripe. If you don'twant any information to be collected and used by Google Analytics, GoogleAdManager, Google Cloud, Upay, Stripe you can install an opt-out in your webbrowser. [NB1]Mund te shtohen subsidiaries testartup ventures