If you have any questions about this privacy notice, including any requests to exercise your legal rights, you can contact us at [email protected] and by using the details provided on our website under the section “Contact us”.

2. What personal data do we collect about you?

We collect any information relating to you that can identify you, directly or indirectly. In this respect, we may collect, use, store and transfer identity data such us your full name, date of birth, gender and contact details like your email address and telephone number. 

Overhan may also collect location data such as geographical information about the user’s specific device’s whereabouts associated with a time identifier and digital data that includes metadata (i.e. set of data that describes and gives information about other data), online identifiers, such as internet protocol addresses, cookie identifiers and other information collected when you visit our website. For more information about cookies, please read our Cookie Policy available on our website. 

Further to the above, the Company may collect website visitors’ preferences in relation to receiving information about our website/Company, namely marketing and communication data.

3. How do we collect your personal data?

We collect personal data you provide to us when visiting our website e.g. by filling the relevant contact form.  In case you access our site but do not interact further with us, we will only process data contained in cookies which are necessary to be able to run our site (see “Cookies Policy” for more info).  Should you decide to interact with us by, for example, submitting a request form, we will process the personal data you provide for the purposes stated on the form.  Some fields are mandatory as otherwise we will be unable to further process your request.

We process personal data collected via our website and other sources for the purposes set out in this Notice. 

Overhan collects your personal data when you contact us via the contact details available on our site e.g. email.  

We may also use javascript, cookies, web beacons, Local Shared Objects and other similar information to collect your personal information while browsing. These technologies are used for measurement, analytics, as well as, to improve available services and provide you with content customised to your interests. Please note that we may allow third parties to place their own cookies, web beacon and similar technologies to collect information through our services.

4. Why do we collect and process your personal data?

We collect and process your personal data for when it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Particularly to answer to your inquiry submitted via email or contact form and provide you with the services you request from us.  When filling out the contact form available on our site we will ask you to enter your personal data, such as your first and last name, email address and your message which may contain personal information depending on the subject. The relevant data you will provide will help us communicate with you, keep record of our communication, help solve any issues you might be facing, send you promotional offers and direct marketing, and inform you about our services. 

Further to the above, the collection of personal data will help us maintain and improve our services, implement other functionalities, develop new services and offers. Data collected will contribute to tailor the services to your needs and interests, provide you with tailored content aimed for a better user experience. Tailored content or services and information that are most relevant to you, thereby giving a much better and more useful experience on our website. Additionally, data collected may be used to enable the carrying out of any payment transactions including refunds, if needed. 

Further we collect data when it is necessary for the purposes of the legitimate interests of our business, particularly:

• To create and maintain a trusted and safer environment; investigating, detecting, preventing, or reporting fraud, misrepresentations, security breaches or incidents, or other potentially prohibited or illegal activities; protecting our sellers’, or your rights or property, or the security or integrity of our Services; 
• Enforcing our Terms of Use or other applicable agreements or policies;
• Verifying our client’s identity.
• Detecting and preventing online fraud and intrusions when we implement certain monitoring or tracking devices implying the processing of personal data.
• When it is necessary for the protection of your vital interests or of another natural person.
• When it is necessary for complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process; fulfilling any other purpose disclosed to you in connection with our services; contacting you to resolve disputes and provide assistance with our services.
• When it is necessary for performing a task in the public interest and this task has a clear basis in law
• When you give us your consent to process your personal data. For instance, when we offer you to register to our services and create an account, subscribe to our newsletter or marketing emails or when we ask to follow any relevant procedure to allow you to either clearly accept or refuse the envisaged data processing; if you accept, you will be entitled to withdraw your consent at any time. 

• However, in certain cases, your choice not to communicate your Personal Data or to withdraw your consent may result in a limitation of your access to our services, features or offering. For instance, it may not be possible for you to gain access to certain parts of the websites or services and for us to respond to your queries without providing the related information.

Change of purpose of processing

We will only use your personal data for the purposes for which we collected it, as described in this Notice. If Overhan, collected personal data on the basis of legitimate interest, contract or vital interests such data can be used for another purpose but only after assessing that the new purpose is compatible with the original purpose. In such a case the Company will consider the following points:

• the link between the original purpose and the new/upcoming purpose;
• the context in which the data was collected (what is the relationship between your company/organisation and the individual?);
• the type and nature of the data (is it sensitive?);
• the possible consequences of the intended further processing (how will it impact the individual?);
• the existence of appropriate safeguards (such as encryption or pseudonymisation).

For any explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If the Company intends to use the data for statistics or for scientific research, it is not necessary to run the compatibility test.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

5. Who may access your data?

For the purposes described above, we shall grant access to your personal data to authorized Overhan employees who have a need-to-know in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

In addition, we may need to transfer or allow access to the following authorized third-parties:

• Suppliers and services providers, we engage with to process personal data or perform the Overhan services on our behalf  following  our instructions and in compliance with this Notice and contractual agreement;
• Successors in title to our business (or who are in meaningful discussions about such a possibility with the (prospective) new owners of the business or company); in this respect, if ownership of all or substantially all of our business changes or undertakes a corporate reorganization or any other action or transfer between group entities, you acknowledge that we may need to transfer your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale to, or re-organization by the new owner. We may also need to transfer your personal data to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this notice;
• Legal advisers, witnesses, experts and judicial and quasi-judicial authorities our users or the public as required or permitted by law, and other third parties to enforce applicable Terms of Service, including investigation of potential violations;
• Administrative or judicial authorities in order to meet the requirements of any applicable law, regulation, legal process or enforceable governmental request.
• We may also aggregate, anonymize data publicly and to other authorized third parties and partners – like advertisers or connected sites. 

6. Where may your personal data be stored or transferred?

Due to the nature of our operations we may transfer your personal data outside the European Economic Area (EEA) to countries whose data protection laws may not be as extensive as those in the jurisdiction where you are located.  

Where this is the case, we will take steps to ensure that your personal data receives an adequate level of protection. In this respect, when we transfer data outside the EEA, we will only transfer such personal data 

• to a country which the European Commission considers having adequate data protection laws; or 
• where we have put in place an appropriate data transfer mechanism, such as standard contractual clauses, to ensure that your personal data are adequately protected, including but not limited to your consent.

7. How do we ensure the security of your personal data?

We maintain technical and organizational controls aim at protecting your personal data from loss, misuse, alteration, unauthorized access, use, alteration, disclosure, or destruction including anti-virus, firewalls, secure servers, etc. Our personnel accessing your personal data are informed on the applicable procedures and measures aim to protect the confidentiality of your personal data. Such personnel will be granted access to your personal data to the extent that they need such data to perform their duties. 

Please note however that no data transmission over the internet or website can be guaranteed to be secure from intrusion. In addition, you further acknowledge and agree that you take appropriate actions for the appropriate safeguarding of  your personal data, in particular by keeping your password secure and confidential. 

8. How long do we keep your personal data?

We will only retain your personal data for the period necessary to fulfil the purposes described in this Privacy Notice. Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized or destroyed.

Please note that we may also retain your personal data for longer periods if necessary, to comply with our legal obligations or to protect our legitimate interests.

9. Do we collect and process minors’ personal data?

In order to subscribe to our services and provide us with your personal information you must be 18 years of age or older to satisfy the minimum age in the relevant jurisdiction.

If we become aware that we have collected personal information from a minor under the age of 18 or under the minimum age provided by the law and we have not been provided with the parent’s or legal guardian’s consent, we will promptly delete that information.

10. What rights do you have?