5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

·       Service providers who support our operations (e.g., hosting, analytics, payment processing, IT support, marketing tools).

·       Affiliates or subsidiaries within our corporate group where necessary for administrative or technical purposes.

·       Business partners in connection with app distribution, marketing collaborations, or customer support.

·       Regulators, legal authorities, or law enforcement if required by law.

·       Successors or acquirers in the event of a merger, sale, or corporate restructuring.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We operate globally, and your personal data may be transferred to and processed in countries other than your country of residence.

Where data is transferred outside your jurisdiction (including the EEA, UK, or Switzerland), we ensure that appropriate safeguards are in place, such as:

·       Adequacy decisions by the European Commission or UK Government;

·       Standard Contractual Clauses (SCCs) or International Data Transfer Agreements (IDTAs); or

·       Other lawful mechanisms approved by applicable regulators.

A copy of these safeguards can be requested by contacting us at legal@gladianv.com

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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 business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When personal data is no longer needed, it will be securely deleted, anonymized, or archived in accordance with applicable law.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

·       Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

·       Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

·       Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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, if applicable, at the time of your request.

·       Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests) OR to object any time to the processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

·       Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, 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 (see the table in section 4 for details of when we rely on your consent as the legal basis for using your 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. We will advise you if this is the case at the time you withdraw your consent.

·       Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

·       If you want us to establish the data's 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

·       You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the information in Section 10

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us:

·       Email address: legal@gladianv.com

·       Postal address: Schout Bij Nacht Doormanweg 40, Curaçao, P.O. Box 4745

11. Complaints

If you have concerns about how we handle your personal data, we encourage you to contact us first so we can address your issue.

Depending on your location, you also have the right to lodge a complaint with your local data protection authority.

12. Changes to the privacy policy and your duty to inform us of changes 

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons.

The latest version will always be available on our website with the “Last Updated” date at the top.

13. Third-party links 

This website may include links to third-party websites, plug-ins and applications. 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 websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.