This Privacy Notice describes the manner in which Phast Marketing Limited (hereinafter to be referred to as “Phast”, “we”, “us” or “our”) collects, processes, uses, and protects the personal information you provide when you access or use our www.phastmarketing.com website (“Website”).
Phast is committed to safeguarding your privacy. Any information that may identify you and that is requested in connection with your use of the Website will be collected, used, and protected in accordance with the terms of this Privacy Notice.
We reserve the right to amend this Privacy Notice from time to time by publishing an updated version on this page. You are encouraged to review this Privacy Notice periodically to ensure that you remain informed of any changes. Any updates will be reflected by the “Last Updated” date indicated in this Privacy Notice.
DEFINITIONS
“Personal Data” refers to any information relating to a living individual who can be identified, whether directly or indirectly.
“Controller” refers to any natural or legal person, public authority, agency or other body that, acting alone or together with others, determines the purposes for which Personal Data is processed and the means by which such processing takes place. For the purpose of this Privacy Notice, the Controller is Phast Marketing Limited, a company duly incorporated under the laws of Seychelles.
“Processing” refers to any operation, or combination of operations, carried out in relation to Personal Data or collections of Personal Data.
WHICH DATA WE COLLECT
When you access or use the Website, we may collect and process the following categories of information:
- Your name, job title, and the name of the company or organization you represent;
- Your contact details, including your email address;
- Information relating to your preferences and interests;
- Information relevant to customer surveys or promotional offers;
- Any information you choose to provide while using the Website;
- Your employment history and the information contained in your CV, including details relating to your education and referees, where you submit an application for a job vacancy through the Website;
- The IP address from which you access the Website.
HOW WE PROCESS THE INFORMATION WE GATHER
We process your Personal Data to better understand your requirements and enable us to provide and improve our services. In particular, we may process your Personal Data for the following purposes:
- Maintaining our internal records;
- Improving our services and enhancing the functionality of the Website;
- Sending you, where you have given your consent, promotional emails regarding new products, special offers or other information that may be of interest to you, using the email address you have provided;
- Conducting market research activities;
- Assessing and processing applications for employment submitted to us;
- Personalizing your experience on the Website based on your interests; and/or
- Providing you with access to our online client portal, where available.
- Data protection legislation requires us to have a valid legal basis for each instance in which we collect, use, disclose, or otherwise process your Personal Data.
We may process your Personal Data on the basis of one or more of the following lawful grounds:
Your consent, where you have agreed to the processing of your Personal Data for a specific purpose; and/or
Our legitimate interests in providing information and delivering our services in an effective and efficient manner.
The table below explains the purposes for which we process your Personal Data, the lawful basis on which we rely, and, where applicable, the legitimate interests pursued.
| Purpose of Personal data collection | Grounds / reasons | Legitimate interest |
|---|---|---|
| Maintaining internal records | Our legitimate interests | Developing our products and services, including determining appropriate pricing |
| Personalizing the Website based on your interests | Your consent | Enabling you to access and make use of the Website and its functionality |
| Improving our products and services | Your consent | Identifying the products and services that may be relevant to you and providing you with information about them |
| Sending you periodic promotional emails about new services, special offers, or other information that may be of interest to you using the email address you have provided | Our legitimate interests | Identifying the products and services that may be of interest to you and communicating information about them |
| Contacting you from time to time for market research purposes | Your consent | Better understanding customers' profiles for the development of new products or services |
| Using Cookies on the Website (please refer to the section ‘How we use cookies') | Your Consent | Enabling the effective operation of the Website and allowing you to benefit from its features |
| Complying with our legal and regulatory obligations | Our legitimate interests | Meeting the legal and regulatory requirements applicable to the jurisdictions and industries in which we operate. |
DATA SECURITY
We are committed to protecting the security of your information. To help safeguard the information we collect, we implement appropriate technical, physical, and organizational measures, including:
Providing secure methods for the transmission of personal and company information;
Restricting access to your information to employees and third parties who require it for authorized purposes; and
Maintaining appropriate physical, electronic, and administrative safeguards to protect the information collected through the Website.
You can also help protect your information by:
Making use of the security features available within your web browser; and
Verifying that the Website is using a secure connection by checking that the URLs begin with https:// rather than the normal http:// and by looking for your browser’s security indicator (such as a padlock icon) before submitting any information.
GOVERNING LAW
The provisions of this Privacy Notice are subject to the laws of Seychelles and shall be interpreted in accordance with those laws. Any dispute relating to this Privacy Notice, or resulting from your access to or use of the Website, shall be submitted exclusively to the competent courts of Seychelles.
YOUR DATA PRIVACY RIGHTS
You have specific rights regarding the Personal Data that we process about you. However, depending on the applicable data protection legislation, these rights may not apply in every situation or to all categories of Personal Data that we process. Where applicable, you may request that we:
Allow you to access the Personal Data we hold about you;
Correct or update any Personal Data that is inaccurate, incomplete, or no longer current;
Remove Personal Data relating to you, where permitted, subject to any legal or regulatory requirements that oblige us to retain certain information for a specific period;
Limit or restrict the manner in which we process your Personal Data;
Review and take into account any legitimate objections you submit regarding our processing of your Personal Data; and/or
Transfer certain Personal Data that you have provided to us to another service provider upon your request (data portability).
You may also control the collection and use of your Personal Data in the following ways:
When completing any forms available on the Website, you may choose not to provide the requested information;
When you have previously provided consent for your Personal Data to be used for direct marketing purposes, you may withdraw that consent at any time by contacting us in writing or by email using the consent at any time by contacting us in writing or by email using the contact details provided below; and/or
If you wish to obtain a copy of the Personal Data we hold about you, you may submit a request by emailing us at: contact@phastmarketing.com.
If you require any changes, corrections, or updates to your Personal Data, please contact us by email. We will make reasonable efforts to update our records as soon as practicable and, in any event, no later than 7 days after receiving your request.
REQUEST OF PERSONAL INFORMATION
You have the right to request access to Personal Data that we hold about you. Any request to access your Personal Data may be submitted and will be handled in accordance with the applicable data protection laws. To make such a request, please contact us at contact@phastmarketing.com.
SHARING DATA WITH THIRD PARTIES
We may share your Personal Data with companies within our corporate group, affiliated entities, and selected service providers or vendors where necessary.
Your Personal Data may also be disclosed to third parties in the following circumstances:
Where we, or a significant part of our business or assets, are acquired by another entity, in which case Personal Data held about our customers or Website users may form part of the transferred assets;
Where disclosure is required to comply with any applicable legal or regulatory obligation;
Where necessary to enforce or apply the terms of this Privacy Notice or any other agreement;
Where required to protect our rights, property, safety, or the rights, property, or safety of our customers or other individuals; and/or
Where you have provided your consent for such disclosure.
We do not disclose your Personal Data to third parties for marketing purposes unless we have obtained your prior explicit consent.
Where we transfer Personal Data to recipients located outside the jurisdiction in which the information was originally collected, we will take reasonable measures to ensure that such Personal Data continues to receive an appropriate level of protection. Such measures may include, where applicable:
Appropriate contractual safeguards;
Internal data protection measures; or
Any other safeguards considered suitable under the applicable data protection laws.
For the avoidance of doubt, we will only transfer Personal Data to other entities within our corporate group or third parties where appropriate safeguards are in place and where such transfer is permitted under applicable data protection legislation. Any transfer of Personal Data requiring your consent will only be carried out after obtaining such consent.
DIRECT MARKETING
By providing your consent to this Privacy Notice and choosing to receive communications from us, you agree that we may contact you with marketing and promotional information. Such communications may be delivered through online channels or other methods, including email. You may withdraw your consent and stop receiving such communications at any time by contacting us at: contact@phastmarketing.com. You may also unsubscribe from promotional communications by following the opt-out instructions or link included in each communication.
THIRD PARTY WEBSITES
The Website may include links to third-party websites that may be of interest to you. Please note that once you access any such external website, we no longer have control over its content, security practices, or privacy procedures. Accordingly, we are not responsible for the protection of information or privacy practices applied by third-party websites that you may visit through links provided on our Website. These websites are not covered by this Privacy Notice, and we recommend that you review the privacy notices or statements applicable to any third-party website before providing them with your information.
DATA RETENTION
We retain Personal Data only for the period necessary to fulfil legitimate legal or business purposes. When determining the appropriate retention period, we consider applicable local laws, contractual requirements, and the reasonable expectations and needs of our customers and Website users. Once Personal Data is no longer required, we will securely delete or dispose of it. When you have submitted an employment application and have not been successful, we may offer you the opportunity to allow us to retain your information in our talent pool for a period of six months. If you agree to this, we may contact you should a suitable employment opportunity become available.
OUR CONTACTS
If you have any questions, comments or requests concerning the protection of your Personal Data, please contact us by email at contact@phastmarketing.com.
If you are dissatisfied with any aspect of this Privacy Notice or with the manner in which we process your Personal Data, you have the right to submit a complaint. We encourage you to contact us first so that we may address and resolve any concerns you may have.
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