Introduction 1.1 This Privacy Policy explains how Affina Ltd ("Affina", "we", "us") handles your personal data. It outlines the types of information we collect, how we use it, and how long we retain it. This policy applies to all personal data collected during interactions with Affina Ltd, including trading, communication, and other exchanges.
How We Process Your Data 2.1 Affina Ltd processes your data for various purposes, ensuring compliance with data protection regulations. We handle your data if you are a customer, member, or event participant. Information is typically sourced directly from you and processed only for the duration necessary to fulfill its purpose. Below are the specifics of our data processing practices: 2.1.1 Membership When you become a member of Affina Ltd, we collect and use your personal information to manage your membership (GDPR art. 6(1)(b)). This includes your name, address, email, phone number, date of birth, and payment details. We retain this data for the duration of your membership and up to six years after its termination by the Accounting Act. 2.1.2 Website Usage We use cookies to collect personal data to enhance the website's functionality and user experience. This data collection occurs only with your consent, which can be withdrawn anytime. Details are available in our Cookie Policy. Our website features social media plugins that collect data if you consent. We share joint data responsibility with these social media platforms. We collaborate with advertising platforms to monitor your website interactions through behavioral metrics, heatmaps, and session replays. This data helps improve and market our products/services, optimize site performance, and ensure security. It is collected via first and third-party cookies and other tracking technologies. When you contact us via rn@affi.today or other @affi.today emails, we collect your name, email address, and inquiry details to respond appropriately. This information is deleted six years after our final response unless another legitimate purpose for processing exists. 2.1.3 Mobile App Using the AffiCoach app involves processing your data for standard operations. Members can upload a profile picture and name within our community, which can be deleted upon request. 2.1.4 Event Participation When you register for our events, we collect your name, phone number, email, date of birth, address, and payment information to manage your participation (GDPR art. 6(1)(b)). In accordance with the Accounting Act, this information is stored for up to six years after the Event. 2.1.5 Newsletter Subscription If you subscribe to our newsletter, we process your name and email to send you newsletters and marketing content (offers to purchase goods and services, participate in events and other opportunities of Affina and partners) based on your consent (GDPR art. 6(1)(a)). You can withdraw your consent anytime by contacting rn@affi.today or using the unsubscribe link in the newsletter. We retain evidence of your consent for six years after you unsubscribe. 2.1.6 Job Applications When you apply for a job at Affina Ltd, we process your data to evaluate your suitability for current or future positions (GDPR Article 6(1)(b)). This includes your name, contact information, date of birth, work and educational history, and references. We may also use data from your social media profiles or personality/proficiency tests if it outweighs your interest in non-processing. We will seek your consent to store your data beyond the recruitment process. 2.1.7 Suppliers and Partners We collect contact information when entering agreements with suppliers and partners. This includes names, positions, phone numbers, emails, and payment details. This processing is necessary for agreement fulfillment (GDPR Article 6(1)(b)) or is based on legitimate interests (GDPR Article 6(1)(f)). Contact information is stored for the duration of collaboration, and correspondence is deleted continually, with compliance-related data kept for up to six years.
Legal Basis for Processing 3.1 We process your data based on legal requirements, agreements, or claims that need to be met to fulfill our services. Providing this data is essential for us to offer our services. Without it, we may not be able to provide the requested services.
Data Sharing 4.1 We treat your personal data confidentially and generally do not share it with third parties unless you consent, there is a legitimate interest, or we are legally obliged. 4.2 We may share your data with our system suppliers (data processors), who process it on our behalf under specific instructions. 4.3 Some of our data processors and social media platforms, with which we share data responsibility, may be outside the EU. In such cases, we ensure a legal transfer basis, including EU Commission Standard Contractual Clauses (SCCs).
Your Rights 5.1 You have several rights regarding your data under personal data regulations. These include the right to access, correct, delete, restrict, or object to our processing of your data and the right to data portability. 5.2 If you have provided consent for data processing, you can withdraw it anytime. 5.3 These rights may be subject to conditions and limitations. A concrete assessment will determine whether you can request the deletion of your data.
Our Contact Details Affina Ltd 167-169 Great Portland Street, London, UK, W1W 5PF 6.1 For any questions about our data processing practices, please contact us at rn@affi.today.
Policy Updates 7.1 We reserve the right to update and modify this Privacy Policy. Significant changes will be communicated via email or a visible notice on our website. 7.2 This Privacy Policy was last updated on 1 August 2024.
