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PRIVACY & COOKIES
TYPES OF DATA COLLECTED
Among the types of Personal Data that www.asaboveuk.com collects, by itself or by third parties , there are: Tracker; Usage Data; unique device identifiers for advertising (Google Advertisers ID or IDFA, for example); email address.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through www.asaboveuk.com and confirm that they have the third party’s consent to provide the Data to the Owner.
MODE AND PLACE OF PROCESSING THE DATA
Methods of Processing. The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purpose indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of www.asaboveuk.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party service providers, mail carriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
LEGAL BASIS OF PROCESSING
The Owner may process Personal Data relating to Users if one of the following applies
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
Processing is necessary for compliance with a legal obligation to which the Owner is subject;
Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular wether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owners operating offices and in any other places where the parties involved in the processing are located. Depending on the Users location, data transfers may involve transferring the Users Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of a contract between the owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owners legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
THE PURPOSES OF PROCESSING
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect and malicious or fraudulent activity, as well as following; Analytics, Remarketing and behavioral targeting and Advertising.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data.
DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
Personal Data is collected for the following purposes and using the following services
ADVERTISING - This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertising on www.asaboveuk.com possibly based on User interests. This does not means that all Personal Data used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use trackers to identify Users or they may use the behavioral retargeting technique, i.e display ads tailored to the Users interests and behavior, including those detected outside www.asaboveuk.com. For more information please check the privacy policies of the relevant services. Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt- out feature offered by any of these services below, User may learn more on how to generally opt-out of interest based advertising within the dedication section “How to opt-out of interest based advertising” in this document.
GOOGLE ADS SIMILAR AUDIENCES (GOOGLE IRELAND LTD) - Similar audiences is an advertising and behavioral targeting service provided by Google Ireland Ltd that uses data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of www.asaboveuk.com. On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar Audiences.
Users who don’t want to be included in similar audiences can opt-out and disable the use of advertising trackers by going to google: adsettings.google.com in order to understand Googles use of Data, consult Googles partner policies - policies.google.com (Personal Data processed: Tracker; Usage Data.
GOOGLE AD MANAGER (GOOGLE IRELAND LTD) - Google Ad Manager is a service provided by Google Ireland Ltd that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to understand Googles use of Data, consult Googles Partner Policies - policies.google.com
This service uses the “DoubleClick” cookie which tracked the use of www.asaboveuk.com and User behaviour concerning ads, products and services offered.
Users may decide to disable all the DoubleClick cookies by going to adsettings.google.com (Personal Data processed: Tracker; Usage Data)
REMARKETING AND BEHAVIORAL TARGETING - This type of service allows www.asaboveuk.com and it’s partners to inform, optimise and serve advertising based on past use of www.asaboveuk.com by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the Remarketing and behavioral targeting activity. Some services offer a Remarketing option based on email address lists. Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt out feature offered by any of the services below, Users may learn more on how to generally opt out of interest based advertising within the dedicated section “How to opt out of interest based advertising” in this document.
GOOGLE ADS REMARKETING (GOOGLE IRELAND LTD) - Google Ads Remarketing is a Remarketing a behavioral targeting service provided by Google Ireland Limited that connect the activity of www.asaboveuk.com with the Google Ads advertising network and the DoubleClick Cookie.
FACEBOOK CUSTOM AUDIENCE (FACEBOOK IRELAND LTD) - Facebook Custom Audience is a Remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of www.asaboveuk.com with the Facebook advertising network. Users can opt out of Trackers for ads personalisation by visiting www.facebook.com/about/privacy
FACEBOOK REMARKETING (FACEBOOK IRELAND LTD) - Facebook Remarketing is a Remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of www.asaboveuk.com with the Facebook advertising network.
ANALYTICS - The services contained in this section enable the owner to monitor and analyse web traffic and can be used to keep track of User behavior.
GOOGLE ADS CONVERSION TRACKING (GOOGLE IRELAND LTD) - Google Ads conversion tracking is an analytics service provided by Google Ireland that connect data for the Google Ads advertising network with actions performed on www.asaboveuk.com.
GOOGLE ANALYTICS (GOOGLE IRELAND LTD) - Google Analytics is a web based analytics service provided by Google Ireland Ltd. Google utilises the Data collected to track and examine the use of www.asaboveuk.com, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextual and personalise the ads of its own advertising network.
FACEBOOK ADS CONVERSION TRACKING (FACEBOOK IRELAND LTD) - Facebook Ads Conversion tracking (Facebook Pixel) is an analytics service provided by Facebook Ireland Ltd that connect data from the Meta advertising network with actions performed on www.asaboveuk.com. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and audience network.
INFORMATION ON OPTING OUT OF INTEREST BASED ADVERTISING
In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by “YourOnlineChoices” or other similar initiatives. Such initiatives allow Users to select their tracking preferences for more of the advertising tools. The Owner thus recommends that Users make use of these resources in the addition to information provided in this document. Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
THE RIGHTS OF THE USERS - Users may exercise certain rights regarding their Data processed by the Owner
Withdraw their content at any time - Users have the right to withdraw consent where they have previously given their consent to the processing of their personal data
Object to processing their Data - Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data - Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and Seek Rectification - Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected
Restrict the processing of their Data - Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed - Users have the right, under certain circumstances, to obtain erasure of their Data from the Owner.
Have their Data and have it transferred to another controller - Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transferred to another controller without and hindrance.
Details about the right to object to processing - Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.
Additional information about Data processing and collection
Legal Action - The Users Personal Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of www.asaboveuk.com or the related services. The User declares to be aware to be aware that the Owner may be required to reveal personal data upon request of public authorities
OWNER & DATA CONTROLLER
AS ABOVE LTD, 14a Forde Park, Newton Abbot, Devon, TQ12 1DD, United Kingdom