EEA, UK, and Swiss Privacy Notice

Last Revised: September 12, 2022

This European Privacy Notice for EEA, UK, and Swiss residents supplements the information contained in the general Privacy Notice of Armand Agra (“Armand Agra,” “we,” or “us”), which is incorporated in this European Privacy Notice by this reference.  This European Privacy Notice applies to EEA, UK, and Swiss residents from whom we collect personal information (“consumers” or “you”).  Any terms that are capitalized but undefined in this privacy notice have the meanings ascribed to them in the general Privacy Notice.

  1. Processor.  For the purpose of applicable privacy legislation, Armand Agra will act as the data processor. Armand Agra’s EU representative is [NAME].
  2. Legal Basis. Our legal basis for processing and collecting personal information varies based on the context for which it is collected. We will only use your personal data when the law allows us to. When we use your personal data, we must have a legal ground for doing so. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 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. The following are the legal grounds by which we can use your personal data:
    1. Where you have provided us with your consent for us to do so;
    2. Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you;
    3. Where we need to comply with a legal obligation to which we are subject; or
    4. Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  3. Transfers of Data. We are based out of the United States and thus may transfer your personal information across borders. We have taken appropriate safeguards to ensure your personal information is protected in accordance with this Privacy Notice through implementing additional safeguards, such as the standard contractual clauses.  This transfer mechanism may be found in our Data Processing Addendum here.
  4. Retention of Data. We will only retain personal information for as long as it is required to provide you the Services you have requested, or as otherwise required by applicable law.
  5. Your Rights.  Under certain circumstances, by law you have the right to:
    1. Request access to your personal data (known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
    2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
    3. Request the erasure of your personal data. This enables you to ask us to delete or remove personal data when there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
    4. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
    5. Withdraw your consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe instructions in the communications sent to you. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so;
    6. Complain to your local data protection authority regarding our collection and use of personal information. For more information, please contact your local data protection authority, contact information may be found here; and
    7. Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact in writing at privacy@armandagra.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, applicable law may require or permit us to decline your request, although if we do so, we will inform you of the reason unless otherwise prohibited by law.