Privacy statement AuroMasters

As a user of the AuroMasters platform (hereinafter referred to as "you" or "your"), your personal data is collected and processed by AuroMasters NV, with its registered office at Kievistraat 42, 2400 Mol and registered under company number BE 1005.197.142 in its capacity as data controller (hereinafter referred to as "we", "us", "our").

1. Scope of the Privacy Statement

This privacy statement (hereinafter "Privacy Statement") applies to you for your personal data that we collect and process through AuroMasters. It contains important information about how and for what purposes we collect and process personal data, and clarifies what rights you can exercise as a data subject. Therefore, please read this Privacy Statement carefully.

We are committed to protecting your (personal) data with the utmost care and only processing it in a fair and lawful manner in accordance with the provisions of the Applicable Data Protection Laws, including, but not limited to, the EU General Data Protection Regulation (GDPR) and the corresponding national laws of the EU member states; the UK GDPR and the UK Data Protection Act 2018, the Japanese Act on the Protection of Personal Information (APPI); the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA); the Virginia Consumer Data Protection Act (VCDPA); and the Colorado Privacy Act (CPA).

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2. Overview of Purposes, Personal Data and Legal Basis

Personal data can be defined as any information that directly or indirectly identifies a natural person. You may provide your personal data to us in the context of the following activities, for the corresponding purposes and on the basis of the stated legal basis.

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Correspondence:

Purpose: To handle your question or message.

Category of Personal Data: Name; email address; Question or message.

Legal basis: Necessary for the performance of a contract or to take steps at your request prior to entering into a contract.

Source: Provided by you when you fill in the contact form or contact us via info@auromasters.com.

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Survey/feedback:

Purpose: To assess, evaluate and improve the services offered. To do this, we may send out questionnaires or customer surveys or ask you to fill in our feedback form.

Category of Personal Data: Name; Email address.

Legal basis: Legitimate interest. In this case, we have a legitimate interest in improving our services.

Source: Provided by you following your purchase of goods or services from AuroMasters.

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Contract management of suppliers and partners:

Purpose: For entering into agreements and managing our contractual relationships.

Category of Personal Data: Contact details.

Legal basis: Necessary for the performance of a contract or to take steps at your request prior to entering into a contract.

Source: Provided by you in response to your request to become a supplier or partner.

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Create an account:

Purpose: To have access to the service.

Category of Personal Data: Surname and first name, e-mail address, Date of birth, language preference.

Legal basis: Necessary for the performance of an agreement.

Source: Provided by you when you create your AuroMasters account.

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Personalization account:

Purpose: Customization.

Category of Personal Data: listening history; profile picture; profile name; speaker layout;preferences music genres.

Legal basis: Consent. This information can be supplemented in the account without obligation.

Source: Obtained from you during the course of the service.

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Manage payments:

Purpose: Payments.

Category of Personal Data: Surname and first name; Place of residence; currency; purchase price; Payment method; purchase reference; purchase status.

Legal basis: Legal obligation.

Source: Provided by you after the purchase of credits.

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Executing trades:

Purpose: Agreement.

Category of Personal Data: Email address; user ID; currency; purchase price; Payment method; User balance; product and quantity; purchase reference; purchase status.

Legal basis: Necessary for the performance of an agreement.

Source: Provided by you when purchasing credits.

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Platform security and service delivery:

Purpose: Security & Delivery.

Category of Personal Data: Email address; Address; payment and purchase data; device data.

Legal basis: Legitimate interest.Our legitimate interests here include protecting the AuroMasters service and our users from fraud and other illegal activities.

Source: Received from you during the service.

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Marketing purposes:

Purpose: Direct marketing campaigns to inform you about promotions related to the products and services we provide.

Category of Personal Data: Name; email address; Preferences/Purchase history.

Legal basis: Legitimate interest where the content relates to the same or similar service that you already purchase from AuroMasters Consent for other products or services.

Source: Received from you at the start of and during the service.

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Where the processing of your personal data as indicated in the table above is a legal or contractual requirement, or a requirement necessary to enter into a contract, you are obliged to provide the personal data. If you refuse to do so, we may not be able to enter into an agreement with you.

Furthermore, AuroMasters uses cookies. Cookies are files that are stored on your phone, tablet or computer when you visit a website. You can find information about how we use cookies and how you can manage your cookie preferences in our cookie policy.

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3. Your rights as a data subject

Subject to the conditions and limitations of the Applicable Data Protection Laws, you may exercise the following rights as a data subject:

3.1. Right to access your personal data

The right to request access to your personal data, to request a copy of the personal data we collect about you and additional information about how we process your data.

3.2. Right to rectification

The right to have inaccurate personal data corrected or to complete incomplete personal data we hold about you.

3.3. Right to erasure ("right to be forgotten")

The right to have your personal data deleted from our systems.

The request to delete your personal data cannot always be granted due to, for example, contractual or legal obligations. We will comply with these obligations when responding to your request.

3.4. Right to object

The right to object to the processing of your personal data if the processing is based on our legitimate interest or on grounds of public interest. We will stop processing unless we can demonstrate compelling legitimate grounds for further processing or for the exercise of legal claims.

You can also object if we process your data for direct marketing purposes, so that the personal data is no longer processed for these purposes.

3.5. Right to withdraw your consent

For the processing of your personal data collected by us with your consent, you can withdraw your consent at any time. For example, you can unsubscribe from newsletters at any time. However, withdrawing your consent will not affect the lawfulness of processing based on consent before it was withdrawn.

3.6. Right to restriction of processing

In certain cases, you have the right to have the processing of your personal data restricted. If you successfully exercise this right, we will continue to store your data but limit its use. For example, you can make this request if you believe that your personal data is inaccurate or if the processing by us is not justified. We only need to complete these requests in specific cases, as determined by law.

3.7. Right to portability of personal data

The right to obtain your personal data processed by us in a structured, commonly used and machine-readable format and/or to have this data transmitted or copied to another controller.

The above rights can be exercised free of charge by sending an e-mail to privacy@auromasters.com or by post to Kievistraat 42, 2400 Mol attn. CRANIUM.

Subject to legitimate exceptions under Applicable Data Protection Laws, we undertake to respond to your request within one month of receipt. We may first ask for additional information to confirm your identity and to ensure that the request is from you.

3.8. Right to lodge a complaint

If you believe that we are violating your data protection rights, you have the right to lodge a complaint with the Belgian Data Protection Authority: Data Protection, Drukpersstraat 35, 1000 Brussels, Tel +32 (0) 2 274 48 00, e-mail: contact@apd-gba.be.

4. Receivers

We will refrain from disclosing or selling your personal information to third parties and disclosing your personal information, except in the following specific cases:

• Personal data may be shared with third-party service providers to whom we have outsourced certain processing activities. In any case, they are limited to processing your personal data in accordance with our instructions and, if necessary, a data processing agreement will be concluded so that they are obliged to comply with any obligations required by the Applicable Data Protection Legislation;

• if required by applicable law or regulation.

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5. International transfers

We will comply with Applicable Data Protection Laws in relation to providing adequate protection for the transfer of personal data to recipients in countries outside the European Economic Area ("EEA").

In the event that we transfer your personal data to a third country or international organisation outside the EEA, we will ensure that your personal data is transferred to third countries deemed to provide an "adequate" level of protection by the European Commission (a list of appropriate third countries is available on the European Commission's website),  or, alternatively, where your personal data is not transferred to a country that provides an adequate level of protection, we will ensure appropriate safeguards in place with the entity receiving your personal data (e.g., the EU Standard Contractual Clauses or Binding Corporate Rules, taking into account additional requirements related to international transfers such as additional measures) to ensure that your personal data continues to be protected in accordance with the Applicable Data Protection Laws.

If you would like to receive more information or a copy of these safeguards, please contact us at the following email address: privacy@auromasters.com.

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6. Retention of your personal data

We do not store your personal data longer than is strictly necessary to achieve the purposes for which we received the data. The retention periods differ depending on the type of processing activity and the purpose for which the personal data was collected.

Personal data that we collect on the basis of your consent will be retained by us for as long as your consent remains valid.

In all cases, personal data may be kept for a longer period if there is a legal or regulatory reason for doing so, or for a shorter period of time if you object to the processing of your personal data and there is no longer a legitimate reason to keep it. We guarantee that your personal data will be deleted or anonymized once the retention period has expired.

In particular, we retain personal data for the following periods:

• Your account details and associated metadata: until your account is deleted. In the event of prolonged inactivity of your account, you will be contacted to confirm that you will continue to keep your account. In the absence of a response within a certain period after additional reminder, AuroMasters will proceed to delete your account;

• Invoicing data and associated metadata: for 10 years, from 1 January of the year following the date of issue of the invoice

AuroMasters may deviate from these retention periods where our legal or contractual obligations require it, such as by legitimate order of the government, in the context of an investigation or a process.

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7. Contact details

AuroMasters has appointed CRANIUM (https://www.cranium.eu/nl/) as an external advisor on Privacy and protection of personal data.

If you have any comments or questions about the information contained in this Privacy Notice, or about any other issues relating to our processing of your personal data, please contact us at privacy@auromasters.com.

If you prefer to contact us by post, you can do so at the following address:

Kievitstraat 42, 2400 Mol, directed to CRANIUM.

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8. Changes to our Privacy Statement

We may change or update this Privacy Notice from time to time to reflect changes in our practices regarding the processing of your personal data or changes in Applicable Data Protection Laws. We will do this by posting the updated version on this website. When we post changes to our Privacy Statement, we will change the date and version number of the "last update" of our Privacy Statement. Important changes will be announced on our homepage. Nevertheless, we recommend that you read our Privacy Statement regularly.

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