PERSONAL DATA PROCESSING POLICY

We ensure that we respect the confidentiality of your personal data and, therefore, ALL FRIENDS, we undertake to protect any information that identifies or may contribute to the identification of a person ("personal data"), which we collect, process and/or have access to.

The way personal information is collected, processed and shared depends on the legal purposes and legal basis on which it is collected and processed, as well as the specific consent granted by you.

Through this Personal Data Processing Policy, we want to ensure that you have access to adequate information about the collection and processing of your personal data, including those information that we are required to inform you about, as stipulated by the regulations regarding the protection of personal data, including the GDPR Regulation no. 2016/679 The General Data Protection Regulation ("GDPR").

This policy may be supplemented with other information provided by us, as well as with other terms and conditions that apply to this website or to which you have given your consent by interacting with us.

Who are we?

ALL FRIENDS, is a data operator with headquarters in 203 S BALTIMORE AVENUE, OCEAN CITY, MARYLAND, 21842, phone: +14436642803, e-mail: info@allfriends.co.

All Friends is a registered trademark of Smart Staff LLC.

What data do we process?

For communication you agree to give us personal data such as: email address, first and last name, telephone number. If you have a contractual relationship with All Friends we will request and process your university or faculty, Facebook, Instagram, citizenship, country of residence, correspondence address, identifying identity documents (CI, Passport, Residence Permit), travel history abroad, contact details of an emergency contact and of the parents.

We may also collect and then process certain information about your behavior while visiting our website or using the smartphone application to customize your online experience and to offer you tailored services for your profile.

On our website and on the app we can store and collect information in cookies and similar technologies, according to the Cookie Policy.

What is the purpose and legal basis of the processing?

The purpose to process personal data collected through your consent is to ensure that the contractual agreements between us can be properly implemented so that the relationship can work smoothly and comply with legal requirements, to provide you commercial and marketing materials (eg. information about products, offers, other information about product delivery etc.). The processing of your personal data is based on your consent to that effect (Article 6 (1) (b) of the General Data Protection Regulation).

Who has access to your data?

If you are a recipient of any of our services for which you voluntarily signed up the personal data transmitted by you is processed by All Friends. Moreover, if you are a participant in any of our partner agencies’ programs and you agree to use services provided by All Friends the personal data transmitted by you will also be processed by All Friends.

How long is your data stored?

Personal data provided by you will be processed during the All Friends contract or during the subscription to the newsletter.

Subsequently, either at the termination of the collaboration relationship or at the expiry of the legal obligation to archive that All Friends has, under applicable tax and accounting law, the data will be erased.

What are your rights to withdraw consent and unsubscribe?

You have a number of rights in accordance with the applicable data protection regulations. Certain rights are quite complex and include derogations, which is why it is recommended that you read the relevant legislation as well as the directives issued by the competent authorities to obtain full explanations of these rights. Otherwise, you can find a summary of your rights in the section below.

1. The right to access the data. You have the right to obtain confirmation that your personal data is processed by All Friends or not. Additionally, you have the right to obtain detailed information regarding personal data stored and processed by All Friends, and under certain circumstances you are entitled to obtain a copy of this personal data.

2. The right to data rectification. You have the right to request the rectification of incorrect personal data and, considering the purpose for which they are processed, request the completion of missing personal data.

3. The right to erasure the data. In some cases, you have the right to delete your personal data without undue delay. These circumstances include: i) when personal data are no longer required in relation to the purposes for which they were collected or processed; ii) when you withdraw your consent for consent-based processing; iii) when processing is for direct marketing purposes; iv) when personal data has been processed without complying with applicable law. However, there are some general exceptions to the right to delete the data. These general derogations include cases where processing is necessary: i) for the exercise of the right to freedom of expression and information; ii) to meet legal obligations or; (iii) for the establishment, exercise and defense of legal claims.

4. The right to restriction of processing. In some cases, you may restrict the processing of your personal data. Where processing has been restricted, we may continue to store your personal data. Otherwise, we only process them when: i) we have your consent; (ii) necessary for the establishment, exercise or defense of legal claims; (iii) are necessary to protect the rights of another natural or juridical person; or (iv) for important reasons of public interest.

5. The right to data portability. If the legal framework for processing is your consent and this processing is done by automated means, you have the right to obtain your personal data in a structured format, commonly used and compatible with generic readers. However, this right does not apply where its exercise would adversely affect the rights and freedoms of others.

6. The right to object. You have the right to object regarding the processing of your personal data for specific reasons to your individual situation, but only to the extent that the legal basis for processing is that the processing is necessary: i) to carry out an action in the public interest or in the exercise of any official authorities invested or; (ii) for the legitimate interests pursued by us or by a third party. In such a case, we will cease processing your personal data unless we can demonstrate legitimate compelling legitimations of processing that precede your interests, rights and freedoms or when processing is intended to establish, exercise, and defend legal claims.

You also have the right to object the processing of your personal data for direct marketing purposes. If you raise such an objection, we will cease processing your personal data for that purpose.

7. The right to withdraw consent. To the extent that the legal basis for data processing arises from your consent, you have the right to withdraw at any time from that consent.

If you withdraw your consent, we will cease processing your personal data, unless and to the extent that continued processing is permitted or required in accordance with applicable data protection laws or other laws and regulations that apply in this context. Your withdrawal of your consent will not in any way affect the legal basis on which processing was made prior to the withdrawal of the consent.

If you will refrain from providing the necessary consent or if you later withdraw from these consents, this may result in the fact that you will no longer be able to use a part of our services.

8. The right to complain to the supervisor authority. You have the right to file a complaint at any time with the local data protection supervisor. You may submit a consumer complaint to the Federal Trade Commision (FTC).

Headquarters: 600 Pennsylvania Avenue, NW

Washington DC, 20580

Phone: (202) 326-2222

Website: www.ftccomplaintassistant.gov

We do our best to ensure that we protect your personal data, inform you about the way we process your personal data and comply with the applicable data protection regulations.

If you are dissatisfied with the processing and protection of your personal data or the information we have provided you, we encourage you to notify us in this regard in order to improve our services. Please also contact us without hesitation when you want to exercise your rights.

Please contact us through the contact details listed at the beginning of the document. Also, please provide us with the relevant information for processing your request, including your full name and email address, so we can identify you. We will handle your request without undue delays.

You can withdraw at any time from a consent to receive newsletters etc. and you can unsubscribe from an email list following instructions from any email or communication received from us.

How is your data stored?

The processing of personal data is done by automatic/manual means, in compliance with the legal requirements and under conditions that ensure the security, confidentiality and respect of the rights of the data subjects.

All documents containing personal data are registered and follow the rules of storage, processing, multiplication, transportation, transmission, destruction and archiving established by the legal regulations in force and by internal procedures.

The processing of personal data is done in accordance with the following principles:

a) LEGALITY, EQUITY AND TRANSPARENCY. The data are processed legally, fairly and transparently to the data subject;

b) PURPOSE-LIMITATIONS. The data are collected for determined, explicit and legitimate purposes and are not subsequently processed in a way incompatible with these purposes;

c) DATA MINIMIZATION. The processed data must be appropriate, relevant, and limited to what is required in relation to the purposes for which it is processed;

d) ACCURACY. The data processing must be accurate and, if necessary, the data must be updated; all necessary steps shall be taken to ensure that personal data which are inaccurate, considering the purposes for which they are processed, are erased or rectified without delay;

e) STORAGE RESTRICTIONS. The processed data will be kept in a form that permits the identification of the data subjects for a period that does not exceed the period necessary for the fulfillment of the purposes for which the data are processed;

f) INTEGRITY AND CONFIDENTIALITY. The data will be processed in a way that ensures the adequate security of personal data including protection against unauthorized or unlawful processing and loss, destruction or accidental damage by taking appropriate technical or organizational measures.

How do you access your data?

You can unsubscribe from the newsletter by selecting the unsubscribe option from the bottom of any newsletter sent.

For any questions or requests relating to personal data that you have transmitted to us, including the exercise of your rights, as mentioned in the previous section (eg. request personal copy, change, delete), you can contact us at info@allfriends.co.

All Friends will provide information in electronic format whenever possible, unless you request another format.

The information provided, as well as any communication and measures taken in your exercise of the above rights, are provided by the All Friends free of charge. However, if your claims are unfounded or excessive, in particular because of their repetitive nature, the All Friends may: (i) either charge a fee based on administrative costs for providing the information or communication, or for taking the required measures; (ii) refuse to comply with the request.

Thank you!

By accepting this agreement, your personal data will be processed by All Friends in accordance with this Privacy Policy.