Website Privacy Policy
Dated: 1 September 2022

1. INTRODUCTION
   
   1.1 Important information and who we are Welcome to Cur8 Earth Limited’s Privacy and Data protection Policy (“Privacy Policy”).

   At Cur8 Earth Limited (“we”, “us”, or “our”) we are committed to protecting and respecting  your privacy and Personal Data in compliance with the United Kingdom General Data  Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws  and regulations of the United Kingdom.

   This Privacy Policy explains how we collect, process and keep your data safe. The Privacy  Policy will tell you about your privacy rights, how the law protects you, and inform our  employees and staff members of all their obligations and protocols when processing data.

   The individuals from which we may gather and use data can include:

• Customers
• Suppliers
• Business contacts
• Employees/Staff Members
• Third parties connected to your customers

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your Data Controller

 

Cur8 Earth Limited is your Data Controller and responsible for your Personal Data. We are  not obliged by the GDPR to appoint a data protection officer and have not voluntarily  appointed one at this time. Therefore, any inquiries about your data should either be sent  to us by email to hello@cur8.earth or by post to 2a The Quadrant, Epsom, Surrey, England, KT17 4RH.

You have the right to make a complaint at any time to the Information Commissioner’s  Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We  would, however, appreciate the chance to deal with your concerns before you approach  the ICO so please contact us in the first instance.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you 

In discharging our responsibilities as a Data Controller we have employees who will deal  with your data on our behalf (known as “Processors”). The responsibilities below may be  assigned to an individual or may be taken to apply to the organisation as a whole. The  Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases  laid out in the GDPR (see 2.2 below for more information);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of  confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of  security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging  another Processor;
• Assist the Controller in the fulfilment of the Controller’s obligation to respond to  requests for exercising the data subject’s rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute  to audits, including inspections, conducted by the Controller or another auditor  mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a  Controller;
• Cooperate, on request, with the supervisory authority in the performance of its  tasks;
• Ensure that any person acting under the authority of the Processor who has access  to Personal Data does not process Personal Data except on instructions from the  Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

 

• LEGAL BASIS FOR DATA COLLECTION
  
  2.1 Types of data / Privacy policy scope
  
  “Personal Data” means any information about an individual from which that person can  be identified. It does not include data where the identity has been removed (anonymous  data).We may collect, use, store and transfer different kinds of Personal Data about you which  we have grouped together below. Not all of the following types of data will necessarily be  collected from you but this is the full scope of data that we collect and when we collect it  from you:

• Profile/Identity Data: This is data relating to your first name, last name, gender, date  of birth.

• Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.

• Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.

• Transactional Data: This is information of details and records of all payments you  have made for our services or products.

• Technical Data: This is your IP address, browser type and version, time zone setting  and location, operating system and platform, and other technology on the devices  you use to engage with us.

• Customer Support Data: This includes feedback and survey responses.

• Usage Data: information about how you use our website, products and services.

We do not collect any Special Categories of Personal Data about you (this includes details  about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,  political opinions, trade union membership, information about your health, and genetic  and biometric data). Nor do we collect any information about criminal convictions and  offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and  processing of Personal Data. The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when  you tick a box that confirms you are happy to receive email newsletters from us, or  ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information from you in order  to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance”: We’re required by law to collect and process certain types of  data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be  able to meet our legitimate interests – this covers aspects that can be reasonably  expected as part of running our business, that will not have a material impact on  your rights, freedom or interests. Examples could be your address, so that we know  where to deliver something to, or your name, so that we have a record of who to  contact moving forwards.

 

• HOW WE USE YOUR PERSONAL DATA
  
  3.1 Our data uses We will only use your Personal Data when the law allows us to.

  3.2 Change of purpose
  
  We will only use your Personal Data for the purposes for which we collected it, unless we  reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the  processing for the new purpose is compatible with the original purpose, please contact us.

  If we need to use your Personal Data for an unrelated purpose, we will notify you and we  will explain the legal basis which allows us to do so.

  Please note that we may process your Personal Data without your knowledge or consent,  in compliance with the above rules, where this is required or permitted by law.

 

 

• YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
  
  4.1 Your legal rights
  
  Under certain circumstances, you have the following rights under data protection laws in  relation to your personal data:

• Right to be informed. You have a right to be informed about our purposes for  processing your personal data, how long we store it for, and who it will be shared  with. We have provided this information to you in this policy.

• Right of access. This enables you to receive a copy of the personal data we hold  about you and to check that we are lawfully processing it (also known as a “data  subject access request”). See section 4.4 below for more details on how you can  make a data subject access request.

• Right to rectification. You have a right to request correction of the personal data  that we hold about you. This enables you to have any incomplete or inaccurate data  we hold about you corrected, though we may need to verify the accuracy of the new  data you provide to us.

• Right to erasure. You have the right to ask us to delete or remove personal data  where there is no good reason for us continuing to process it, where you have  successfully exercised your right to object to processing (see below), where we may  have processed your information unlawfully or where we are required to erase your  personal data to comply with local law. Note, however, that we may not always be  able to comply with your request of erasure for specific legal reasons which will be  notified to you, if applicable, at the time of your request.

• Right to object. You can object to the processing of personal data we hold about  you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:(i) Where we are processing your personal data for direct marketing purposes.

  (ii) Where we are relying on a legitimate interest (or those of a third party) and  there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

  (iii) In some cases, we may continue processing your data if we can demonstrate  that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Right to restrict processing. You have the right to request the restriction or  suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:(i) If you want us to establish the data’s accuracy.

  (ii) Where our use of the data is unlawful but you do not want us to erase it.

  (iii) Where you need us to hold the data even if we no longer require it as you  need it to establish, exercise or defend legal claims.

  (iv) You have objected to our use of your data but we need to verify whether we  have overriding legitimate grounds to use it.

• Right to data portability. You have the right to request the transfer of your  personal data to you or to a third party. If you make such a request, we will provide  to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to  automated information which you initially provided consent for us to use or where  we used the information to perform a contract with you.

If you wish to make a request under any of these rights, please contact us at hello@cur8.earth.

4.2 Your control over Cur8 Earth Limited’s use of your Personal Data 

You may delete your account at any time – this will remove your account page from our  systems and our related software.

We guarantee this will delete all stored data.

Your account information will be protected by a password for your privacy and security.  You need to prevent unauthorised access to your account and personal information by  selecting and protecting your password appropriately and limiting access to your  computer or device and by signing off after you have finished accessing your account.

You can access information associated with your account by logging into your account you created with us.

Your account information will be protected by a password for your privacy and security.  You need to prevent unauthorised access to your account and personal information by  selecting and protecting your password appropriately and limiting access to your  computer or device and by signing off after you have finished accessing your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California  residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes,  and providing contact information for such affiliates and/or third parties. If you are a  California resident and would like a copy of this notice, please submit a written request to hello@cur8.earth.

4.3 How Cur8 Earth Limited protects customers’ Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate  disclosure. Any Personal Data collected by us is only accessible by a limited number of  employees who have special access rights to such systems and are bound by obligations  of confidentiality. If and when we use subcontractors to store your data, we will not  relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission  of data over the internet is guaranteed to be completely secure. It may be possible for  third parties not under the control of Cur8 Earth Limited to intercept or access  transmissions or private communications unlawfully. While we strive to protect your  Personal Data, we cannot ensure or warrant the security of any Personal Data you  transmit to us. Any such transmission is done at your own risk. If you believe that your  interaction with us is no longer secure, please contact us.

4.4 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity  and ensure you have the right to access your Personal Data (or to exercise any of your  other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further  information in relation to your request to speed up our response.

 

• YOUR DATA AND THIRD PARTIES
  
  5.1 Sharing your data with third parties
  
  We may also share Personal Data with interested parties in the event that Cur8 Earth  Limited anticipates a change in control or the acquisition of all or part of our business or  assets or with interested parties in connection with the licensing of our technology.

If Cur8 Earth Limited is sold or makes a sale or transfer, we may, in our sole discretion,  transfer, sell or assign your Personal Data to a third party as part of or in connection with  that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to  enforce our terms or this Privacy Policy.

 

• HOW LONG WE RETAIN YOUR DATA
  
  We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes  we collected it for. We may retain your Personal Data for a longer period than usual in the event  of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

 

• AGE LIMIT FOR OUR USERS
  
  You must not use Cur8 Earth Limited unless you are aged 16 or older. If you are under 16 and  you access Cur8 Earth Limited by lying about your age, you must immediately stop using Cur8 Earth Limited.This website is not intended for children and we do not knowingly collect data relating to children.

   

• INTERNATIONAL TRANSFER OF DATAYour information may be stored and processed in the US or other countries or jurisdictions outside the US where Cur8 Earth Limited has facilities. By using Cur8 Earth Limited, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.

• NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
  
  We keep our Privacy Policy under review and will place any updates here. This version is dated 1 September 2022.By using Cur8 Earth Limited, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Cur8 Earth Limited will constitute your express acceptance of any modifications to this Privacy Policy.

 

INTERPRETATION

All uses of the word “including” mean “including but not limited to” and the enumerated  examples are not intended to in any way limit the term which they serve to illustrate. Any email  addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with  or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorised to contract on behalf of Cur8 Earth Limited, waive rights or make  representations (whether contractual or otherwise). If anything contained in an email from a  Cur8 Earth Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Cur8 Earth Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Cur8 Earth Limited legal department.