PASKAL PRIVACY POLICY

1. OUR APPROACH TO PRIVACY
   • Paskal Technologies (“Paskal“, “we“, “our“, or “us“) is committed to protecting and respecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information“) and information regarding our use of cookies and similar technologies.
   • Paskal operates a Service at paskal-group.com (the “Service“). The Service provides information on Paskal’s various products from greenhouses, orchards and vineyards and net connectors’ accessories to irrigation monitoring solutions for agriculture.
   • This privacy policy applies to our Service. Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this privacy policy.
   • Paskal is the data controller of the personal information we hold about you.
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
   • We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, fill in a form on our Service, create or edit your user profile on the Service, correspond with us by phone, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to a survey, post comments in forums, enter a promotion, or use some other feature of our Service. We may also collect personal information from third parties, such as social networks.
   • We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.
   • The table at Annex 1[1] sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of the personal information.
   • We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.
   • The table at Annex 2[2] sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of the personal information.
   • We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
   • We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features. We may also share such anonymised information with others.
   • We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.
3. RECIPIENTS OF PERSONAL INFORMATION
   • In addition to the recipients listed in Annex 1 and Annex 2, we may also share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2):
     • Other companies in the same group as us: our subsidiaries (i.e. any organisation we own or control) or our holding company or ultimate holding company (i.e. any organisation that owns or controls us) and any subsidiaries they own. These companies will only use your personal information in the same way as we can under this privacy policy.

• Service providers and advisors: we may share your personal information with third party vendors and other service providers, , that perform services for us or on our behalf, which may include providing mailing, email or chat services, fraud prevention, web hosting, web programing, data storing, system networking or providing analytic services.
• Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
• Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Use; and/or (iii) exercise or protect the rights, property, or personal safety of Paskal, its users or others.

4. MARKETING AND ADVERTISING
   • From time to time we may contact you with information about our products and services. Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
   • We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details. You can change you preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing messages.
   • You can let us know at any time that you do not wish to receive marketing anymore by sending an email to us at [info@paskal-group.com].
   • You can also change your marketing preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or logging into your account on our Service and changing your preferences.
   • Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service.
5. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
   • Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. For more information about our security measures, please contact us using the contact details below. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
   • International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Union (“EU”), your personal information may be processed outside of the EU including in the United States; these international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.
6. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
   • In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
     • Right of access. You have the right to obtain:
       • confirmation of whether, and where, we are processing your personal information;
       • information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
       • information about the categories of recipients with whom we may share your personal information; and
       • a copy of the personal information we hold about you.
     • Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
     • Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
     • Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
     • Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
   • If you wish to exercise one of these rights, please contact us at: info@paskal-group.com.
   • You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
7. COOKIES AND SIMILAR TECHNOLOGIES
   • Our Service uses cookies to distinguish you from other users of our Service. This helps us to provide you with a good experience when you browse our Service and also allows us to improve our Service.
   • Cookies are pieces of code that allow for personalisation of our Service experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes.
   • We use the following types of cookies:
     • Strictly necessary cookies. These are cookies that are required for the operation of our Service. They include, for example, cookies that enable you to log into secure areas of our Service, use a shopping cart or make use of e-billing services.
     • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Service when they are using it. This helps us to improve the way our Service works, for example, by ensuring that users are finding what they are looking for easily.
     • Functionality cookies. These are used to recognise you when you return to our Service. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
     • Targeting cookies. These cookies record your visit to our Service, the pages you have visited and the links you have followed. We will use this information to make our Service and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose.
     • Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our Service. These third parties are responsible for setting out their own cookie and privacy policies.
   • The cookies we use are designed to help you get the most from the Service but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our Service. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.
     • Cookie settings in Internet Explorer
     • Cookie settings in Firefox
     • Cookie settings in Chrome
     • Cookie settings in Safari weband iOS.
   • We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect information about how you use or connect to our Service, or the types of other Services, social media services, content and ads that you (or others using your device) visit or view or connect to our Service. Typically, this information is collected through cookies and similar tracking technologies.
   • Google Analytics:
     We may use a tool called “Google Analytics” to collect user interaction data with our website. Google Analytics collects information such as how often users visit our website, what pages they visit when they do so, and what other websites they used prior to coming to our website. We use the information we get from Google Analytics to maintain and improve our website and in order to adjust your browsing and usage experience on our website and derive statistical insights in those aspects. You can find further information on the Google website at https://www.google.com/intl/en/policies/technologies/ads/, and you can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. We may also collect and use other analytics tools to collect information about the use of our website and types of technical data in the context of the use of our website, including information about your computer or mobile device or any other device and system, software, location data, time zone, internet protocol (IP) address, language preference etc.
   • If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links (please bear in mind that there are many more companies listed on these sites than those that drop cookies via our Service):
     • Your Online Choices (https://www.youronlinechoices.com/)
     • Network Advertising Initiative (https://www.networkadvertising.org/)
     • Digital Advertising Alliance (https://www.aboutads.info/consumers)
   • If you would like to find out more about cookies and other similar technologies, please visit allaboutcookies.org or the Network Advertising Initiative’s online sources at www.networkadvertising.org.
8. LINKS TO THIRD PARTY SITES

Our Service may, from time to time, contain links to and from third party Services, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these Services, please note that these Services have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those Services.

9. OUR POLICY TOWARDS CHILDREN
   • Our Service is not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
10. CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

11. NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

“If you would like assistance with reviewing the Paskal terms and conditions that are currently on the website, please let us know and we would be happy to help with this. The current terms and conditions relate to the sale of products and our understanding is that these terms will be applicable from when the Paskal products can be purchased directly from the website (please confirm if our understanding is correct). We would be grateful if you could confirm if the Paskal products are intended to be sold to consumers as well as businesses. Under English law, there are specific terms that would need to be included in product terms and conditions in respect of consumer sales.

There are currently no terms on the current website covering website terms of use (i.e. outlining what customers can and cannot do on the website, what Paskal’s liability is in relation to the website etc.) and we would suggest that Paskal incorporates a set of website terms of use. Please let us know if you would like us to draft a set of website terms and conditions for the Paskal website.

Amendments to / drafting of the above terms and conditions are not required for GDPR compliance but are recommended for best practice and in order to protect Paskal’s position in respect of its rights and liability.”

12. CONTACTING US
    • Please contact [info@paskal-group.com] if you have any questions, comments and requests regarding this Privacy Policy.
    • This privacy policy was last modified on [2] 2019.

ANNEX 1 – PERSONAL INFORMATION WE COLLECT

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY