PRIVACY POLICY

This Privacy Policy entered into force on December 16, 2017.

Utopian Future Technologies S.A.  (“UFT”) is committed to protecting the privacy of users and will do everything in its power to ensure that users’ Personal Data is treated with respect to their fundamental rights and freedoms as well as personal dignity, with particular reference to confidentiality.

We at UFT have thus prepared this Privacy Policy in order to briefly explain to you how we will collect, use, share and secure your Personal Data. It also describes your choices regarding use, access and correction of your Personal Data.

This Privacy Policy will also provide you with full information so that you are able to consent to the processing of your Personal Data in an explicit and informed manner, where appropriate.

In general, any information and data which you provide, or which is otherwise gathered by us in the context of the Website, will be used by UFT in compliance with Regulation (EU) 2016/679 (“GDPR”).

This means, in particular that any Personal Data processing carried out by UFT will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.

Data Controller

The Data Controller regarding all Personal Data processing operations carried out through the Website is UFT, with registered offices at 59 Boulevard Royal, 2449 Luxembourg, Luxembourg

UFT has appointed a local coordinator for privacy/Data Protection Officer (DPO). To get in touch with him/her for any information regarding the processing of Personal Data by UFT, including a list of its data processors, please contact: dpo@uft.lu

What information do we collect from you?

As you use the website and, in particular, as you provide information “Request a Demo” or “Contact Us”, UFT may collect and process information related to you as an individual and which allows you to be identified, either directly or together with additional information (“Personal Data”).

Mandatory Data vs Data voluntarily provided by users

As you visit the website, you can choose to fulfill the form “Request a Demo” or “Contact Us” to receive further information about the products and services of our company. If so, the mandatory data required are: the family name, The surname and the email address. The other information are not mandatory thus you decide to provide them voluntary and you will suffer no consequence if you choose not to give it.

Browsing data

The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation, whose transmission is automatic when using Internet communication protocols.

Although UFT does not collect this information in order to associate it to specific users, it is still possible that, by their nature and through processing and association with further data held by third parties, such data may permit to identify user, either directly via that information or by using other information collected. As such, this information must also be considered Personal Data

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, information about your activities on our Website (for instance, the pages you visit, the goods you view), the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), details on the device (for instance, your computer, tablet or smartphone) which you use to access our Website and so on, by means of cookies and other technologies which allow this tracking. To manage Flash cookies, please click here. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service, as further described below.

Such data shall only be used by UFT for anonymous, statistical purposes about the use of the Website, without associating them to any identifier of the users, to ensure its correct operation and identify any faults and/or abuse of the Website. This data may also be used for the purposes of investigating liabilities in the event of information crimes committed against the Website.

Processing activities

UFT intends to use your Personal Data, collected through the Website, for the following purposes:

• To provide answers or services you request; to receive information from UFT; to verify your identity and assist you; to contact you when necessary and respond to your requests and enquiries, including emails; to process card payments and to provide any other services which you may request;

No consent is required for the processing of data for the purposes since such processing is necessary to provide the services requested and, therefore, for the performance of an agreement to which you are a party or for the implementation of measures requested by you prior to entering into an agreement (GDPR art. 6,1b). It is not mandatory for you to give UFT your Personal Data for these purposes; however, if you do not, UFT will not be able to provide any services to you.

• For marketing, promotional and publicity purposes, (“Marketing”), and to send you offers, promotions or other information about our goods and services. Processing for these purposes is based on your consent. It is never mandatory for you to give consent to UFT for the use of your Personal Data for these purpose, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from the company UFT). Any consent given may also be withdrawn at a later stage.

• For compliance with laws which impose upon UFT the collection and/or further processing of certain kinds of Personal Data, including regulations on contests in case users participate to contests or prizes on our Website (“Compliance”). When you provide any Personal Data to UFT, UFT must process it in accordance with the applicable laws, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations. No consent is required for the processing of data for this purpose since such processing is necessary to comply with a legal obligation (GDPR, art. 6, 1a).

• To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”). Processing for this purpose is necessary to pursue UFT’s legitimate interests in preventing and detecting fraudulent activities or misuse of the Website (for potentially criminal purposes).

• To analyze and improve our service provision, enhance the Website, evaluate the effectiveness of Kussbus brand’s marketing activities and services, perform statistical and demographics analyses and registered users (“Analytics”).

Processing for this purpose is necessary to pursue UFT’s legitimate interests in the development and administration of the Website and to improve the services provided on the Website.

Users shall not be required to provide Personal Data to browse public pages of the Website. The provision of Personal Data for the purposes mentioned above is optional, however, failure to provide required data (indicated as such in the registration form, as applicable) may prevent users from completing registration or availing of related services.

Who will be able to access your Personal Data?

In the framework of its activity and for the purposes specified above, your Personal Data may be shared with the following entities (“Recipients”):

• Selected individuals employed at or authorized by UFT to process Personal Data, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of UFT);

• Public entities, bodies or authorities, in accordance with the applicable law or binding orders of those entities, bodies or authorities. We may also disclose your Personal Data when we believe in good faith that disclosure is necessary to protect your safety or the safety of others, investigate fraud, or respond to a government request.

Data Transfer

Personal Data may be transferred to other countries of the European Union where the premises or the servers of UFT or of any of its suppliers are located. In this case an adequate level of protection is ensured (GDPR. Art. 45 & Art. 32).

Security of Personal Data

All Personal Data collected and processed through the Website will be stored and processed so as to minimize the risk of destruction, loss (including accidental loss), unauthorized access / use or incompatible use with the initial purpose of collection. This is achieved by the technical and organizational security measures put in place by UFT.

Retention of Personal Data

Generally, UFT will keep your Personal Data only for as long as strictly necessary, according to the reason for which it was collected:

• Personal Data processed for Service Provision will be kept by UFT for the period deemed strictly necessary to fulfil such purposes. Information will, however, be kept for longer if we need it to address any claims regarding the services or to protect UFT’s interests related to potential liability related to the Service Provision.

• Personal Data processed for Marketing and Profiling will be kept by UFT from the moment you give consent until the latter is withdrawn. Where it is not withdrawn, consent will be asked to be renewed at fixed intervals of 24 months. Once consent is withdrawn (or not given, following a renewal request), Personal Data will no longer be used for these purposes, although it may still be kept by UFT as it may be necessary to protect UFT’s interests related to potential liability related to this processing. Personal Data processed for Soft Spam will be kept by UFT from the moment where it is provided by you to UFT until you object to this processing. Once you have objected, Personal Data will no longer be used for these purposes, although it may still be kept by UFT, in particular as may be necessary to protect UFT’s interests related to potential liability related to this processing.

• Personal Data processed for Compliance will be kept by UFT for the period required by the specific legal obligations for which the Personal Data was processed.

• Personal Data processed for preventing Misuse/Fraud and Analytics will be kept by UFT for as long as deemed strictly necessary to fulfil the purposes for which it was collected.

After such periods, all data shall be deleted or anonymized, except that data we are required by law to keep for a longer period.

What are your rights? How can you exercise them?

As a data subject, you are entitled to exercise the following rights, at any time:

- Obtain confirmation as to the existence of your Personal Data being processed by UFT, access and obtain copy of such data;

- Update, modify and/or rectify your Personal Data where it may be inaccurate or incomplete;

- Erasure of your Personal Data

- Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent UFT from processing your Personal Data for a given purpose;

- Object to processing of Personal Data that is made for the purposes of sending advertising material, carrying out direct sales, market researches or for commercial communication;

- Withdraw your consent to processing (for Marketing and Profiling), where your consent serves as the legal basis for processing – this will not affect the lawfulness of processing carried out prior to your withdrawal.

- Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, or that the processing is unnecessary or unlawful, as well as where you have objected to the processing;

- Portability – you have the right to obtain a copy of the Personal Data you provided to UFT in a structured, commonly used and machine-readable format, as well as to request the transmission of those Personal Data to another data controller;

At any time, you shall be entitled to exercise the rights established by the law in force, by addressing the relevant request to our Privacy Department at physical and email address: privacy@UFT.com.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us

Finally, you are entitled to file complaints with to your local EU Data Protection Authority or to the data protection authority of Country of the UFT entity (CNPD at https://cnpd.public.lu/fr/support/contact.html), if you believe that we have handled your information in an unlawful manner.

Amendments

This Privacy Policy entered into force on December 16, 2017. Last modified: 06 March 2019

UFT reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. If UFT makes any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. UFT therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how UFT collects and uses Personal Data.