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GENERAL DATA PROTECTION REGULATION (GDPR)

Who is providing this notice:

Rollman Management Ltd. is registered in the British Virgin Islands: Craigmuir Chambers, Road Town, Tortola, VG 1110.

Company Number 2160179.

Email: [email protected]

This GDPR describes how the Company collects, processes and shares the information of users (hereinafter referred to as “User”) of the www.rollmanmanagement.com website.

The Company may use the other processors listed below for the processing of personal data.

We advice you to read the entire GDPR and make sure you fully understand the information provided. If you have any questions about this Privacy Policy or the Company’s collection, processing and sharing of personal information, please contact us at [email protected].

What data will be processed?

he company processes data collected during the use of the website and  cookies. In order to better target advertising campaigns and improve the website, the Company uses information about the pages viewed by the user, the links clicked on and other activities on the website, such as filling in orders and contact forms. This data is collected automatically with the help of the Company’s tools and data processors listed below. If you have cookies enabled on your device, this data is also collected with these files.

The company primarily processes the data you provide when creating and using a user account, creating an order or registering for a loyalty program, and when subscribing to the newsletter. Some personal data is necessary for registration (name and email address) and serves for basic user identification or customer account registration. The data that the Company processes when registering for the newsletter or creating a user account may be as follows:

• -Name and surname or company name
• -Email
• -Phone number
• -Delivery address
• -Company identification data
• -Payment details
• -Server, email and web access details
• -Any other data necessary for the performance of the contractual relationship

The Company does not knowingly collect information from children under 18, and children under 18 cannot use its services. If you become aware that a child has provided us with personal information violating this GDPR, you may notify us at [email protected].

For what purposes will the personal data be used? (as part of our contractual obligation)

The company always processes personal data solely for the purposes for which it was collected, based on a legitimate interest, legal obligation or consent. We process personal data for various purposes, in particular:

• -performance and implementation of concluded contracts and orders,
• -fulfillment of statutory bookkeeping and tax obligations, as required by other applicable laws and regulations or as required by any legal process or governmental agency.
• -communicating with customers, including sending information about current services and products, updating terms and conditions, and for marketing and promotional purposes,
• -responding to inquiries from website users,
• -replying to a specific job offer,
• -analyzing website traffic to improve the services and offerings,
• -marketing outreach through electronic contact,
• -transaction processing and fraud detection,
• -targeting potential customers through online advertising. To better target advertising and optimize the website, the Company uses information about user activity on the website. This information includes data collected through the use of cookies.
• -Push notifications. If you have this feature enabled, the Company may send so-called push notifications directly in the website interface. These notifications are displayed based on your consent given after the respective information is displayed in the website interface.

Processors who have access to the data

Personal data is processed primarily by the Company and its employees, who are bound by confidentiality, as well as by the Company’s suppliers insofar as it is processed in connection with the performance and execution of concluded contracts and orders (e.g., transport companies).

The Company may also use a so-called processor to process personal data. These entities may only process personal data for the purposes and in the manner specified by the Company and may not disseminate it without further consent. We only pass on to processors the data that they necessarily need to provide their services.

The Company may transfer personal data to other entities (processors) in justified cases.

Personal data may be transferred to the following processors:

processors who process personal data according to the Company’s instructions in the area of public relations, electronic data management or accounting,
public authorities and other entities where required by applicable law;
other entities in the event of an unexpected event in which the provision of data is necessary to protect life, health, property or other public interest or where it is necessary to protect our rights, property or safety.

The period for which the personal data will be retained

Personal data for the purposes referred to in point “For what purposes will the personal data be used” are processed to the extent necessary for fulfilling these purposes and for the period needed to achieve them or for the period directly provided for by law. After that, the personal data shall be erased or anonymized.

After this period, personal data may be retained only for the National Statistical Service’s purposes, for scientific and archiving purposes.

The basic time limits for processing personal data are available below.

• -The Company processes the personal data of registered customers until their registration is canceled. Customer contact details are processed for the duration of the business relationship or until the customer updates the details.
• -In the case of service customers, the Company is entitled to process their basic personal, identification, contact, service and communication data with the Company for 10 years from the date of termination of the last contract.
• -In the case of purchase of goods from the Company, the Company is entitled to process the customer’s basic personal, identification, contact, goods and communication data for a period of 5 years from the date of expiry of the warranty period for the goods.
• -Invoices issued by the Company are archived for 10 years from the date of issue in accordance with Section 35 of Act No. 235/2004 Coll., on Value Added Tax. Contracts are also archived for 10 years from the date of termination of the contract due to the need to prove the legal reason for issuing the invoices.
• -The data collected for marketing purposes are processed for the entire duration of the consent, i.e., also for as long as the user allows storage within the cookie settings on the website or in his browser. The processing may also continue after the withdrawal of consent, at the latest, until the respective type of cookie expires.
• -Sales and marketing communications via electronic contact are sent until the consent is withdrawn or until the user unsubscribes.

Withdrawal of consent

Customers may unsubscribe from any marketing and commercial communications at any time by:

by clicking on the relevant link in the footer of each commercial communication;
on the designated website;
by sending a request to the contact provided
The user can disable the targeting of advertising (cookies) by changing it directly in his browser. If you disable the storage of selected Cookies, some parts of the website may not work properly.

Methods of processing and storage of personal data

Personal data will be processed and stored:

• -machine (automated) through computer hardware and software,
• -in written form.

Rights of the data subject

The data subject will have the following rights if he or she is an identifiable natural or legal person and proves his or her identity:

Right to access personal data

According to Article 15 of the GDPR, the data subject has the right of access to personal data, which includes the right to obtain from the Company:

• -Confirmation as to whether it processes his/her personal data,
• -information about the purposes of the processing, the categories of personal data concerned, the recipients to whom the personal data have been or will be disclosed, the intended duration of the processing, and the existence of the right to request the controller to rectify or erase personal data relating to the data subject or to restrict or object to the processing, the right to complain with a supervisory authority, any available information about the source of the personal data if not obtained from the data subject, the fact that automated decision-making, including profiling, takes place, appropriate safeguards in the event of a transfer of data outside the EU,
• -if the rights and freedoms of others will not be adversely affected, a copy of the personal data.

If a repeated request occurs, the Company will be entitled to charge a reasonable fee for a copy of the personal data.

Right to correct inaccurate data

According to Article 16 of the GDPR, you have the right to correct inaccurate personal data that the Company processes. You also have an obligation to notify changes to your personal data and to provide evidence that such changes have occurred. You are also obliged to cooperate with the Company if it is found that the personal data it processes about you is not accurate. We will make the correction without undue delay but always taking into account the technical possibilities.

Right to delete data
According to Article 17 of the GDPR, you have the right to delete personal data concerning you unless the Company demonstrates legitimate grounds for processing such personal data. The Company has set up mechanisms to ensure the automatic anonymization or deletion of personal data if they are no longer needed for the purpose they were processed.

Right of restriction of processing
According to Article 18 of the GDPR, the data subject has the right to restrict processing until the complaint is resolved if he or she contests the accuracy of the personal data, the grounds for processing or objects to the processing in writing to the Company’s registered office.

Right to notification of rectification, deletion or restriction of processing
According to Article 19 of the GDPR, the data subject has the right to be notified by the Company in case of rectification, deletion or restriction of processing of personal data. If personal data are rectified or deleted, the Company will inform the individual recipients, except where this proves impossible or requires disproportionate effort.

Right to portability of personal data
According to Article 20 of the GDPR, you have the right to the portability of data relating to you that you have provided to us as a controller in a structured, commonly used and machine-readable format. You also have the right to ask us to transfer this data to another controller.

If the exercise of this right could adversely affect the rights and freedoms of third parties, your request cannot be granted.

Right to object to the processing of personal data
According to Article 21 GDPR, you have the right to object to the processing of your personal data by the Company. If the Company does not demonstrate that there is a compelling legitimate reason for the processing which overrides the interests or rights and freedoms of the data subject, the Company will terminate the processing without undue delay on the basis of the objection.

Right to withdraw consent to the processing of personal data
If you have given the Company your consent to the processing of personal data, you may withdraw it at any time. The revocation must be made by an explicit, intelligible and specific expression of will, either in writing to the Company’s registered office or by emailing [email protected].

Automated individual decision-making, including profiling
The data subject has the right not to be subject to any decision based solely on automated processing, including profiling, which would have legal effects concerning him or her or similarly significantly affect him or her. The Company states that it does not carry out automated decision-making without the influence of human judgment having legal effects on data subjects.

Right to contact the Data Protection Authority
You have the right to lodge a complaint regarding our processing of your personal data with the the independent supervisory authority in British Virgen Islands, the DPI.

Safety

The Company is committed to protecting personal data and other information about its customers and users of its services. To do this, it uses a range of security technologies and measures designed to protect information from unauthorized access, use or disclosure. The measures it uses are designed to provide a level of security appropriate to the risk of misuse of personal information. The Company’s security of personal information is regularly tested, and protection is continually improved. However, please keep in mind that the Internet cannot be guaranteed to be 100% secure.

All personal data in electronic form is stored in databases and systems that can only be accessed by those who have an immediate need to handle the personal data for the purposes set out in this policy and only to the extent necessary.

Update of the privacy policy

Please note that we may modify or update this Privacy Policy. Any changes to this Privacy Policy will become effective when posted at the following link: https://rollmanmanagement.com/legal/

This Privacy Policy is effective as of January 1, 2023.

Terms of use

This is the official website (the “Website”) of Rollman Management Ltd. (the “Company”), the use of which is governed by the terms and conditions set out below, which you should read before proceeding. If after careful consideration you do not agree to use the Website in accordance with them, you should exit without proceeding further. By using the Website, you are deemed to have accepted these terms and conditions.

This website is not directed at you if we are prohibited by any law of any jurisdiction from making the information on this site available to you and is not intended for any use that would be contrary to local law or regulation. Services mentioned on this site are subject to legal and regulatory requirements in applicable jurisdictions and may not be available in all jurisdictions. Accordingly, persons are required to inform themselves of and observe any such restrictions. The provision of the information in this website does not constitute an offer to purchase securities to any person in the United States or to any U.S. Person as such term is defined under the United States Securities Act of 1933, as amended. This website is made available free of charge. We do not guarantee that this website, or any content on it, will always be available or be uninterrupted. Access to this website is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of this website without notice. We will not be liable to you if, for any reason, this website is unavailable at any time or for any period. You are responsible for making all arrangements necessary for you to have access to this website. You are also responsible for ensuring that all persons who access this website through your internet connection are aware of these terms of use and other applicable terms and conditions and that they comply with them.

This Website is not directed to any person in any jurisdiction where the publication or availability of this Website is prohibited. Persons in respect of whom such prohibitions apply must not access this Website.

By accessing this Website and any pages thereof, you acknowledge your agreement with, and understanding of, our terms of use and legal information pertaining to both this Website and any material in it. If you do not agree to the terms of use, do not access this Website or any pages thereof.

Access to the information contained on this Website may be restricted by laws and regulations applicable to the user.

Limitation of Liability

Whilst every effort is made to verify the accuracy of the information on the Website it is supplied on an “as is” basis and the Company makes no representation or warranty (express or implied) that such information is accurate, complete, current or suitable for the purposes for which it will be used. You are advised to verify any information before relying on it.

Accordingly, the Company shall not be liable for any loss or damage that anybody may suffer (whether directly or indirectly) as a result of relying on the information contained on the Website or on information contained on any site accessible via the Website. Nor shall the Company be liable for any direct or indirect loss or damage resulting from any interruption in availability, viruses, contamination, lack of technical specifications necessary for downloading or any other liability howsoever caused. In using the Website, the user accepts all risks pertaining thereto.

Nothing contained in this Website constitutes an invitation to invest in the services of Rollman Management or any of its subsidiaries or joint venture partners. The past performance of the models and services offered constitutes no guarantee as to its future performance.

This Website does not provide business, finance, legal, tax or any other form of professional advice. Clients should always consult a legal adviser before making a decision.

In many countries, the finance and business mentioned in this part of the Website are subject to restrictions in relation to publication and access via the Internet, marketing, offering and/or selling. Reference is made to the respective prospectus for any details, however, it is the obligation of each person to inform themselves about and to obey any restrictions. Thus persons, being subject to any restriction shall not access this part of the Website. In relation to a particular investments, all current versions of all documents in relation to such investments shall be considered. All further or additional reservations in such documents apply. Persons in respect of whom such prohibitions apply must not access this Website.

Governing Law

These terms shall be governed by and construed in accordance with British Virgen Islands law and subject to the sole jurisdiction of the British Virgen Islands courts. No representation or warranty is made by the Company that the information and materials on or accessed through this Website comply with legislative or regulatory requirements applicable to other areas in which this Website may be accessed.

Data submitted to us by you will be used by us for the purposes for which it has been submitted and for the administration of this Website only, and, except for the postage of information to you at your request (which may be subcontracted to an authorised representative for this purpose), will not be disclosed to any third party without your prior consent other than as required by law.

Whilst the Company will take all reasonable steps to protect all personal information received from you it does not guarantee the security of any information given to it via this Website or any site accessible through it.