1.
Introduction
We respect your privacy, and we are
committed to protecting your personal data. This Privacy Notice applies to the
processing of personal data by Foris DAX Middle East FZE (“Crypto.com”, “we”,
“us”, “our”) in connection with:
·
use of any of our products,
services or applications (together the “Services”),
·
visit or use of our website
including the Exchange subdirectory (“Sites”) or, main mobile application
(“Crypto.com App”) or exchange mobile application (“Crypto.com Exchange App”)
(together, the “Apps”).
Please
note that our Services, Sites and Apps are not intended for minors below 18 years of
age and we do not knowingly collect data relating to minors.
For services provided
by other Crypto.com companies, please carefully
read the respective privacy notice or policy
available on the Sites or in the Apps.
2. Purpose
This
Privacy Notice aims to give you information on how we collect and process your personal
data.
This Privacy Notice informs you about your privacy rights
and how the data protection principles set out in the Federal Decree-Law No. 45
of 2021 On the Protection of Personal Data (“Data Protection Code”)
of the United Arab Emirates
outside any of the UAE financial free zones (“UAE”) protect your personal data.
It is
important that you read this Privacy Notice together with any other notice we may provide
on specific occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your data. This Privacy Notice
supplements other notices and is not intended to override
them.
Please note that all or part of our Services
may not be available in your region.
3. Who we are
Data Controller
The controller of your personal data
is the legal entity that determines the purposes, conditions and manner
of any processing activities that it carries
out. Foris DAX Middle East FZE is the data controller and is responsible for
the processing of your personal data.
Foris
DAX Middle East FZE is established as a Free Zone Establishment in the Dubai
World Trade Centre fee zone
in the Emirate of Dubai, the United Arab Emirates, with limited liability (“we”
or “us”), with company registration number 2125 and registered address at: the
8th floor, offices 4, One Central, Dubai World Trade Centre, Dubai, United Arab
Emirates.
Data Protection Officer
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy
Notice. If you have any questions or complaints related to this Privacy Notice or our privacy
practices, or if you
want to exercise your legal rights, please contact our
DPO at
[email protected].
Complaints
You have the right to make a complaint to the UAE Data Office
about the way we process
your personal data. The UAE Data Office is the UAE supervisory authority for data protection issues.
We
would, however, appreciate the chance to deal with your concerns before you approach the UAE Data Office or other relevant
authority, so please feel free to contact
us in the first instance.
Our duties and your duties in case of changes
We keep our Privacy Notice under
regular review. This version was last updated on the date above written.
Please check from time to time for new versions
of the Privacy Notice. We will also additionally inform you on material changes
of this Privacy
Notice in a manner which
will effectively bring the
changes to your attention.
It is
important that the personal data we hold about
you is accurate and up-to-date.
Please keep us informed if your
personal data changes during your relationship with us.
Third-party links
The Sites and any applicable web browser, the Apps or
application programming interface required to access the Services
(“Applications”), may include links to third-party websites, plug- ins and
applications (“Third-Party Sites”). Clicking on those links or enabling those
connections may allow third-parties to collect or share data about you. We do
not control these Third-Party Sites and are not responsible for their privacy statements and policies. When you
leave our Sites or Applications, we encourage you to read the privacy
notice or policy of every Third-Party Site you visit or use.
4. What data we collect about you
Personal data
Personal data, or personal information
means any information relating to an identified natural person (a “Data Subject”), or one who can be identified directly
or indirectly by way of linking data, using identifiers such as name, voice, picture, identification
number, online identifier, geographic location, or one or more special features
that express the physical, psychological, economic, cultural or social identity
of such person. It does not include data where the identity has been removed
(anonymous data).
It also includes Sensitive Personal
Data which is any data that directly or indirectly reveals a natural person's
family, racial origin, political or philosophical opinions, religious beliefs,
criminal records, biometric data, or any data related
to the health of such person, such as his/her
physical, psychological, mental, genetic or sexual condition, including
information related to health care services provided thereto that reveals
his/her health status.
Different pieces of information, which
collected together can lead to the identification of a particular person, also
constitute personal data. It does not include data where the identity has been
removed (anonymous data).
Depending on whether and how you use our
Services, Sites or Apps, we will collect, use, store and transfer different
kinds of personal data about you which we have grouped in categories as
follows:
|
Category of Personal
Data
|
Examples of specific pieces of personal data
|
|
Identity Data
|
●
first name;
●
maiden name;
●
last name;
●
username or similar identifier;
●
title;
●
employment status;
●
date of birth and gender;
●
biometric information, including a visual
image of your
face,
●
video and voice recording; and
●
national identity card, passport, driving
license or other
form of identification
document.
|
|
Social Identity Data
|
●
your group/company data;
●
information on referrals related
to you;
●
political background;
●
close connections;
●
behavioral data;
●
risk assessment; and
●
compliance assessment.
|
|
Contact Data
|
●
residence details;
●
billing address;
●
delivery address;
●
home address;
●
work address;
●
email address and telephone number(s); and
●
proof of address documentation.
|
|
Financial Data
|
●
bank account;
●
payment card
details;
●
virtual currency account(s);
●
stored value account(s);
●
amounts associated with account(s);
●
external account
details;
●
annual income range; and
●
source of funds and related documentation.
|
|
Transactional Data
|
●
details about
payments to and
from you; and
●
other details of any transactions you enter into
using the Services, Sites
or Apps.
|
|
Investment Data
|
●
information about
your:
○
investment objectives (e.g. expected annual
transaction volume range);
○
investment experience; and
○
prior investments.
|
|
Technical Data
|
●
internet
connectivity data;
●
internet protocol (IP) address;
●
operator and carrier data;
●
login data;
●
browser type
and version;
●
device type, category and model;
●
time zone setting and
location data;
●
language data;
●
application version and SDK version;
●
browser plug-in types and versions;
●
operating system
and platform;
●
diagnostics data such as
crash logs and any other data we collect for the purposes of measuring technical diagnostics; and
●
other information stored on or available regarding the devices you allow us access to when you
visit the Sites, or use the Services or the Apps.
|
|
Profile Data
|
●
your username and password;
●
your identification number as our user;
●
information on whether you
have an account
and the email associated with your accounts;
●
requests by you for products or services;
●
your interests, preferences and
feedback; and
●
other information generated by you when you communicate with us, for example when you address a request to our
customer support.
|
|
Usage Data
|
●
information about
how you use the Sites,
the Services, the
Apps and other offerings made available by us, including:
○
device download time;
○
install time;
○
interaction type
and time; and
○
event time, name and source.
|
|
Marketing and Communications
Data
|
●
your preferences in receiving marketing from us or third-parties, your communication
preferences; and
●
your survey responses.
|
As explained above under Identity Data, we may
also collect a visual image of your face which we will use, in conjunction with
our sub-contractors (see Section
7), to check your identity for onboarding purposes. This data falls
within the scope of Sensitive Personal Data (a.k.a. special categories of
personal data) which warrants extra protection.
We may also ask you to prove ownership
or control of a particular blockchain address. We are required to ask for certain information to comply with anti-money laundering and counter-financing
of terrorism requirements, and to ensure we safeguard against
and report any suspicious activity.
If you refuse to provide personal
data
Where we need to collect
personal data by law, or under the terms of a contract
we have with you and you refuse to provide that data when
requested, we may not be able to
perform the contract we have or are trying to enter into with you – for
example, to provide you services. In this case, we may have to cancel a product
or service you have with us, but we will notify you if this is the case at the time.
5. How we collect
your data
We use different methods to collect
data from and about you including through:
Direct interactions. You may give us your Identity Data, Social
Identity Data, Contact
Data, Financial Data, Profile Data and Marketing and Communications Data by filling in forms, providing a visual image of yourself via the Services, by email or otherwise. This includes personal
data you provide when you:
●
visit our Sites or Apps;
● apply for our Services;
● create an account;
● access or make use of any of our Services;
● request marketing to be sent to you, for example
by subscribing to our newsletters;
●
enter a competition, promotion
or survey, including through social media channels;
●
give us feedback or contact us.
Automated technologies or interactions. As you interact with us via our Sites or Apps, we will
automatically collect Technical
Data about your equipment, browsing
actions and patterns. We collect this personal data by using cookies, server
logs and other online identifiers. We will also collect Transactional Data, Investment Data and Usage
Data. We may also receive Technical Data and Marketing
and Communications Data about you if
you visit other websites employing our cookies. You may find more information
about how we use cookies through the Cookie Preferences.
Third parties or publicly
available sources. We also obtain information about
you, including Social Identity
Data, from third parties or publicly
available sources. These sources
may include:
● fraud and crime
prevention agencies,
● a customer referring
you,
● public blockchain,
● publicly available information on the Internet
(websites, articles etc.)
6. How we use your data
Lawful basis
We will only use your personal data when
the applicable legislation allows us to. In other words, we have to ensure that
we have a lawful basis for such use. We rely for the processing your personal
data on the principles and legal bases provided by the Data Protection Code for
the processing of your personal data.
Most commonly, in the absence
of your consent,
we will use your personal
data on the legal bases provided for under the Data Protection Code which includes
(among others) the following relevant legal bases:
●
public interest: means processing your data where it is necessary to protect the public
interest;
●
legal proceedings: means processing your data where it is necessary to initiate or defend
legal proceedings or in relation to judicial or security procedures;
●
protection of your interests: means processing your personal data where
it is necessary to protect your
interests;
●
performance of a contract: means
processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request
before entering into such a contract; we use this basis for provision of our
Services; and
●
compliance with a legal obligation: means processing your personal data where we need to comply with a legal obligation
we are subject to.
Purposes for which we use your personal data
We have set out
below a description of all the ways we plan to use your personal
data, and which of the legal
bases we rely on to do so.
Note that we may process your personal data
on more than one lawful ground depending on the specific purpose
for which we are using your data.
We establish the applicable legal basis prior to
the processing activity and in relation to the specific
purpose. Please contact us if you need details about the specific legal ground
we are relying on to process your personal data where more than one ground has been set out in the
table below.
|
Purpose and/or
activity
|
Categories of personal data
|
Lawful basis
for processing
|
|
To register you as a new
customer
|
●
Identity Data
●
Social Identity Data
●
Contact Data
●
Financial Data
|
●
Performance of a contract
|
|
To carry out and comply with anti-money laundering requirements
|
●
Identity Data
●
Social Identity Data
●
Contact Data
●
Financial Data
|
●
Compliance with
a legal obligation
|
|
To process and deliver our Services and
any of our Apps’ features to you, including
to execute, manage and process any instructions or orders
you make
|
●
Identity Data
●
Contact Data
●
Financial Data
●
Transactional Data
●
Technical Data
●
Marketing and Communications Data
|
●
Performance of a contract
|
|
To prevent abuse of our Services and promotions
|
●
Identity Data
●
Contact Data
●
Financial Data
●
Transactional Data
●
Technical Data
●
Marketing and Communications Data
|
●
Public interest
●
Consent, if required
|
|
To manage our relationship with you which will
include asking you to leave
a review, take a survey
or keeping you informed of
our company's business and product
development
|
●
Identity Data
●
Contact Data
●
Profile Data
●
Transactional Data
●
Marketing and Communications Data
|
●
Performance of a contract
●
Consent, if required
|
|
To keep our records updated and to study
how customers use our products/services
|
●
Identity Data
●
Contact Data
●
Profile Data
●
Transactional Data
●
Marketing and Communications Data
|
●
Consent, if required
|
|
To manage, process, collect and transfer
payments, fees and charges, and to collect
and recover payments owed to us
|
●
Identity Data
●
Contact Data
●
Financial Data
|
●
Performance of a contract
|
|
To obey applicable legislation and handle
complaints, including:
manage risk and crime prevention involving performance
of anti- money laundering, counter terrorism, sanction screening, fraud
|
●
Identity Data
●
Social Identity Data
●
Contact Data
●
Financial Data
●
Technical Data
●
Transactional Data
●
Investment Data
●
Sensitive Personal Data (a.k.a.
Special Categories
|
●
Compliance with
a legal obligation
●
Performance of a contract
●
Consent, if required
|
|
and other background
checks
detect, investigate, report and prevent financial crime in the broad
sense
ensure your account's security, in order
to honour requests regarding information and/or changes to your account
|
Data) data that
you give us directly or that we receive from
third-parties and/or publicly available sources:
- data which might be revealed by KYC or other background checks (for
example, because it has been reported in the press or is available in public
registers); - data that is incidentally revealed by photographic ID although
we do not intentionally process this personal data;
|
|
|
To enable you
to partake in a prize draw,
competition or survey
|
●
Identity Data
●
Contact Data
●
Profile Data
●
Usage Data
●
Marketing and Communications Data
|
●
Performance of a contract
●
Consent, if required
|
|
To gather market
data for studying customers'
behaviour including their preference, interest and how they use our products/services, determining our marketing campaigns and growing
our business
|
●
Identity Data
●
Contact Data
●
Profile Data
●
Usage Data
●
Marketing and Communications Data
|
●
Consent
|
|
To administer and
protect our business, our Sites, Apps and social media channels
including bans, troubleshooting, data analysis, testing, system maintenance,
support, reporting, hosting of data
|
●
Identity Data
●
Contact Data
●
Financial Data
●
Technical Data
●
Transactional Data
●
Investment Data
|
●
Performance of a contract
● Consent
|
|
To deliver relevant website content and
advertisements to you and measure or understand the effectiveness of the
advertising we serve
to you
|
●
Identity Data
●
Contact Data
●
Profile Data
●
Usage Data
●
Technical Data
●
Marketing and Communications Data
|
●
Consent
|
|
To use data
analytics to improve our
website, products/services, marketing,
customer relationships and experiences
|
●
Technical Data
●
Usage Data
|
●
Consent
|
|
To make suggestions and recommendations to you about goods or services that may
be of interest to you
|
●
Identity Data
●
Contact Data
●
Technical Data
●
Usage Data
●
Profile Data
●
Investment Data
●
Marketing and Communications Data
|
●
Consent
|
|
To use the services of social media
platforms or advertising
platforms some of which will use the personal data they receive for their own
purposes, including marketing purposes
|
●
Technical Data
●
Usage Data
|
●
Consent
|
|
To use the services of financial
institutions, crime and fraud prevention companies, risk measuring companies,
which will use the personal data they receive for
their own purposes in their capacity of independent controllers
|
●
Identity Data
●
Social Identity Data
●
Contact Data
●
Financial Data
●
Transactional Data
●
Investment Data
●
Technical Data
●
Usage Data
|
●
Performance of a contract
|
|
To record voice
calls for compliance,
quality assurance and training purposes
|
●
Identity Data
●
Social Identity Data
●
Contact Data
●
Financial Data
●
Transactional Data
|
●
Performance of a contract
|
Automated Decision
Making
What is an automated decision?
Automated decision is usually a decision that may impact you and is made automatically based on software algorithms, without
human intervention. As an illustrative example, we use automated decisions
to complete the onboarding process
of a new customer or to perform anti- fraud monitoring.
Why is an automated decision
important to you?
Depending on the particular case, using your personal data may lead to automated
decisions being taken (including profiling) that legally affect you or
similarly significantly affect you.
How do we protect your interests regarding automated decisions?
The rights and interests of individuals whose personal data
undergoes automated decision- making is safeguarded through appropriate measures. When an automated decision is made about you, you have the right to oppose the decision, to express your opinion, and to require human
intervention regarding the decision. If you need more detailed information or
wish to exercise this right, please contact us.
Marketing
We may use your Identity Data, Contact Data, Technical Data, Transactional Data, Usage Data, Investment Data and Profile Data to form a view on what
we think you may want or need, or what may be of
interest to you. This is how we decide which products, services and offers may
be relevant for you (we call this marketing).
You
will receive marketing
communications from us if you have requested information from us and
consented to receive marketing communications, or if you have purchased from us and you have not
opted out of receiving such communications. We will use your Marketing
and Communications Data for
our respective activities.
Third-party marketing
We will get your opt-in
consent before we share your personal data with any third party for
marketing purposes.
Opting out
You can ask us to stop sending
you marketing messages
at any time by following
the opt-out links on any
marketing message sent to you.
Further, you can let us know directly
that you prefer not to receive any marketing messages
by emailing [email protected].
Where
you opt out of receiving
marketing messages, this will not apply to service messages
which are directly related to the use of our Services (e.g. maintenance,
change in the terms and conditions and so forth).
Cookies
You can set your browser to refuse all
or some browser cookies, or to alert you when websites set or access cookies.
If you disable or refuse
cookies, please note that some parts of the Services or Sites may become
inaccessible or not function properly.
For more information about the cookies we use, please review the Cookie
Preferences.
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.
Sale or transfer of business
We may also need to process your data in connection with or during
the negotiation of any merger, financing, acquisition,
bankruptcy, dissolution, transaction or proceeding involving all or a part of
our shares, business or assets in which case we may need to seek your consent.
7.
Disclosures of your data
We
share your personal data with our third-party service providers, agents,
subcontractors and other associated organisations, our group companies and
affiliates in order to complete tasks and provide the Services to you on our behalf.
When using third-party service providers, they are
required to respect the security of your personal data and to treat it in
accordance with the law.
We may pass your personal data to the following parties:
●
companies and organisations
that assist us in processing, verifying or refunding
transactions/orders you make and in providing any of the Services that you have requested;
●
identity verification agencies to undertake required verification checks;
●
fraud or crime prevention agencies to help fight against
crimes including fraud, money-
laundering and terrorist financing;
●
anyone to whom we lawfully transfer
or may transfer our rights
and duties under the
relevant terms and conditions governing the use of any of the Services;
●
any third-party because of any
restructure, sale or acquisition of our group or any affiliates, provided
that any recipient uses your information for the same purposes as it
was originally supplied to us and/or used by us; and
●
regulatory and law enforcement authorities, whether they are outside
or inside of the
UAE, where the law allows or requires us to do so.
Where required
under the Travel Rule, we and other custodial cryptocurrency exchanges and
financial institutions share certain basic information about their customers
when handling a cryptoasset transfer over a certain amount to another financial
institution.
Specifics regarding the use of the blockchain
The blockchain technology used in the provision of certain Services
operates on a decentralised
network, where transactions are recorded in an immutable and transparent
manner. This characteristic ensures the integrity and security of the data stored on the blockchain. However, it also means that
once data is added to the blockchain, it becomes virtually impossible to remove or delete
it.
8. International transfers
As
part of our operations, your personal data may be processed by entities within
our group or by external third parties located
outside the UAE. To safeguard your data in these instances, we adhere to stringent measures in line with UAE regulations:
·
We prioritize transferring personal
data to countries recognized by the UAE as providing adequate data protection. This
includes nations listed by the UAE for their data protection standards or those
engaged in bilateral or multilateral data protection
agreements with the UAE.
·
For countries not meeting
these criteria, we ensure one of the following safeguards is in place:
o
Binding contractual agreements with the data-receiving parties, obligating them to
adhere to the UAE Data Protection Code standards.
o
Transfers serving specific purposes, such as:
a. Fulfilling legal obligations or defending legal
rights.
b. Contractual necessities involving you or a third party for your benefit.
c. Engaging in international judicial cooperation.
d. Upholding public interest.
·
In certain situations, we may transfer
personal data outside
the UAE if we determine that there are sufficient legal grounds under the UAE Data
Protection Code.
·
Alternatively, transfers may occur based on your explicit written
consent.
For more details
on the mechanisms, we use for international data transfers, please
feel free to contact us.
9. Data security
While there is an inherent risk in any data being shared
over the internet, we have put in place appropriate security measures to prevent your personal data from
being accidentally lost, used, damaged, or accessed in an unauthorised or unlawful way, altered, or disclosed. In addition, we limit access to your personal data to
those employees, agents, contractors and other third parties who have a legitimate business
need to know.
They will only process your personal data on our instructions, and they are
subject to a duty of confidentiality.
Depending on the nature of the risks presented by the proposed
processing of your personal data, we will have in place
the following appropriate security measures:
●
organisational measures (including but not limited
to staff training
and policy development);
●
technical measures (including but not limited
to physical protection of data,
pseudonymization and encryption); and
●
securing ongoing availability, integrity, and accessibility (including but not limited
to ensuring appropriate back-ups of personal data are held).
We have put in place procedures to deal with any suspected personal data breach
and will notify you and any
relevant regulator of a breach where we are legally required to do so.
If you want to know more about our security practice, please visit this link.
10. Data retention
The UAE Data Protection Code does not specify a fixed duration
for retaining personal
data. Our approach to determining the retention period considers various
factors, such as the volume,
type, and sensitivity of the personal data, the risk of harm from
unauthorized access or disclosure, the objectives of processing your data and if these can be achieved through
other means, and relevant
legal, regulatory, tax, accounting, or other obligations.
Upon concluding that your personal
data is no longer necessary for the purposes
for which it was
collected, we will either delete or anonymize it.
Here are key considerations influencing our decision on the duration
of data retention:
·
In case of a complaint, we may retain
relevant data.
·
If there's a reasonable chance
of litigation related to our relationship with you, or for defending potential
future legal claims, we may keep certain data (like email addresses, chat
content, letters) for up to 8 years after our relationship ends, in line with
the UAE’s limitation period.
·
To comply with legal and
regulatory requirements, certain data (e.g., for audit purposes) may be
retained as needed.
·
We may retain data in accordance with industry standards
or guidelines.
·
For our legitimate business
interests, such as preventing abuse in promotions, we retain customer data for
the duration of the promotion and a specified period thereafter to deter
abusive practices.
Please
note that under certain condition(s), you can ask us to delete
your data: see Section
Your Legal
Rights for further information. We
will honor your deletion request ONLY if the condition(s) is/are met. However,
when interacting with any blockchain, we may not be able to ensure that your personal
data is deleted.
This is because blockchains are public decentralised networks and
blockchain technology does not generally allow for data to be deleted and your
right to erasure may not be able to be fully enforced. In these circumstances,
we will only be able to ensure that all personal data that is held by us is permanently
deleted.
11. Your legal rights
You
have rights we need to make you aware of. The rights
available to you depend on our reason for processing your personal data.
If you need more detailed information or wish to exercise any of the rights set
out below, please contact us.
You may, among other things:
●
request access to your personal data,
which enables you to obtain
confirmation of whether we are
processing your personal data, to receive a copy of the personal data we hold
about you and information regarding how your personal data is being used by us;
●
request rectification of your
personal data by asking us to rectify information you think is inaccurate and
to complete information you think is incomplete, though we may need to verify
the accuracy of the new data you provide to us;
●
request erasure of your
personal data by asking us to delete or remove personal data we hold about you; 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;
●
object to or require that
decisions be reconsidered if they are made solely by automated means, without
human involvement; we use automated tools to make sure that you are eligible to
be our customer taking into account our legal obligations; if these automated
tools indicate that you do not meet our acceptance criteria, we will not onboard
you as our customer;
●
request restriction of processing your personal data, which enables
you to ask us to suspend
the processing of your personal
data, if you want us to establish
the data accuracy;
where our use of the data is unlawful, but you do not want us to erase
it; 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, or if you have
objected to our use of your data;
●
object to and request
that the processing of your personal
data, if the processing is unlawful,
or for the purposes of direct marketing
(including profiling) or conducting statistical surveys (provided the survey is not necessary to achieve the
public interest);
●
request the transfer of your
personal data to you or to a third party, and we will provide to you, or a third party you have chosen (where technically feasible), 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;
●
withdraw consent at any time
where we are relying on consent to process your personal data; however, this
will not affect the lawfulness of any processing carried out before you
withdraw your consent; if you withdraw your consent, we may not be able to provide
certain products or services to you, but we will advise you if this is
the case at the time you withdraw your consent;
●
complain to the UAE Data Office
or any relevant authority about any perceived violation and to seek compensation for
damages in the courts.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a
reasonable fee if your request is not of the type which is required to be
provided free of charge under the Data Protection Code. Alternatively, we could
refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than one month if your request
is particularly complex
or you have made several
requests, also if more time is required to consult with a
third party or other data controller (if needed) before we can reply to your
request; In this case, we will notify you and keep you updated.