EU Privacy Notice

Last Modified: July 2024 

Contents

1.SCOPE OF THE PRIVACY NOTICE

2.PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

3.HOW, FOR WHICH PURPOSES, AND ON WHICH LEGAL BASES WE USE YOUR PERSONAL INFORMATION

4.HOW WE DISCLOSE PERSONAL INFORMATION

5.CONTROL OVER YOUR INFORMATION

6.SECURITY OF YOUR PERSONAL INFORMATION

7.RETENTION OF YOUR PERSONAL INFORMATION

8.INTERNATIONAL TRANSFER OF YOUR PERSONAL INFORMATION

9.YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

10.THIRD-PARTY WEBSITES AND SERVICES

11.CHANGES TO THIS PRIVACY NOTICE

12.CONTACT US

13.ADDITIONAL NOTICE FOR THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM

ANNEX 1

Welcome to SF Express! This Privacy Notice is designed to help you understand what personal information we collect, why we collect it, how we use it, and how you can manage your information with us. When we use the term "personal information" in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. 

1.SCOPE OF THE PRIVACY NOTICE

When we use the terms "SF Express", "we", "us", or "our" in this Privacy Notice, we are referring to the data controller including itssubsidiaries, affiliates and branches. When we use the term "Service" or "Services", we are referring to all of the services and product offerings that we offer as a controller, including our express and logistics services, our physical stores, the website www.sf-international.com/ and its subsites (the "Websites"), the SF INTERNATIONAL App and any other SF Express product, service or website that posts or links to this Privacy Notice. 

Entity acting as Data Controller: For purposes of applicable data protection laws, the "data controller" (or similar term under applicable laws) is the entity referred to in the CONTACT US section. This entity is generally responsible for and controls the processing of your personal information collected through your use of our Services.

If you are located in the European Economic Area (“EEA”) that includes the European Union (“EU”), or in the United Kingdom (“UK”), please see the Additional Notice for Europe for additional European-specific privacy information, including what constitutes your personal information, the lawful bases we rely on to process your personal information, and your rights in respect of your personal information.

Our Services may use cookies and similar tracking technologies ("Cookies"). Our processing activities in connection with Cookies, including information on the data collected and the purposes of use, are set out in our Cookie Notice. 

2.PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT 

When you use our Services, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services and sometimes, we collect the personal information directly from you. At times, we may collect personal information about you from third parties.

Personal Information You Provide 

We may collect the following personal information you provide in connection with our Services:

• Customer Account Data. If you create an online customer account for our Websites, we collect information on your country, either your email address or your mobile phone number, and your account password. Additionally, you may also provide a user name, your birthday, gender.
• Payment and Transaction Information. If you purchase or sign up for one of our Services requiring payment, we collect the information which you may provide in connection with such payment, such as transaction-related information (i.e., payment date, amount) but no credit card or bank account numbers.. Please note that you may choose to use third party payment processors (e.g.,SF Financial, Alipay, WeChat Pay, Unionpay, NetsUnion) to process payments made to us. As such, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice. We will only receive transaction-related information without any credit card numbers. If custom billing is arranged, the customer account user name, customer's name, address, GST or VAT number, and billing amount will be collected as well. 
• Contractual Information. If you order any products or Services from us, we will collect first and last name, company name (if applicable), (business) address, email address, (business) phone number, additional business information (if applicable), and payment information. If the ordered services involve identity verification or include conducting export and import customs declarations for you, we will also collect the information on identity documents and, if required, e.g., for customs declarations, additional contact information of the sender and recipient (phone number, email address, etc.). To the extent we offer respective additional services, we may also collect information on pickup and/or delivery preferences, any further preferences, or any other additional services selected.
• Logistics Services. If you order shipping services as the sender or are the recipient of a shipment, we collect your name, address, email address (optionally if you are the recipient), and optionally your mobile phone number ("Waybill Information"). 
• Contact Information. When you contact us through any method of communications, including through our Websites' "Contact Us" function or our customer service robot, we may collect information from you regarding the relevant product or service, subject of your inquiry, area of interest, company, contact name, email, (mobile) phone number, full address, Customer Account Data, what prompted the inquiry, and contents of your inquiry. Depending on the method of contacting us, we may automatically collect certain additional technical information, such as the time the communication was sent, device specifications and IP address. If you contact us via phone, we may additionally record the conversations. If you use the speech input function of our customer service robot, we additionally collect your audio recording.
• Address Book Function. The "Address Book" feature in the SF INTERNATIONAL App will automatically save any address which you have used in your orders and allows you to save further addresses. The addresses saved in the Address Book can be retrieved for future orders. When you use this feature, we will collect the information entered into the Address Book. Additionally, the Address Book allows you to grant permission to automatically recognize your current location or to take and/or upload a photo of a written address to save the respective address. In that case, we will collect your current geographical location or the uploaded photo respectively.
• Market Survey Results, Feedback and Opinions. We may collect information contained in results of market surveys which we conduct, such as surveys for determining net promoter scores (i.e., the metric about the likelihood of survey respondents to would recommend our Services). When you contact us directly via our agents or call center for sharing your feedback or opinions, we will record your comments and opinions. When you contact us via phone, we will also record the phone call itself. 
• Newsletter and Marketing Messages. If you sign up to receive news or marketing messages (e.g., via mail or SMS) from us, we may collect your name, email address or mobile phone number, and company name (if applicable). We also collect certain tracking information, such as opening and click rates.
• Business Cooperations. If you are maintaining a business cooperation with us, e.g., as a supplier or vendor, we may collect information regarding your company, first and last name, the relevant cooperation project, business address, email address, business phone number, additional business information, and payment information.
• Business Cooperation Inquiries. If you submit inquiries on business cooperations with us, we will collect information regarding your company, first and last name, business address, email address, business phone number, and the contents of your inquiry.
• Video-surveillance footage. Our physical stores are secured by video-surveillance. When you visit our physical stores, we will collect video footage of your visit. 
  
  

Our Services are designed and intended for use by adults. We will not knowingly collect any personal information from or about children under the age of 13 or the minimum age allowed in your jurisdiction. If you believe that your child has provided us with his / her personal information, please contact us via the email address provided in the CONTACT US section, and we will take steps to delete such personal information as soon as possible.

Personal Information Automatically Collected 

We and our third-party providers and partners collect certain personal information automatically when you visit, interact with, or use our Services:

• If you use our Websites, the SF INTERNATIONAL App or interact with our emails, we may collect log data. Such data includes yourinternet protocol (IP) address, operating system, browser details (such as type, ID, and configuration), unique identifiers, device type and version, the referring URL, date/time of your visit, the time you spent on our Services and any errors that may occur during your visit to our Services.
• Web Analytics. In addition to the technical data above, we collect certain analytical data, such as which products and services you visited, type of usage, and certain actions that help us understand the way you use our products and services.
• Cookie Information. To the extent we collect personal information via Cookies, please see our Cookie Notice.
• Security Information (such as captcha). We automatically collect certain information that we need to secure our Services, such as yourinternet protocol (IP) address, operating system, browser details (such as type, ID, and configuration), unique identifiers, device type and version, the referring URL, date/time of your visit, your WeChat ID (if you use our Services via WeChat), the time you spent on our Services, certain movements or patterns, if you can solve simple security questions (such as mathematical questions or detecting certain things in pictures and any errors that may occur during your visit to our Services)
• Map Function. When you use map functions of our Services to locate our service points and to use navigation functions, we collect information on your geographical location.
• Camera Functions. If you use camera-based functions of our Services, e.g., for scanning QR codes to complete shipments or payments, we collect the visual information provided via your camera.
  
  

Personal Information from Other Sources and Third Parties

We may also obtain personal information from third parties, which we may combine with personal information we collect either automatically or directly from an individual.

We may receive personal information from the following third parties:

• SF Express Entities. We may receive personal information from other companies owned or controlled by or under common control with the data controller.
• Partner Entities. If our business partners collaborate with us, they may disclose to us your name, phone number, email address, company name and address, opportunity/interest details of your or your company, information about outstanding payments, and information if you or your company is a current customer of our partner.
• Social Media. When you interact with us through various social media networks, such as when you "Like" us on Facebook or follow us or share our content on Facebook, Twitter, Instagram or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive depends on your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
• Connection with Third-Party Services. If you use functions of connecting your SF Express customer account with your account for third-party services (e.g., to enable login to your SF Express customer account via third-party accounts), we will collect information shared by the respective third-party, e.g., profile pictures, user names, and contact information. If you place a shipping order via a third-party website or channel, (we will collect the Waybill Information from the third-party website or channel.
• Service Providers. Our service providers that perform services solely on our behalf, such as chat services, payout processing, and marketing providers, collect personal information and often share some or all of this information with us.
• Your Employer. If you work for one of our customers, we may receive certain personal information about you from them to enable you to purchase and use our products and services. Such personal information may include your name, title, contact details (email address, phone), username and usage data

3.HOW, FOR WHICH PURPOSES, AND ON WHICH LEGAL BASES WE USE YOUR PERSONAL INFORMATION

The reasons for the processing of your personal information may differ depending on the purpose of collection. In general, we process your personal information for the following purposes and on the following legal grounds:

The processing of your personal information is necessary for the performance of a contract with you or to take steps at your request prior to entering into the contract. This may include processing to

• to deliver the services you have requested, and for account and contract management (including customer support);
• process payment for our services;
• correct faulty recipient addresses, which you may have provided accidently, for ensuring reliable shipment.
  
  

The processing of your personal information is necessary for the purposes of our legitimate interests. This may include processing to

• review our business performance;
• test, enhance, update and monitor the Services, or diagnose or fix technology problems; 
• help maintain the safety, security and integrity of our property, physical stores, Services, technology assets and business;
• enforce our contractual rights, including without limitation, and to the extent applicable, the SF Express Terms and Conditions, any addenda thereto or other applicable terms; 
• resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties;
• prevent, investigate or provide notice of fraud or unlawful or criminal activity.
  
  

The processing of your personal information is based on your consent. This applies to certain limited circumstances and may include processing to

• market our Services to businesses and individuals, including through email, notifications via the SF INTERNATIONAL App, notifications via our official WeChat account, or SMS;
• administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services and analyzing our customer base;
• conduct market research;
• opportunity tracking, conversion and lead generation.
  
  

The processing of your personal information is necessary for compliance with our legal obligations, for example if we are required to retain certain information due to statutory law.

4.HOW WE DISCLOSE PERSONAL INFORMATION

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as described below. 

• Service Providers: We share personal information with third party contractors and service providers subject to reasonable confidentiality terms. The services provided on our behalf by such third-party contractors and service providers may include processing payments, providing web hosting and maintenance services, technology support providers, email communications providers, analytics providers, data storage providers, and web and video hosting providers and developers. Any such third-party contractors and service providers will be bound to only process the data on our behalf and under our instructions, unless such service providers act as their own controllers (e.g., if we seek advice from lawyers and tax consultants).
• SF Express Affiliates: We may share personal information with other companies and brands owned or controlled by SF Express, and other companies owned by or under common ownership as the data controller.If our affiliates refer to this Privacy Notice, these companies will use your personal information in the same way as we do in accordance with this Privacy Notice.
• Business and Marketing Partners: We may also disclose personal information with other business and marketing partners with whom we jointly offer products or services, or who are part of our partner program. We may obtain your consent where required by applicable law. Our business and marketing partners will use your information in accordance with their own privacy notices. 
• Corporate Transactions: We may transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in the company) or any portion or combination of our products, services, businesses and/or assets. Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, change of control or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Notice.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement agencies, regulators, other authorities and other third parties for legal reasons if we reasonably believe that such action is necessary:

• in connection with the establishment, exercise, or defense of legal claims;
• to comply with laws or to respond to lawful requests and legal process; 
• to protect our rights and property and the rights, personal safety and property of others, including to enforce our agreements and policies;
• to detect, suppress, or prevent fraud or other criminal activity; or 
• as otherwise required by applicable law.

• With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Websites or service-related publications. Please note, that any comments, reviews, or testimonials posted publicly on our Websites may be read by any interested party, for as long as they are public.

5.CONTROL OVER YOUR INFORMATION

• Email communications. From time to time, we may send you emails regarding updates to our Services, notices about our organization, or information about products/services we offer that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the "unsubscribe link" provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related communications (e.g., account verification, confirmations of transactions, technical or legal notices). 
• SMS Text Messaging. We may use personal information we collect to communicate with individuals via text message, including (with your consent) to market to you or offer you information and updates on products or services we think you may be interested in. You can unsubscribe from marketing text messages at any time with effect for the future by replying STOP or clicking the unsubscribe link (where available) in one of our messages. 
• SF INTERNATIONAL App Notifications. Via the SF INTERNATIONAL App, we may send you notifications on shipment and payment status as well as, from time to time, marketing notifications. You may deactivate such notifications in the account settings provided in the SF INTERNATIONAL App.
• Customer Account. If you have an online customer account with us, you can modify certain information in your account (e.g., your contact information) through the account options provided on our official websites and in the SF INTERNATIONAL App. Not all personal information is maintained in a format that you can access or change. If you would like to request access to, or correction or deletion of personal information, you may send your request to us at the email address provided under "CONTACT US". 

You may delete your customer account through the account deletion function provided on our official websites and in the SF INTERNATIONAL App.

6.SECURITY OF YOUR PERSONAL INFORMATION

We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting credit or debit card information. 

7.RETENTION OF YOUR PERSONAL INFORMATION

We will retain your personal information only as long as necessary for the fulfillment of the purposes for which it was collected, including for the purposes of our legitimate interests, or according to statutory law.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements. 

8.INTERNATIONAL TRANSFER OF YOUR PERSONAL INFORMATION

The personal information we collect may be transferred to and stored in countries where we and our third-party service providers have operations, which may be outside your country of residence. 

Where required under the applicable laws, we will ensure that international transfers of your personal information are made pursuant to appropriate safeguards. 

9.YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

In accordance with applicable privacy laws, you may have the following rights in respect of your personal information that we hold:

• Right of access. You have the right to obtain information about our processing of your personal information, in certain cases, including a copy of the personal information we hold about you.
• Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
• Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay. 
• Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay, such as if the continued processing of that personal information is not justified. 
• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information, such as where the accuracy of the personal information is contested by you.
• Right to withdraw consent. There are certain circumstances where we require your consent to process your personal information. In these instances, and if you have provided consent, you have the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal. 
• Right to object. You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason at any time.

If you wish to exercise one of these rights, we kindly ask you to contact us using the details set out under “CONTACT US“.

You also have the right to lodge a complaint to your local data protection authority. However, we encourage you to first contact us so that we can together solve any concerns you may have. 

Due to the confidential nature of data processing, we may ask you to provide proof of identity when exercising the above rights.

10.THIRD-PARTY WEBSITES AND SERVICES

The Services may contain integrations or links to third-party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party and not SF Express. Please note that SF Express is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the privacy notices and online terms of those third parties to learn more about how they handle your personal information.

11.CHANGES TO THIS PRIVACY NOTICE 

We reserve the right to change this Privacy Notice from time to time in our sole discretion. We will notify you about material changes in the way we treat personal information by placing a prominent notice on the applicable Website, or through other appropriate communication channels. It is your responsibility to review this Privacy Notice periodically. All changes shall be effective from the date of publication unless otherwise provided.

12.CONTACT US 

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to [joeyxie@sf-express.com] or contact us under the following contact details:  

S.F. Express Co., Ltd. 

Shenzhen Software Industry Base

Xuefu Road 

Hi-tech Industrial Park South 

Shenzhen, 518054 

P.R. China

13.ADDITIONAL NOTICE FOR THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM 

SF Express maintains operations in Europe and may direct its services to individuals located in the EEA and the UK. In these instances, the following disclosures apply to our processing of personal data.

When we use the term “personal data” in this section, we mean information relating to an identified or identifiable natural person as defined applicable law.

a.CONTROLLERS 

• EEA: If you are located in the EEA, the following entity is the controller of your personal data:

SF Express (NL) B.V.

Jachthavenweg 109-H, 1081 KM

Amsterdam

Netherlands

• UK: If you are located in the UK, the following entity is the controller of your personal data:

SF Express (Europe) Co., Ltd

Suite 1, 1 Heathrow Boulevard, 286 Bath Road

London, UB7 0DQ

United Kingdom 

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to [joeyxie@sf-express.com] if you are located in the EEA or UK, or contact us under the above contact details.

b.LEGAL BASES FOR THE PROCESSING

Regularly, we use your personal data based on the following legal grounds according to the Regulation (EU) 2016/679 (the "EU GDPR") or, where applicable, the "UK GDPR" as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the UK European Union (Withdrawal) Act 2018 GDPR:

Performance of our contractual services or taking steps prior to entering into a contract with you: If you order Services from us or if you contact us to request our Services, we use your personal data to provide you with these Services, including for account and contract management, to facilitate user benefits and services, including customer support. 

Justified by our legitimate interests: The usage of your personal data may also be necessary for our own business interests. For example, we may use some of your personal data to send you gifts; market our Services to individuals; administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services and analyzing our client-base; process payment for our Services; conduct market research; opportunity tracking, conversion and lead generation; test, enhance, update and monitor the Services, or diagnose or fix technology problems; help maintain the safety, security and integrity of our property, physical stores, Services, technology assets and business; enforce our Terms and Conditions; resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties; and prevent, investigate or provide notice of fraud or unlawful or criminal activity. 

Consent: In some cases, we may ask you to grant us separate consent to use your personal data. 

Compliance with legal obligations. We are obligated to retain certain personal data because of legal requirements, for example, tax or commercial laws, or we may be required by law enforcement to provide personal data on request.

We do not use your personal data for automated individual decision-making.

You can find more information on the legal bases in the table in ANNEX 1.

c.HOW LONG WILL WE STORE YOUR PERSONAL DATA

We will usually store the personal data we collect about you for no longer than necessary for the purposes as set above, and in accordance with our legal obligations and legitimate business interests. 

The criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:

• Contract. Where we are processing personal data is based on contract, we generally will retain your personal data for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
• Legitimate Interests. Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account your fundamental interests and your rights and freedoms.
• Consent. Where we are processing personal data based on your consent, we generally will retain your personal data until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that personal data.
• Legal Obligation. Where we are processing personal data based on a legal obligation, we generally will retain your personal data for the period of time necessary to fulfil the legal obligation.
• Legal Claim. We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim.  In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data when determining the appropriate retention period. 

d.INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

Where required under the GDPR, we will ensure that international transfers of your personal data are made pursuant to appropriate safeguards, such as: 

1. (i)Ensuring that the personal data is only transferred to countries recognized as offering an equivalent level of protection as compared to the level of protection in the country you are located; or 
2. (ii)the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission or UK Secretary of State (as applicable) in connection with appropriate supplementary measures. The decision and the template text of these standard contractual clauses can be found here; or
3. (iii)the transfer is made pursuant to appropriate safeguards, such as binding corporate rules.
   
   

If you wish to enquire further about these safeguards, including the specific contracts entered into, used, please contact us using the email addresses or the contact details set out in the "CONTROLLERS" section.

e.OBLIGATION TO PROVIDE PERSONAL DATA

Some information, such as your name, address, payment information and information on your requested Services may be necessary for the performance of our contractual obligations. Without providing this information, you might not be able to request or use certain Services or enter into a contract with us. If information is required in one of our forms, we will let you know that this is the case. 

f.YOUR EEA- AND UK-SPECIFIC RIGHTS IN RESPECT OF YOUR PERSONAL DATA

In accordance with applicable privacy law, you may have the following rights in respect of your personal data that we hold:

• Right of access. You have the right to obtain certain information about our processing of your personal data which includes:
• confirmation of whether, and where, we are processing your personal data;
• information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
• information about the categories of recipients with whom we may share your personal data; and
• a copy of the personal data we hold about you.
• Right of portability. See above in the "YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION" section.
• Right to rectification. See reference above under "Right of portability". 
• Right to erasure. See reference above under "Right of portability". 
• Right to restriction. See reference above under "Right of portability".
• Right to withdraw consent. See reference above under "Right of portability". 

RIGHT TO OBJECT. YOU ALSO HAVE THE RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION. THERE MAY BE COMPELLING REASONS FOR CONTINUING TO PROCESS YOUR PERSONAL DATA, AND WE WILL ASSESS AND INFORM YOU IF THAT IS THE CASE. YOU CAN OBJECT TO MARKETING ACTIVITIES FOR ANY REASON AT ANY TIME.

If you wish to exercise one of these rights, we kindly ask you to contact us using the email addresses or the contact details set out in the "CONTROLLERS" section.  

You also have the right to lodge a complaint to your local data protection authority. If you are based in the EU, information about how to contact your local data protection authority is available here. If you are based in the UK, your local data protection authority is the UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/). However, we encourage you to first contact us so that we can together solve any concerns you may have. 

Due to the confidential nature of data processing, we may ask you to provide proof of identity when exercising the above rights.

ANNEX 1

Specifics of the Processing