Welcome to Ground One and our website at www.ground-1.com (our “website”). Data protection and data security when using our website and services are very important to us. We would therefore like to inform you which of your Personal Data we collect when you visit our website and for what purposes it is used.
WHO IS RESPONSIBLE?
The person responsible in the sense of Luxembourg`s Law of 1 August 2018 (Data Protection Act) (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”) is Valéan Sàrl, 13A Avenue Guillaume,1651 Luxembourg, Luxembourg (“Ground One”, “we”, “us”, “our”). If you want to contact us or if you have any questions, you can reach us by email using hello@ground-1.com, call +352 26389659 or write to us at the above address.
PRINCIPLES OF DATA PROCESSING
a) Personal data
Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behavior.
b) Processing
The processing of Personal Data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis.
c) Legal basis
In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: i) you have given your consent, ii) the data is necessary for the fulfillment of a contract / pre-contractual measures, iii) the data is necessary for the fulfillment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
d) Retention
Processed Personal Data will be deleted as soon as the purpose of the processing has been achieved and there are no longer any legally required retention obligations.
DATA WE COLLECT
a) Provision and use of the website
When you call up and use our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii)name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your computer as well as the name of your access provider. The legal basis is our legitimate interest.
b) Hosting
The hosting services used by us for the purpose of operating our website is Squarespace Inc., (225 Varick Street 12th Floor New York, NY 10014 United States). In doing so Squarespace processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests.
c) Content Management System
We also use the Content Management System (CMS) of Squarespace to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to Squarespace. This represents a legitimate interest.
d) Cookies
We use cookies on our website. In accordance with Luxembourg`s Law of 30 May 2005 (the Electronic Communications Act) (“ECA”) and the EU`s Privacy and Electronic Communications Directive (“PECD”) we are required to obtain your consent before placing so-called Non-Essential Cookies (Functional cookies, Analysis and Performance Cookies, Advertising Cookies or Targeting Cookies).
e) Cookie consent
Our website uses the cookie consent tool CookieLawInfo of CookieYes LTD (3 Warren Yard Warren Park, Wolverton Mill, Milton Keynes, MK12 5NW, United Kingdom) to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us via our cookie consent tool: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
f) reCAPTCHA
We also use Google`s reCAPTCHA from Google LLC to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. The legal basis for using reCAPTCHA is our legitimate interest.
g) Analytics
For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymised values. For this purpose we use Squarespace Analytics which is a web analytics service offered by Squarespace. The legal basis is our legitimate interest and your consent. For further information, please refer to our Cookie Policy.
h) Contacting Us
We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract. As a rule, we do not require any special categories of Personal Data to provide our services.
i) Appointments and Meetings
For requesting a meeting in an easy and convenient way, we use Calendly Inc., (88 North Avondale Road Suite 603 Avondale Estates, GA 30002 United States). Your data from the form will be transferred to our appointment account at Calendly after you press the "Book appointment" button. You will then receive a confirmation email with a link to the event. Your data will be kept at Calendly until the purpose for storing the data no longer applies (appointment made) or you request us to delete it. Calendly undertakes not to pass on your data to third parties. The legal basis is your consent as well as our legitimate interest.
j) When using our services
We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfillment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.
k) Register interest
We use the services of Typeform SL (C/ Can Rabia 3-5, 4th floor, 08017, Barcelona, Spain) to make registering interest as convenient as possible for you. Doing so we process your full name, your organization or company name, your role, the personal data contained in your project description, your social media handles, your email address, your phone number. The data processing is based on our legitimate interest and your consent.
l) Newsletter
If you register on our landing page or during the interest registration process for our newsletter, we may send you after you have confirmed your subscription the occasional email for marketing purposes using the services of Squarespace. The only data required for our mailing list is your email address. The processing bases are your consent and our legitimate interest.
m) Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
o) Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose including improving our website and services. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.
SOCIAL MEDIA
We are present on social media on the basis of our legitimate interest (Instagram (Meta Platforms, Inc., 1601 Willow Road Menlo Park California 94025 and 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland)). If you contact or connect with us via Instagram, we and Instagram are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
When you visit our Instagram profile, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
DATA SECURITY
We undertake to protect your privacy and to treat your Personal Data confidentiality. In order to prevent manipulation or loss or misuse of your data stored with us, we take extensive technical and organizational security precautions which are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognised encryption procedures (SSL or TLS).
However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. We have no technical influence on this. It is the user's responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.
MARKETING
a) General
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
b) Direct Marketing
Direct Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
c) Customer Profiles
In accordance with our legitimate interests, we may make use of profiling and screening methods to identify potential new customers and supporters, produce more relevant communications, target digital advertising, and provide a better experience for our customers and supporters. Processing your Personal Data for profiling can help us target our resources more effectively by gaining an insight into the background of our customers and supporters, helping us to build relationships that are appropriate to your interests and capacity to engage. If you wish to object to the processing of Personal Data for customer profiles, please contact us.
d) Facebook Custom Audience
We may participate in Facebook's (Meta Platforms, Inc., 1601 Willow Road Menlo Park California 94025 and 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland) Custom Audience program which enables us to display personalized ads to persons on our email lists when they visit Facebook.com. We provide Personal Data such as your email address to Facebook to enable Facebook to determine if you are a registered account holder with Facebook. You may opt-out of participation in our Facebook Custom Audience by sending an email, from the email address you are opting out of, to hello@ground-1.com. For your opt-out to be effective, you must: (i) place the following text in the subject line of the email - "Opting Out of Facebook.com Website Custom Audience Ads", and (ii) in the body of the email, include your name and email address. We will forward your name and email address to Facebook.com with a request to delete you from all of our Facebook Custom Audience Ads.
For more information about the privacy policy of Facebook and Custom Audience, please check here or here. If you do not want data acquisition via Custom Audience, you can disable Custom Audience here. Facebook offers a separate data processing agreement for Custom Audiences which you can find here. The legal basis is our legitimate interest and your consent.
INTERNATIONAL TRANSFERS
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
HOW WE MAY SHARE YOUR PERSONAL DATA
We may share your Personal Data with our business partners and within Valéan Sàrl for the purposes described in this Privacy Policy, including (but not limited to) conducting the services you request, or customizing our business to better meet your needs. We share your Personal Data only with business partners who agree to protect and use your Personal Data solely for the purposes specified by us.
We may also disclose your Personal Data for any purpose with your consent or for law enforcement, fraud prevention or other legal actions as required by law or regulation, or if we reasonably believe that we must protect us, our customers or other business interests. Except as described above of which you will be informed in advance, we will not disclose your Personal Data.
WHAT WE DO NOT DO
● We do not request Personal Data from minors and children;
● We do not use Automated decision-making including profiling; and
● We do not sell your Personal Data.
PRIVACY RIGHTS
Under the DPA and the GDPR, you can exercise the following rights:
● Right to information
● Right to rectification
● Right to deletion
● Right to data portability
● Right of objection
● Right to withdraw consent
● Right to complain to a supervisory authority
● Right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
UPDATING YOUR INFORMATION AND WITHDRAWING YOUR CONSENT
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or want to withdraw any consents you have given us, please contact us.
ACCESS REQUEST
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
COMPLAINT TO A SUPERVISORY AUTHORITY
The supervisory authority in Luxembourg is the Commission Nationale pour la Protection des Données (CNPD) (www.cnpd.lu). We would, however, appreciate the chance to deal with your concerns before you approach the CNPD or any other supervisory authority.
HOW DO WE MAKE CHANGES TO THIS POLICY?
We may change our Privacy Policy from time to time. When we change our Privacy Policy, we will publish the updated policy on our website. Please check this Privacy Policy regularly. Subject to applicable law, all changes will take effect as soon as we publish the new Privacy Policy, but where we have already collected information about you and/or where legally required to do so, we may take additional steps to inform you of any material changes to our Privacy Policy and may request that you agree to these changes.
EFFECTIVE DATE
Monday, 28th of June, 2024
