IT IS IMPORTANT THAT YOU READ THIS PRIVACY POLICY SO THAT YOU ARE FULLY AWARE OF HOW AND
WHY WE ARE USING YOUR PERSONAL DATA
ATSC Global Limited (“ATSC Global” “we,” “us,” or “our”) is committed to protecting the privacy of our users (“Data Subject”, “you”, or “your”). This Privacy Policy outlines how we collect, use, disclose, and protect your Personal Data in compliance with applicable Data Protection Legislation.
By using our Services or submitting Personal Data to Us, you consent to the practices described in this policy. Reference to “consent”, “your consent” or “your explicit consent” shall include the ticking of a tick box or clicking on a “Submit” or “I agree” button on our site(s).
1. Purpose of this Policy & our Role
Purpose:
This Privacy Policy is designed to inform you about how ATSC Global handles Personal Data when you use our Services, including any information you provide through the “Contact Us” form or any Personal Data we process from your electronic communications with us (such as emails, electronic forms, or interactions on our social media platforms).
Our Services are not intended for Children, and we do not knowingly collect data relating to Children.
Our Role:
Data Controller/ Responsible Party: We may act as the Data Controller (as defined under the GDPR) or Responsible
Party (as defined under POPIA) when processing our Clients’ Personal Data.
Data Processor/ Operator: We may act as the Data Processor (under the GDPR) or Operator (under POPIA) when we process Personal Data on behalf of our Clients (Data Controller), including the Personal Data of their customers, and only in accordance with their instructions and subject to obtaining the necessary consent where required.
2. Information We Collect
We collect Personal Data, it does not include data where the identity of the Data Subject has been removed (anonymous data).
We may Process the following types of Personal Data:
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Identity Data |
First name, Last name, Username or similar identifier, Title, Date of birth, Gender. |
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Contact Data |
Billing address, Delivery address, Email address, Telephone numbers. |
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Financial Data |
Payment card details. |
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Transaction Data |
Details about payments to and from us and other details of goods and/or services you have acquired from us. |
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Technical Data |
Internet protocol (IP) address, Your login data, Browser type and version, Time zone setting and location, Browser plug-in types and versions, Operating system and platform, Other technology on the devices you use to access this website/portal . |
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Profile Data |
Your username and password, Purchases or orders made by you, Your interests, Preferences, Feedback and survey responses. |
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Usage Data |
Information about how a Person uses our website products and/or Services. This information shall include: the full Uniform Resource Locators (URL) Clickstream to, through and from our website (including the date and time) and the services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse- overs), use of a certain function on any Service and methods used to browse away from the page and any phone number used to call our client service number, service transaction instructions from and to you via our APIs. |
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Marketing and Communications Data |
Marketing preferences in receiving marketing from ATSC Global and third parties, your communication preferences (communications related to the Services). |
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Aggregate Data and Pattern Data (“Pattern Data”) |
Statistical, demographical or transactional information derived from Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal the identity of the Data Subject. For example, we may aggregate the Usage Data of a Data Subject to calculate the percentage of users accessing a specific website or specific Service feature or executing a specific transaction type. However, if we combine or connect Pattern Data with your Personal Data so that it can directly or indirectly identify you, we will treat the combined data as Personal Data which will be used in accordance with this Privacy Policy. |
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Additional Personal Data |
You may choose to provide additional Personal Data to us. When you do so, you agree to provide accurate and current information, and to not impersonate or misrepresent any person or entity or falsely state your affiliation with anyone or anything. |
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Special Category Data/Special Personal Information and Children Information
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We do not collect any Special Category Data/Special Personal Information or Children Information directly from Data Subjects. |
You may opt to provide us with additional Personal Data, in which case you agree to supply accurate and up-to-date information, and you must not impersonate or misrepresent any individual or entity, nor falsely claim or misrepresent your association with anyone or anything.
We do not collect any Special Category Data about you, except when providing our Services, which will be collected with your consent.
Submission of Personal Data on behalf of another: If you submit information on behalf of someone else, it is your responsibility to obtain the necessary consent from that person/User before sharing their Personal Data with us. Upon receiving such Personal Data, we will assume that the required consent has been obtained and will process the data according to your instructions. By submitting Personal Data on behalf of another person/User, you indemnify us against any claims from third parties related to Personal Data processed without the necessary consent or other legal exceptions.
If you fail to provide Personal Data: If we are required by law or under the terms of a contract with you to collect Personal Data and you do not provide that data upon request, we may be unable to fulfill our contractual obligations (for example, providing you with Services, including complimentary Services). In such cases, we may need to cancel a Service you have with us, but we will inform you if this becomes necessary at that time.
3. How is the Personal Data Collected?
We use different methods to collect data from you and about you including through:
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Direct Interactions |
Automated technologies |
Third Parties/ Publicly Available Sources |
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• Engaging through Zoom, Teams, Skype etc. • Sign up/register for our Services • Request our marketing material from Us. • When engaging with our support services. • Provide us feedback. • Contact us via our “Contact Us”. form, or WhatsApp or other social media sites’ messaging platforms.
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• As you interact with our Services or website, we will automatically collect Technical Data about your equipment, browsing actions, patterns, and device(s). • We may also receive Technical Data about you if you visit other websites employing our cookies.
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• Analytics providers such as Google. • Advertising networks. • Search information providers. • Third Party service providers that provide a service or product to you, subject to your consent to us to collect the information. • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
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4. Cookies
For detailed information on how we use cookies and similar tracking technologies on our website/platform, please review our Cookies Policy. By continuing to use our website, you consent to our use of cookies as described in that policy.
5. Purposes of Processing
We process your Personal Information for the following purposes:
• To Provide Services: To create and manage your account, process transactions, and provide customer support.
• To Improve Our Services: To analyse usage patterns and improve our website and Services.
• Marketing Communications: To send you promotional materials and updates if you have opted in to receive such communications.
• Legal Compliance: To comply with applicable laws and regulations.
Note that we may process Personal Data for more than one lawful ground depending on the specific purpose for which we are using the data. 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.
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Purpose of Activity |
Type of Data |
Lawful basis for processing including basis of legitimate interest |
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To register you as an ATSC Global Client
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• Identity • Contact • Marketing and Communications
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• Consent • Performance of a contract with you
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Delivery of Services to ATSC Global Clients, including but not limited to sharing of information with External Parties as part of the Services
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• Identity • Contact
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• Consent • Performance of a contract with you
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Manage payments, fees and charges; Collect and recover money owed to ATSC Global
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• Identity • Contact • Financial • Transaction • Marketing and Communications
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• Performance of a contract with you • Necessary for our legitimate interests (to recover debts due to us) [TAKE NOTE: we do not store Financial Information – card details. We use third party service provider(s) to execute transactions where you use your card. You should read their privacy policy]
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To manage our relationship with you which will include: • Notifying you about changes to our Terms of Services or this Privacy Policy where required • Asking you to leave a review • General Service communications.
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• Identity • Contact • Profile • Marketing and Communications
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• Performance of a contract with you • Necessary to comply with a legal obligation • Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)
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To administer and protect our business, website and other electronic platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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• Identity • Contact • Technical
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• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) • Necessary to comply with a legal obligation
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To deliver relevant website and Service content and information about similar services and/or products to you and measure or understand the effectiveness of the advertising we serve to you
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• Identity • Contact • Profile • Usage • Marketing and Communications • Technical
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• Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
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To use data analytics to improve our website, Services, marketing, client relationships and experiences
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• Technical • Usage
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• Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
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To make suggestions and recommendations to you about Services that may be of interest to you
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• Identity • Contact • Profile • Usage • Marketing and Communications • Technical
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• Necessary for our legitimate interests (to develop our services and grow our business)
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6. Legal Basis for Processing
Under the GDPR & POPIA, we process your Personal Data only on the basis of one or more of the following grounds:
• Consent: Where you have provided consent for us to process your data for specific purposes.
• Contractual Necessity: Where processing is necessary for the performance of a contract with you.
• Legal Obligation: Where we are required to comply with a legal obligation.
• Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided that your interests do not override those interests.
We ensure that, in every instance, your Personal Data is processed in a fair, lawful, and transparent manner.
7. Disclosure of Personal Information
We may share your Personal Data with:
• Service Providers: Third-party vendors who assist us in providing our services (e.g., payment processors, IT support).
• Legal Authorities: When required by law or to protect our rights or the rights of others.
• Business Transfers: In connection with any merger, sale of assets, or acquisition.
8. International Data Transfers
Some of our External Third-Parties may be based outside your country so their processing of your Personal Data could involve a transfer of data outside your country.
Whenever we transfer your Personal Data out of your country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your Personal Data to countries that have appropriate data protection and privacy legislation to protect your Personal Data.
• Where we use certain service providers, we conclude an agreement with them to confirm that your Personal Data is confidential, they can only process on our instructions and that they should establish and maintain appropriate technological and organisational measurements to protect your Personal Data.
By submitting your Personal Data to us you consent to the transfer of your Personal Data outside the borders of your country (when required).
9. Data Security
We implement appropriate technical and organizational measures to protect your Personal Information against unauthorised access, loss, destruction, or alteration. However, no method of transmission over the internet or method of electronic storage is 100% secure.
10. User Rights
European Union Users (GDPR Rights)
You have the following rights under GDPR:
• Right to Access: You can request access to your Personal Information. There may be a fee associated with this request – see below.
• Right to Rectification: You can request correction of inaccurate or incomplete data.
• Right to Erasure: You can request deletion of your personal data under certain conditions.
• Right to Restrict Processing: You can request that we limit the processing of your data.
• Right to Data Portability: You can request a copy of your data in a structured format.
• Right to Object: You can object to processing based on legitimate interests or direct marketing.
South African Users (POPIA Rights)
You have the following rights under POPIA:
• Right to Access: You can request access to your Personal Information held by us.
• Right to Correction: You can request correction of inaccurate or incomplete data.
• Right to Deletion: You can request deletion of your Personal Information under certain conditions.
• Right to Object: You can object to processing based on legitimate interests or direct marketing.
• Right to Withdraw Consent: You can withdraw your consent for the processing of your Personal Information.
• Right to Lodge a complaint: You have the right to lodge a complaint with the Information Regulator.
To exercise these rights, please contact us using the contact details provided below.
Fee required: Apart from any prescribed fees under any applicable data protection legislation, 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 clearly unfounded, repetitive or excessive. 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 30 (thirty) days. Occasionally it could take us longer than 30 (thirty) days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Data Retention
We will retain your Personal Information only for as long as necessary to fulfill the purposes outlined in this policy or as required by law.
How long will we use your 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 of 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.
• By law we have to keep basic information about our clients (including Contact, Identity and Transaction Data) for five years after they cease being clients for tax purposes.
• In some circumstances you can ask us to delete your data: see your legal rights below for further information.
• In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our website. Your continued use of our services after any changes indicates your acceptance of the revised policy.
13. Important Information and who we are
To get in touch with us:
Full name of legal entity: ATSC Global Limited
Contact details: Website (click here to communicate via our website)
Email: legal@atsc.global
Registered address: 1st Floor, Penrose 2, Penrose Dock, Cork City, Ireland, T23 YY09
14. Definitions
• Children means natural persons under the age of 18 years.
• Data Controller (EU) / Responsible Party (RSA) means a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for processing Personal Data.
• Data Processor/ Operator means an entity that handles Personal Data as instructed by a Data Controller (our Clients).
• Data Protection Legislation means the General Data Protection Regulation (EU) 2016/679 (“GDPR”) applicable to users in the European Union (“EU”) and the Protection of Personal Information Act (“POPIA”) applicable to users in South Africa (“SA”).
• Data Subject means the person to whom Personal Data relates and, in this document, refers to you as the party providing Personal Data that will be processed by ATSC Global or a relevant third-party.
• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best Service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of 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.
• Personal Data includes the definition contained in the GDPR as well as the definition of “Personal Information” in the POPI Act.
• Process or Processing as defined under the POPI Act and GDPR.
• RSA means the Republic of South Africa.
• Services has the same meaning as per our Terms of Use.
• Special Category Data as defined by the GDPR or Special Personal Information as defined by the POPI ACT.
• THIRD-PARTIES
i. Internal Third-Parties: Partners, affiliates, employees, shareholders, directors and/ or agents of ATSC Global (if applicable), acting as joint responsible parties or operators and who may also provide IT and system administration services and undertake leadership reporting.
ii. External Third-Parties:
(1) Service providers acting as operators who provide IT and system administration services.
(2) Professional advisers acting as operators or joint Responsible Parties, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
(3) The Revenue Services, regulators and other authorities acting as operators or joint Responsible Parties who require reporting of processing activities in certain circumstances.
(4) Courts of law or any other authorities where we have an obligation under law to share your Personal Data.
(5) In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.