Last update: 25th of May 2018

I. INTRODUCTION

Slate Companies (hereinafter referred to as “Slate Digital”) is a business organization engaged in the production, distribution and promotion of professional hi-end audio equipment of the brands Slate Digital. In addition it also operates a website, where it offers different services www.SlateDigital.com (“Website”).

We at Slate Digital strives to protect the personal data of our customers, users of our website as well as representatives of our clients (hereinafter referred to as “users” or ”customers” or “you”). Slate Digital is committed to ensuring that its data processing activities comply with the General Data Protection Regulation (Regulation (EU) No. 2016/679 of the European Parliament and of the Council, hereinafter referred to as: the Regulation), as well as with all other relevant and applicable data protection laws and regulations.

With this Privacy Policy, we intend to inform our customers and/or the legal representatives or contact persons of our business partners about the data being processed in connection with the commercial and service activities carried out by Slate Digital (hereinafter referred to as “Services”), their source, the purpose of data processing, its legal basis, its duration, the activities of the potentially involved data processors related to data handling, and – in case where personal data is transmitted – the legal basis of transmitting the relevant data and the scope of recipients. The document also contains information on how Slate Digital protects this data and information.

This present Privacy Policy, the Terms of Use of the Website, Cookie Policy regulates the rules Slate Digital shall comply with upon processing the personal data, collected about you or which you are providing us (Personal Data).

Please read carefully this Privacy Policy before using the Website or any of our Services, or before providing your personal data in any other way. If you do not wish Slate Digital to process your personal data in the way described in this Privacy Policy, please do not provide it. You provide your personal data voluntarily with a view to use and access our Services and/or the Website. Please be advised that in some occasions we may not be able to provide you the requested Services if you don’t provide us the minimum required information.

II. CATEGORIES OF THIRD PARTIES WHO MAY ACCESS AND PROCESS YOUR PERSONAL DATA

We may share personal data with third parties as follows:
Transport/courier companies with a view to fulfilling our contractual obligations for delivery of purchased/repaired goods or spare parts, or papers for fulfilling our contractual obligations we have either with you or with a company you are representing or which employee or agent are you; Individuals who, under Slate Digital assignment, maintain equipment and software used to process your personal data; Dealers and Distributors; Banks or other payment operators, servicing payments; Services Providers. We may share your information with other companies we use to support our Services. These companies provide services like consultancy services, bill collection, fraud detection, technical support services etc. Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information; Affiliates. We may share your information with other companies under common ownership or control with Slate Digital. These companies use your information as described in this Privacy Policy.

Safety, Security, and Compliance with Law. We may share your information to follow applicable law, or to respond to legal process – in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena). We also may share your information when: (i) there are threats to the physical safety and/or health of of you, another person, or the public generally; (ii) there are violations of this Privacy Policy or other agreements, or (iii) necessary to protect the legal rights of third parties, including our employees, users, or the public; Business Transactions. We may share your information during a corporate transaction like a merger, or sale of our assets. If a corporate transaction occurs, we will provide notification of any changes to control of your information, as well as choices you may have; Consent. We may share your information in other ways if you have asked us to do so or have given consent.

III. WHERE DO WE STORE YOUR DATA?

The data that we collect from you is stored within the European Economic Area (“EEA”).
Since Slate Digital is a multinational company, having its clients and providing its Services all around the world, we have partners (predominantly dealers/distributors and service/technical support centers) also outside the European Economic Area.

Our partners located outside the EEA are normally taking care of our customers and users that are not citizens and/or are not residing in a country Member state of the European Union. However, we may not restrict our clients and users, who are residents or residing in an EU member state, to use our Services only in the EEA or only through our partners in the EEA. Therefore, it might happen that the personal data of our EU users is transferred to and processed in a country outside of the EEA. In most cases this will be due to your request. Any such transfer of your personal data will be carried out in compliance with applicable laws.
For transfers outside the EEA, Slate Digital will use Standard Contractual Clauses and Shields as safeguards for countries without adequacy decisions from the European Commission.

IV. SECURITY OF YOUR PERSONAL INFORMATION

In accordance with the applicable laws and regulations, we have taken adequate technical and organizational measures to safeguard the security of your personal information. We store the personal information that we process on a secure database that is protected by technical access controls. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.

We restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations.

Some of the technical and organizational measures to safeguard the security of your personal information are:
using password protection or encryption, and limiting access to the data (e.g. only those Slate Digital employees may access the data who need it in order to achieve the aforementioned goals), and preventing unauthorized access to the network with the use of available IT methods, logging; providing access to the data stored on the server only to the designated persons who have sufficient authority to do so, creating backups to avoid data loss.

The customer may also assist us in protecting the data and information by regularly changing the password he uses for the registration/login processes and making sure that, third parties cannot gain access to his passwords. We urge you to log out of your Slate Digital account you have used to access our Services when you are finished using them.

Please be advised that while we strive to protect your personally identifiable data, no website or Internet transmission is completely secure. Despite all our efforts, Slate Digital cannot guarantee the security of your data completely. We make no guarantees or assurances about our ability to prevent any such loss, access, hacking or misuse and are not responsible in the event that such loss or misuse occurs.

V. CHILDREN’S PRIVACY

Our Services are not designed for and are not marketed to people under the age of 18 (“minors”). We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use our Services. If you are a minor, please do not use our Services or send us your information. Your submission of your personal data is considered for declaration that you are 18 years or more. We delete information that we learn is collected from a minor without verified parental consent. Please contact us using the email address listed in Section XI if you believe we might have information from or about a minor.

VI. SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, trade union membership or criminal background) on or through the Slate Digital Services or otherwise to us, except where explicitly requested and consented to.

VII. WHAT ARE YOUR RIGHTS?

Right of access and Information

You are entitled to receive information from us about whether the processing of your personal data is still ongoing or not. If the data processing is ongoing, you have the right to access the personal information being processed, as well as to request and receive any relevant information about the data processing of your personal data, including all the information presented in this section.

Right of Rectification/Correction

You have the right to have Slate Digital rectify inaccurate personal data concerning you without undue delay. Where the purpose of data processing makes this relevant, you are also entitled to request the completion of incomplete personal data.
If you have an Slate Digital account you can edit your personal data under your account.
Right of Erasure (“right to be forgotten”)
You have the right to have Slate Digital erase personal data concerning you without undue delay, and we are obliged to erase the personal data in question without undue delay where one of the following grounds applies:
a) the data is no longer necessary for the purposes for which they were collected or otherwise processed;
b) you withdraw your consent which served as the legal basis of processing, and there is no other legal basis available to continue processing;
c) you have objected to the processing based on the relevant provisions of the law, and there are no overriding legitimate grounds for the processing, or you have objected to the processing because it was carried out for direct marketing purposes (including profiling);
d) the personal data have been unlawfully processed;
e) the personal data must be erased to comply with a legal obligation stemming from EU or Member State law to which Slate Digital is subject;
f) the personal data have been collected in relation to the offer of information society services marketed directly to children.

Please be aware that there are certain situations (legally determined reasons), where we would not be obliged to delete the data if processing.

The right to erasure should, in particular, not imply the erasure of personal data concerning the you which have been provided by you for the performance of a contract to the extent that and for as long as the personal data is necessary for the performance of that contract.
Furthermore, the right to erasure is not applicable in cases where the duration of data processing is governed by law.

Right of Restriction

You have the right to request that Slate Digital restricts the process of your personal data under the following circumstances:
if you object to a processing based Slate Digital’s legitimate interest, Slate Digital shall restrict all processing of such data pending the verification of the legitimate interest;
if you have claim that your personal data is incorrect, personal data processing will be restricted pending the verification of the accuracy of the personal data;
if the processing is unlawful you can oppose the erasure of personal data and request the restriction of the use of your personal data instead;
if Slate Digital no longer needs the personal data but it is required by you to defend legal claims.
Slate Digital shall inform the customer (upon whose request the restrictions have been introduced) about the fact of lifting the restrictions (in the cases provided by law) prior to such event.

Right of data portability

You have the right to receive your personal data which you have submitted to us, in a structured, commonly used and machine-readable format and have the right to transmit these data to another data controller without any hindrance from Slate Digital, where both below requirements are met:
a) the legal basis for processing is consent or a contract; and
b) the processing is carried out by automated means.
Your right to object to processing based on legitimate interest
You have the right to object to processing of your personal data that is based on Slate Digital’s legitimate interest.
In this case Slate Digital shall not continue to process personal data unless Slate Digital demonstrates legitimate grounds for the procession which override your interests, rights and freedoms or those needed for the establishment, exercise or defence of legal claims.
Your right to object to direct marketing
You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.
You can opt out from direct marketing by the following means:
following the instruction in each marketing emails, usually by selecting the “unsubscribe” or “opt-out” link;
by editing the settings of your Slate Digital account;
Please note that if you opt out of receiving marketing communications from us, we may still communicate with you from time to time if we need to provide you with information about the Services you are using from us, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons, for example, if we update this Privacy Policy or our Terms of Use or if we need to communicate a common problem of a product of ours that may affect you.

Right to withdraw your consent

If personal data is processed based on your consent only you may withdraw your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.

VIII. SOURCES OF INFORMATION.

1. Information we collect from you
In most cases the personal information we process about you will be directly provided by you. The different types of information you provide us are listed below in the section of each various case of data processing.

2. Information we collect automatically when you use the platform/website
In addition to any other listed ways of collection and processing information, when you use our platform we automatically collect information about you (although not personally identifiable), including:
Log Information: We collect log information about your use of the platform, including the type of browser that you use; the time, duration and frequency of your access; web platform pages viewed; your IP address
Device Information: We collect information about the computer or mobile device that you use to access our platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Location Information: We may collect information about the location of your device each time you use our platform based. Your location data will be obtained via a cookie. Please refer to our Cookie Policy for additional information on how to manage our use of cookies. We track geolocation by other means as well (IP)
Information Collected by Cookies and Other Tracking Technologies: We and our service providers collect information using various technologies, including cookies. Cookies are small data files stored on your hard drive or in device memory that help us improve our platform and your experience. You can learn more about the types of cookies we and our service providers use by reading our Cookie Policy.

3. Information we collect from others
In some cases, in order to provide you our Services we may receive information about you from our dealers or Service/technical support centers.

IX. METHODS OF EXERCISING YOUR RIGHTS

We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to privacy@slatedigital.com or sending request to some of the contacts listed in Section XI below.

Please be advised that prior to complying with your requests regarding your rights, we are obliged to identify the person submitting the request (the username and password connected to the user profile may be sufficient for this). Where we have reasonable doubt about the identity of the natural person submitting the request, additional information may be requested to confirm its identity.

We will inform you without undue delay and at the latest within 30 days of the reception of the request about the measures taken in response to the request. If necessary, taking into account the complexity of the request and the number of requests, this deadline may be extended by two additional months. We will inform you about the extension of the deadline and shall also indicate the causes of the delay within one month of the reception of the request. When the request was made in an electronic form, unless otherwise requested by the customer and if possible, the information shall be provided in an electronic form.

X. COMPLAINING TO A DATA PROTECTION AUTHORITY

If you are a citizen of a member state of the European union or EEA, or you are residing in one of the member states or of the EEA, without prejudice to other administrative or judicial remedies, you are entitled to file a complaint with a supervisory authority – in particular in the Member State of your habitual residence, your place of work or where the suspected infringement took place – if you believe that the procession of your personal data violates the Regulation. Contact details for data protection authorities in the European Union are available here. – http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

XI. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and web beacons in our Apps and on our Website. A cookie is a small text file that is delivered with pages from the Apps or Website and which is stored by your browser on the hard drive of your computer or on your smartphone. Cookies have various functions, for example, a cookie can store your language preferences or password token. Web beacons are electronic files invisibly embedded on web pages or in email to permit the sender to track online movements of web users. Cookies and web beacons do not usually contain any information that could personally identify you. For additional information on how to manage our use of cookies, please refer to our Cookie Policy .

You can turn off the use of cookies via the settings on your computer or your smartphone. Please note, turning off cookies can result in some functions of the website or Apps not working properly.

XII. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

Name of the company: Slate Companies

Headquarters and address of management: Slate Companies, 3330 Cahuenga Boulevard West Suite 510, Los Angeles, California 90068 USA
Contact address: 3330 Cahuenga Boulevard West Suite 510, Los Angeles, California 90068 USA
E-mail address: slateco@slatedigital.com
E-mail address for data protection inquiries: sales@slatedigital.com
Webpage: https://www.slatedigital.com

XIII. UPDATES TO OUR PRIVACY POLICY

We may modify this Privacy Policy from time to time. When we do, we will provide notice to you by publishing the most current version and revising the date at the top of this page. If we consider any change to this policy as an important one, we will provide additional notice to you, such as by sending you an email or displaying a prominent notice on our Website.
Last updated: May 25, 2018