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Pyaza European Regional Privacy Notice
This European Regional Privacy Notice (the “Notice”) supplements Pyaza’s Global Privacy Policy and applies specifically to users (Members and Visitors) located within the European Economic Area (EEA), Switzerland, and the United Kingdom (collectively, the "Designated Countries"). If there is any conflict between this Notice and the Global Privacy Policy, the terms of this Notice will take precedence.
Pyaza is committed to complying with the General Data Protection Regulation (GDPR) and other applicable data protection laws. This Notice outlines your rights as a user in the Designated Countries and provides additional information about how we process your personal data in accordance with these laws.
Data Controller
For users located in the Designated Countries, Pyaza Limited, registered in Malta, is the data controller of your personal data. This means Pyaza Limited is responsible for determining the purposes and means of processing your personal data.
If you are located in the United Kingdom, Pyaza Limited also acts as the data controller of your personal data in compliance with the UK General Data Protection Regulation (UK GDPR).
You can contact us with any questions about this Notice or about your rights as outlined in the Contact Us section of this Notice.
Legal Bases for Processing Your Data
Pyaza only processes your personal data when we have a legal basis to do so under GDPR. The legal bases we rely on for processing your data include the performance of our contract with you, compliance with legal obligations, and where we have legitimate interests or have obtained your consent.
Below is a summary of the legal bases we rely on for processing your data and the specific purposes for which we use your data.
To Perform Our Contract with You
We process your personal data when it is necessary to provide you with the Services under our User Agreement. If you do not provide the required personal data, we may be unable to perform our contractual obligations, and as a result, you may not be able to access our Services.
Why and How We Use Your Data:
To register and manage your Pyaza account.
To enable you to access our Platform and Services, including choosing your preferences and setting up your profile.
To deliver core services such as providing access to your profile, facilitating connections, and sharing posts and messages with other Members.
To ensure the Platform functions according to your preferences (e.g., language settings).
Data We Use:
Account Information: Your name, email address, login details, and any other information you provide when creating an account.
Service Usage Data: IP address, device information, location data, and other online identifiers collected through cookies or other tracking technologies.
Consent
In certain situations, Pyaza processes your personal data based on your explicit consent. Consent under the GDPR must be freely given, specific, informed, and unambiguous, meaning that you are fully aware of how your data will be used and have the ability to choose whether to allow it.
You may be asked to provide consent for specific types of data processing, such as for the use of cookies, marketing communications, or processing sensitive personal data (e.g., data revealing racial or ethnic origin, political opinions, religious beliefs, or health data).
Where Pyaza relies on your consent to process your personal data, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing carried out before you withdrew your consent.
Below, we outline why and how we use your data when we rely on consent, along with the specific data we use for these purposes.
Why and How We Use Data
Data We Use
Marketing Communications: We send you direct marketing communications and promotional materials based on your consent. You can withdraw consent at any time by adjusting your settings or using the "unsubscribe" link in any communication.
- Contact information: email address, phone number (if provided).
- Profile information: name, job title, industry.
- Interaction data: engagement with previous communications, preferences.
Cookies and Similar Technologies: We use cookies and similar tracking technologies to understand your preferences, show you relevant content and ads, and optimize your experience on our platform. You can manage your cookie preferences or withdraw consent through our Cookie Policy.
- Device data: IP address, device ID, browser type, operating system.
- Online identifiers: cookie data, session activity, browsing behavior, preferences.
Processing Sensitive Data: In limited cases, we may process sensitive personal data with your explicit consent. For example, if you voluntarily include sensitive information in your profile or posts. You can modify or delete such information at any time.
- Sensitive personal data: information related to racial or ethnic origin, political views, religious beliefs, or health, if provided.
- Profile data: personal interests, affiliations.
How to Withdraw Your Consent
You can withdraw your consent at any time through the following methods:
Marketing Communications: You can opt out of receiving marketing or promotional emails by following the unsubscribe link in the message or by adjusting your settings within your Pyaza account.
Cookies and Tracking Technologies: You can manage your cookie settings through our Cookie Policy or your browser settings to stop or limit the use of cookies and similar technologies.
Sensitive Data: If you have provided sensitive personal data in your profile or posts, you can remove or modify this information by editing your profile or content within your account.
Impact of Withdrawal: Please note that withdrawing your consent may affect certain features of the platform. For example, if you disable cookies, certain services, like personalized content and targeted advertisements, may not function correctly.
Legitimate Interest
In some instances, Pyaza processes your personal data based on our legitimate interests. This means that we have a genuine, reasonable purpose for processing your data, which is balanced against your privacy rights. When processing data under legitimate interest, we ensure that it does not infringe on your rights and freedoms and provide you with the option to object to this processing in certain cases.
Below is an explanation of why and how we use your data, the data we use, and the legitimate interests we rely on for this processing.
Why and How We Use Data
Data We Use
Legitimate Interests Relied On
Service Improvements: We analyze how users interact with our Platform to improve functionality, develop new features, and ensure optimal performance for all users.
- Usage data: pages viewed, time spent on the platform, clicks, interactions.
- Device data: IP address, browser type, operating system.
Improving the platform’s performance and user experience.
Personalized Content: We process your data to provide recommendations for relevant content, connections, or events tailored to your activity on the Platform.
- Profile data: industry, job title, interests.
- Activity data: posts liked or shared, groups or events participated in.
Offering a more relevant and personalized experience to increase user engagement.
Security and Fraud Prevention: We process data to maintain the security of the Platform, prevent fraud, detect malicious activities, and investigate suspicious behavior.
- Device data: IP address, login activity, geolocation, session information.
- Account data: login history, email address, account status, access logs.
Protecting users’ accounts and safeguarding the platform against threats and fraud.
Direct Marketing: Based on our legitimate interest in promoting our services, we may send you communications about updates, promotions, or relevant offerings.
- Contact information: name, email address.
- Profile data: industry, interests.
- Interaction data: engagement with previous marketing materials, platform interactions.
Promoting Pyaza’s products and services to users in a relevant way that enhances their experience.
Customer Support: We process your data to resolve issues, troubleshoot problems, and respond to your inquiries about our Services.
- Account data: name, email address, membership status.
- Communication data: support inquiries, chat transcripts, correspondence.
Ensuring timely and effective customer service to resolve issues and maintain user satisfaction.
Analytics and Reporting: We analyze trends and user behavior across the Platform to generate insights that help us make informed business decisions and report on performance.
- Usage data: platform interactions, feature usage, engagement levels.
- Demographic data: age, location, gender (if provided).
- Aggregated data: anonymized data for trend analysis.
Optimizing business performance and making informed decisions for the benefit of the company and its users.
Platform Management: We process data to ensure the continued operation, stability, and security of our Platform infrastructure, including managing technical and operational aspects.
- Device data: IP address, browser version, device type, operating system.
- System logs: server interactions, error logs, system diagnostics.
Maintaining the security, stability, and performance of the platform to provide a seamless user experience.
Business Operations: We use your data to support our business operations, including maintaining internal databases, conducting audits, and ensuring compliance with corporate policies.
- Administrative data: account registration information, subscription details, billing information.
- System logs: access history, timestamps, user interactions for compliance and auditing.
Ensuring efficient and lawful business operations, including auditing, compliance, and financial record-keeping.
Research and Development: We use aggregated or anonymized data for research and development purposes to innovate, test, and develop new features or services.
- Aggregated data: anonymized interactions, user feedback, usage statistics.
- Profile data: anonymized demographic details for testing and feature development.
Improving our platform and services through innovation and new feature development based on non-personally identifiable data insights.
Legal Compliance and Defending Rights: We process personal data to comply with legal obligations, or where necessary, to protect or defend our legal rights or interests.
- Legal data: records of communication, contractual agreements, transaction history.
- Compliance data: data required for investigations, legal proceedings, or compliance reviews.
Fulfilling legal obligations and protecting Pyaza’s rights in case of disputes or regulatory requirements.
Internal Research and Surveys: We may invite you to participate in surveys or internal research to help us understand user needs and improve our Platform and Services.
- Contact data: email address (for survey invitations).
- Survey responses: feedback, preferences, suggestions.
- Demographic data: age, location, industry, if provided in responses.
Understanding user needs, improving services, and collecting insights for product development.
Recruitment and Talent Acquisition: We may process your data when you apply for a position at Pyaza or express interest in employment opportunities.
- Application data: CV, cover letter, professional experience.
- Contact data: email address, phone number.
- Interview records: feedback from interviews and references.
Attracting and hiring talent to grow our team, ensuring the right candidate fit for available roles.
Maintaining Platform Integrity and Preventing Misuse: We process your data to detect and prevent activities that violate our terms, such as spamming or abusive behavior.
- Usage data: posts, comments, messages, interactions.
- Security data: IP address, login history, session data.
- Account data: email address, account activity, access logs.
Protecting the platform from misuse and ensuring a safe environment for all users.
Third-Party Vendor Management: We may share some data with third-party vendors who provide services that support Pyaza, such as hosting, payments, and analytics.
- Vendor data: name, email address, vendor performance details.
- Payment data: transaction records, billing information (if related to vendor services).
Managing relationships with third-party vendors and ensuring the proper delivery of contracted services.
Engagement with Pyaza Events: We process your data when you participate in virtual or in-person events hosted or co-hosted by Pyaza.
- Event registration data: name, email address, job title, company name.
- Interaction data: event participation, feedback, post-event surveys, networking interactions.
Facilitating event participation and enhancing the user experience at events.
Compliance with Industry Standards and Certifications: We may process data to ensure that we meet industry best practices and maintain certifications or audits.
- Audit data: system logs, security protocols, compliance records.
- Certification data: information related to third-party assessments or security certifications.
Maintaining industry certifications and ensuring Pyaza’s compliance with best practices in data security and operations.
Responding to User Feedback or Feature Requests: We may process your feedback and feature requests to better understand how to improve Pyaza’s services and offerings.
- Feedback data: comments, suggestions, feature requests.
- Contact data: email address, name (if provided with feedback).
Improving services by incorporating user feedback and requests into platform enhancements.
How to Object to Processing Based on Legitimate Interest
You have the right to object to the processing of your personal data based on legitimate interest in certain circumstances. If you wish to object, you can do so by contacting us through the methods provided in the Contact Us section of this Notice, or by adjusting your account settings.
In particular, you can object to:
Personalized Content Recommendations: You can adjust your preferences in the settings to limit the personalization of content or professional connections based on your activity.
Marketing Communications: While we may send marketing communications based on legitimate interest, you can opt out at any time by using the unsubscribe link in the message or adjusting your communication preferences in your account.
Please note that if you object to certain types of processing, some features or services on the Platform may be limited.
Compliance with Legal Obligations
Pyaza processes personal data to comply with legal obligations imposed by applicable laws and regulations. These obligations may require us to preserve, disclose, or process certain information as necessary to comply with legal requests from law enforcement agencies, regulatory bodies, courts, or other authorities. New legal requirements may also arise over time, necessitating the processing of personal data in different ways.
Below are examples of some of the legal obligations that Pyaza complies with, along with the types of personal data we process to meet these requirements:
Applicable Laws
Our Legal Obligations
Civil and Commercial Laws: e.g., Regulation (EU) No 1206/2001 on evidence cooperation.
To comply with court orders that may require us to process and disclose personal data for civil or commercial legal matters.
Criminal Laws: e.g., Prevention of Money Laundering Act, Criminal Code.
To comply with search warrants, subpoenas, or other legal orders related to criminal investigations.
Consumer Protection Laws: e.g., Consumer Affairs Act.
To comply with regulatory inquiries or requests requiring the processing of personal data to protect consumer rights.
Company and Tax Laws: e.g., Company Act, Value Added Tax Act.
To comply with tax reporting obligations, audits, and other corporate regulatory requirements.
Data Protection Laws: e.g., General Data Protection Regulation (GDPR), ePrivacy Directive.
To comply with data protection regulations and respond to inquiries from supervisory authorities or data protection bodies.
The type of data we process for legal compliance depends on the nature of the request or legal obligation. For example, court orders may require us to process personal information such as contact details, usage data, or account activity.
Public Interest
In some cases, Pyaza processes personal data when necessary to carry out tasks in the public interest. This could include processing data to protect public safety, prevent harm, or comply with legal standards that serve the public interest.
Why and How We Use Data
Protection of Public Safety: We may process personal data to detect and prevent illegal activities or harm to others, such as monitoring suspicious activity to protect against fraud or abuse on the platform.
Data We Use
Account Information: Information such as user profiles, account activity, and messages may be processed to identify and mitigate potential risks.
Content Data: Posts, messages, or shared content that is flagged as inappropriate or harmful may be reviewed to prevent abuse or harm to the public or our users.
Data Sharing with Third Parties
In addition to what is covered in Pyaza’s Global Privacy Policy, we provide further details on how we share personal data with third parties to support the operation of our Services, comply with legal obligations, and enhance user experience. We only share data when necessary and ensure that third parties are obligated to protect your data and use it only in accordance with our instructions.
Third-Party Service Providers
Pyaza collaborates with third-party providers who assist us in operating our Platform and delivering services to you. These providers include but are not limited to:
Cloud Service Providers: Hosting and data storage providers that securely store your information.
Payment Processors: Providers that handle payment transactions securely and comply with financial regulations.
Analytics and Marketing Partners: Companies that help us analyze usage patterns and deliver personalized content or ads.
Customer Support Services: External support teams who help manage inquiries and resolve issues on behalf of Pyaza.
Security Providers: Services that assist in maintaining platform integrity and preventing fraud or abuse.
Regulators and Law Enforcement Agencies
Pyaza may share your data with regulators, government authorities, or law enforcement agencies if required by law. This includes responding to legal requests such as subpoenas, search warrants, or regulatory inquiries. For example, we may disclose account information or communications data in response to a lawful request to comply with a legal investigation.
Affiliates
We may share your data with Pyaza-affiliated entities for internal business purposes or in connection with joint offerings. For example, this could involve sharing data with Pyaza subsidiaries or other related entities to manage platform operations or enhance user features.
With Other Organizations for Safety and Security
To ensure the security of our platform and protect our users, we may share data with other companies or organizations facing similar threats. For example, we may exchange information with other technology companies to address common security challenges or prevent fraudulent behavior across platforms.
How You Can Control Your Data
As a user of Pyaza, you have several rights regarding your personal data. These rights allow you to access, correct, delete, or restrict the processing of your data. You also have choices regarding how your data is collected, used, and shared.
Accessing Your Data
You can access and download your personal data at any time. Pyaza will provide your data in a structured, commonly used, and machine-readable format. To access your data, visit the Data Privacy section of your account settings.
Correcting and Rectifying Your Data
You can review and update your profile and personal information directly through your account. If any personal data cannot be edited in your settings, you can contact Pyaza’s support team to request changes.
Deleting Your Data
You have the right to request the deletion of your personal data. Most profile and account-related data can be deleted directly via your account settings. For data that cannot be deleted through your settings, you can contact us and submit a Data Deletion Request.
Restricting the Use of Your Data
If you believe your personal data is inaccurate or being processed unlawfully, you have the right to request that we restrict the processing of your data. This can be done by contacting us or submitting a Data Restriction Request through our support team.
Objecting to the Use of Your Data
You have the right to object to the processing of your personal data where it is based on legitimate interest or public interest. To exercise this right, contact us using the details in the Contact Us section. If you object to the processing of your data for direct marketing purposes, we will stop using your data for this purpose.
Withdrawing Consent
Where Pyaza relies on your consent to process your data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing before the withdrawal.
Data Retention
Pyaza retains your personal data for as long as necessary to provide you with our Services. We retain data provided by you, data generated through your use of the platform, and data inferred from your interactions, as long as your account is active.
Account Data: Your data will be retained for the duration of your account’s activity. If you close your account, your personal data will be deleted within a reasonable period, except where retention is necessary for legal or regulatory reasons.
Profile and Content: Content and information you’ve shared with others may remain visible to others (e.g., posts, messages) even after you delete your account. In some cases, content may remain in backup systems for a limited time.
Legal Retention Requirements: We may retain certain data for longer periods as required by law, such as to comply with regulatory obligations, resolve disputes, or enforce our agreements.
Transfers of Your Data Outside the Designated Countries and the UK
Pyaza may transfer your data outside the European Economic Area (EEA), the United Kingdom, or Switzerland, including to countries that may not have the same data protection laws as those in your jurisdiction. These transfers are carried out in accordance with applicable data protection laws to ensure that your data is protected.
Legal Mechanisms for Transfers
Standard Contractual Clauses (SCCs): We use European Commission-approved SCCs to ensure that appropriate data protection standards are in place when transferring personal data outside of the EEA, UK, or Switzerland.
Adequacy Decisions: Where applicable, we rely on decisions from the European Commission that determine whether a country outside the EEA provides an adequate level of data protection.
Contacting Your Supervisory Authority
If you have any concerns about Pyaza’s handling of your personal data, you have the right to raise the issue with your local Supervisory Authority. If you believe that we have not addressed your concern to your satisfaction, you can lodge a complaint with the data protection authority in your jurisdiction.
Contact Us
If you have questions about this Privacy Notice or if you would like to exercise your rights concerning your personal data, you can reach us in the following ways:
Online: Contact our support team via the Help Center on the Pyaza Platform.
By Mail:Pyaza Ltd℅ Data Protection Officer29, San Gwann Street, Gharghur, Malta