Privacy Notice

This Privacy Notice relates to the website www.apoyo-global.com that is owned/operated by Apoyo Global.

Apoyo Global is committed to protecting your personal data. This privacy notice will tell you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Data protection is very important to Apoyo Global. It’s possible to use this website without sharing personal information but if you contact us or engage our services, we will need to process some of your personal data. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the person whose data we’re processing.

The Data Controller

The controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in EU Member states and other provisions related to data protection is Apoyo Global Ltd.

Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:

Jack Graham: info@apoyo-global.com

You may, at any time, contact us directly with all questions and suggestions concerning data protection via the email address above.

The processing of personal data, such as your name, address, e-mail address, and telephone number shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Apoyo Global. In this Privacy Notice we’re going to explain the nature, scope and purpose of the personal data we collect, use and process and your rights over that data.

As the data controller, Apoyo Global have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, web-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, you are free to transfer personal data to us via alternative means, e.g. telephone.

Cookies

This website uses cookies. Cookies are small pieces of data or text files that are stored in a computer system via an web browser.

Cookies are commonly used by websites. Each contains a cookie ID, which is a unique identifier. It consists of a character string through which web pages and servers can be assigned to the specific web browser in which the cookie was stored. This allows visited websites and servers to differentiate the individual browser of the subject from other web browsers that contain other cookies. A specific web browser can be recognised and identified using the unique cookie ID.

Through the use of cookies, Apoyo Global can provide the users of this website with more user-friendly services, such as faster download speeds, which would not be possible without the cookie setting.

You may, at any time, prevent the setting of cookies through our website by changing the settings on your web browser. Furthermore, you can delete already set cookies at any time via your web browser. This is possible in all popular web browsers; check your browser’s Help pages to find out how. But please note that deactivating cookies may affect how you use the website.

Collection of General Data and Information

This website collects a series of general data and information when you or an automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider (ISP) of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, Apoyo Global does not draw any conclusions about you. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Apoyo Global analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by you.

Contacting us via the Website

Our website contains numerous forms via which you can contact us. You can also choose to contact us directly via email. If you contact us by e-mail or via a contact form, the personal data transmitted by you are automatically stored. Such personal data transmitted on a voluntary basis by you to us are stored for the purpose of processing or contacting you. There is no transfer of this personal data to third parties.

Routine erasure and blocking of personal data

The data controller shall process and store your personal data only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Your rights

a) Right of confirmation
You have the right granted by the European legislator to ask us whether or not personal data concerning you are being processed. If you want us to confirm how we are currently using your data, please get in touch using the email address info@apoyo-global.com.

b) Right of access
You also have the right granted by the European legislator to ask how your personal data are stored at any time. Furthermore, the European directives and regulations grant you access to the following information:

  • the purposes of the processing;

  • the categories of personal data concerned;

  • the recipients or categories of recipients to whom your personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

  • the existence of the right to ask us to update or erase your personal data, or restrict the processing of your personal data, or object to such processing;

  • the existence of the right to lodge a complaint with a supervisory authority;

  • where your personal data have not been collected from you (for example information about performance in an interview), any available information as to their source;

  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.

Furthermore, the you have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, you shall have the right to be informed of the appropriate safeguards relating to the transfer.

If you wish to avail yourself of this right of access, you may, at any time, contact us and request it.

c) Right to rectification
You have the right granted by the European legislator to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If you wish to exercise this right to rectification, you may, at any time, contact us and request it.

d) Right to erasure (“Right to be forgotten”)
You have the right granted by the European legislator to ask us to erase your data without undue delay, and the we are obliged to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

  • You withdraw consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

  • You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.

  • The personal data have been unlawfully processed.

  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and you want to request the erasure of personal data stored by Apoyo Global, you may, at any time, contact any employee of the controller. An employee of Apoyo Global will promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that you have requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of Apoyo Global will arrange the necessary measures in individual cases.

e) Right of restriction of processing
You shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • You contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data.

  • The processing is unlawful and you oppose the erasure of the personal data and request instead the restriction of their use.

  • The controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.

  • You have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override yours.

If one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data stored by Apoyo Global, you may at any time contact any employee of Apoyo Global. The employee will arrange the restriction of data processing.

f) Right to data portability
You have the right granted by the European legislator, to receive personal data concerning you, which was provided to us, in a structured, commonly used and machine-readable format. You shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising your right to data portability pursuant to Article 20(1) of the GDPR, you shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, you may at any time contact any employee of Apoyo Global.

g) Right to object
You have the right granted by the European legislator to object, on grounds relating to your particular situation, at any time, to processing of personal data concerning you, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

Apoyo Global shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

If Apoyo Global processes personal data for direct marketing purposes, you shall have the right to object at any time to processing of your data for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If you object to Apoyo Global processing your data for direct marketing purposes, we will stop.

In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you by Apoyo Global for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, you may contact any employee of Apoyo Global. In addition, you are free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use your right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling
You have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between you and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between you and a data controller, or (2) it is based on your explicit consent, Apoyo Global shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and contest the decision.

If you wishes to exercise the rights concerning automated individual decision-making, you may, at any time, contact any employee of Apoyo Global.

i) Right to withdraw data protection consent
You shall have the right granted by the European legislator to withdraw your consent to processing of your personal data at any time.

If you wish to exercise the right to withdraw consent, you may, at any time, contact any employee of Apoyo Global.

Data Protection Provisions About the Application and Use of Google Analytics

On this website, the controller has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and to carry out a cost-benefit analysis of internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our website for us.

Google Analytics places a cookie on your web browser. Cookies are defined above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this website, which is operated by the controller and into which a Google Analytics component was integrated, your web browser will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, Google gains knowledge of personal information, such as your IP address, which allows Google to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by you. With each visit to our website, such personal data, including your IP address, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

You may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of your web browser used and thus permanently deny the setting of cookies. Such an adjustment to your browser used would also prevent Google Analytics from setting a cookie on your browser. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programmes.

You can object to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, you must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through JavaScript, that any data and information about the visits of web pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If your computer system is later deleted, formatted, or newly installed, then you must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by you or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

Data Protection Provisions about the Use of Dropbox

The controller uses the Dropbox “File request” feature as a means to collect and store curriculum vitae and other supporting documents from visitors to the website.

The operator of the Dropbox component is Dropbox International Unlimited Company, 5 Hatch Street Upper, Saint Kevin's, Dublin, Ireland.

The purpose of the Dropbox component is to enable website visitors to send personal data and supporting information about job roles and clients to Apoyo Global quickly and simply.

Dropbox processes your data to provide Dropbox Services to you and to the controller Apoyo Global. For example, Dropbox host your files, backs them up, and shares them when asked to by the controller. They also analyze how you and the controller use Dropbox Services.

The files you send are saved in a private Dropbox folder which is only accessible to employees of Apoyo Global who are privy to the Apoyo Global Dropbox password. Other users of the service who upload documents to Dropbox cannot see the contents of the folder.

If you do not wish to send personal information via the internet to a private Dropbox folder, the alternative is to attach your files to an email and send it to info@apoyo-global.com.

If you would like us to delete the files you have sent to us, please send an email to info@apoyo-global.com.

Legal Basis for Processing Personal Data

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which you are party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR.

The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of enquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.

In rare cases, the processing of personal data may be necessary to protect your vital interests or those of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the above-mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by your interests or fundamental rights which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator, who considered that a legitimate interest could be assumed if you are a client of the controller (Recital 47 Sentence 2 GDPR).

The Legitimate Interests Pursued by the Controller or by a Third Party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees.

Period for Which Personal Data will be Stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Your obligation to provide the personal data; possible consequences of failure to provide such data.

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that you provide us with personal data, which must subsequently be processed by us. You are, for example, obliged to provide us with personal data when our company signs a contract with you. The non-provision of the personal data would have the consequence that the contract with you could not be concluded. Before personal data is provided by you, you must contact us. We will clarify to you whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.