Privacy Policy

Introduction

Welcome to the Thruwind’s privacy policy.

Thruwind respects your privacy and is committed to protecting your
personal data. This privacy policy will inform you as to 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.

This privacy policy is provided in a layered format so you can click
through to the specific areas set out below. Please also use the Glossary to
understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

  1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Thruwind collects
and processes your personal data through your use of this website, including
any data you may provide through this website when you purchase a product or
service.

This website is not intended for children and we do not knowingly
collect data relating to children.

It is important that you read this privacy policy together with any
other privacy policy or fair processing policy we may provide on specific
occasions when we are collecting or processing personal data about you so that
you are fully aware of how and why we are using your data. This privacy policy
supplements other notices and privacy policies and is not intended to override
them.

Controller

Thruwind is the controller and responsible for your personal data
(collectively referred to as, “we”, “us” or “our”
in this privacy policy).

We have appointed a data privacy manager who is responsible for
overseeing questions in relation to this privacy policy. If you have any
questions about this privacy policy, including any requests to exercise your
legal rights, please contact the data privacy manager using the details set out
below.

Contact details

If you have any questions about this privacy policy or our privacy
practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Super30 Bangladesh

Email address: info@super30bangladesh.com

Postal address: Dhaka, Bangladesh

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was
last updated on 10-09-2020.

It is important that the personal data we hold about you is accurate
and current. Please keep us informed if your personal data changes during your
relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy policy of every
website you visit.

Personal data, or personal information, means any information about
an individual from which that person can be identified. It does not include
data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal
data about you which we have grouped together as follows:

  • Identity
    Data includes first name, maiden name, last
    name, username or similar identifier, marital status, title, date of birth and
    gender.
  • Contact
    Data includes billing address, delivery address,
    email address and telephone numbers.
  • Financial
    Data includes bank account details.
  • Transaction
    Data includes details about payments to and from
    you and other details of products and services you have purchased from us.
  • Technical
    Data includes internet protocol (IP) address,
    your login data, browser type and version, time zone setting and location,
    browser plug-in types and versions, operating system and platform, and other
    technology on the devices you use to access this website.
  • Profile
    Data includes your username and password, purchases
    or orders made by you, your interests, preferences, feedback and survey
    responses. 

We also collect,
use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated
Data could be derived from your personal data but is not considered personal
data in law as this data will not
directly or indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific website
feature. However, if we combine or connect Aggregated Data with your personal
data so that it can directly or indirectly identify you, we treat the combined
data as personal data which will be used in accordance with this privacy
policy.

We do not collect
any Special Categories of Personal
Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your
health, and genetic and biometric data). Nor do we collect any information
about criminal convictions and offences.

If you fail to provide personal data

Where we need to
collect personal data by law, or under the terms of a contract we have with
you, and you fail to provide that data when requested, we may not be able to
perform the contract we have or are trying to enter into with you (for example,
to provide you with goods or services). In this case, we may have to cancel a
product or service you have with us but we will notify you if this is the case
at the time.

We use different methods to collect data from and about you
including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by
    filling in forms or by corresponding with us by post, phone, email or
    otherwise. This includes personal data you provide when you:
  • apply for our products or
    services;
  • create an account on our
    website;
  • subscribe to our service or
    publications;
  • request marketing to be sent to
    you;
  • enter a competition, promotion
    or survey; or
  • give us feedback or contact us.
  • Third parties or publicly
    available sources.
    We will receive personal data
    about you from various third parties and public sources as set out below:
  • Technical Data from the
    following parties:

  • Contact, Financial and
    Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from
    data brokers or aggregators.
  • Identity and Contact Data from
    publicly available sources.
  • How
    we use your personal data

We will only use your personal data when the law allows us to. Most
commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the
    contract we are about to enter into or have entered into with you.
  • Where it is necessary for our
    legitimate interests (or those of a third party) and your interests and
    fundamental rights do not override those interests.
  • Where we need to comply with a
    legal obligation.

Generally, we do not rely on consent as a legal basis for processing
your personal data although we will get your consent before sending third party
direct marketing communications to you via email or text message. You have the
right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the
ways we plan to use your personal data, and which of the legal bases we rely on
to do so. We have also identified what our legitimate interests are where
appropriate.

Note that we may process your personal data for more than one lawful
ground depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been
set out in the table below.

Purpose/Activity Type
of data
Lawful
basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order
including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e)
Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate
interests (to recover debts due to us)
To manage our relationship with you which
will include:
(a) Notifying you about changes to our
terms or privacy policy
(b) Asking you to leave a review or take
a survey
(a) Identity
(b) Contact
(c) Profile
(d)
Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal
obligation
(c) Necessary for our legitimate
interests (to keep our records updated and to study how customers use our
products/services)
To enable you to partake in a prize draw,
competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e)
Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate
interests (to study how customers use our products/services, to develop them
and grow our business)
To administer and protect our business
and this website (including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data) 
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate
interests (for running our business, provision of administration and IT
services, network security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal
obligation
To deliver relevant website content and
advertisements to you and measure or understand the effectiveness of the
advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e)
Marketing and Communications
(f) Technical
Necessary for our legitimate interests
(to study how customers use our products/services, to develop them, to grow
our business and to inform our marketing strategy)
To use data analytics to improve our
website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests
(to define types of customers for our products and services, to keep our
website updated and relevant, to develop our business and to inform our
marketing strategy)
To make suggestions and recommendations
to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests
(to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal
data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data
to form a view on what we think you may want or need, or what may be of
interest to you. This is how we decide which products, services and offers may
be relevant for you (we call this marketing).

You will receive marketing communications from us if you have
requested information from us or purchased goods or services from us and you
have not opted out of receiving that marketing.

Third-party marketing

We will get your
express opt-in consent before we share your personal data with any third party
for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing
messages at any time.

Where you opt out of receiving these marketing messages, this will
not apply to personal data provided to us as a result of a product/service
purchase, warranty registration, product/service experience or other
transactions.

Change of purpose

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 you wish to
get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us
.

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, in compliance with the above rules, where this is
required or permitted by law.

We may share your personal data with the parties set out below for
the purposes set out in the table above.

  • Internal Third Parties (as
    defined below).
  • External Third Parties (as defined
    below).
  • Third parties to whom we may
    choose to sell, transfer or merge parts of our business or our assets.
    Alternatively, we may seek to acquire other businesses or merge with them. If a
    change happens to our business, then the new owners may use your personal data
    in the same way as set out in this privacy policy.

We require all third parties to respect the security of your
personal data and to treat it in accordance with the law. We do not allow our
third-party service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified purposes and
in accordance with our instructions.

We do not transfer your personal data outside the European Economic
Area (
EEA).

We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an unauthorised
way, altered or disclosed. In addition, we limit access to your personal data
to those employees, agents, contractors and other third parties who have a
business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal
data breach and will notify you and any applicable regulator of a breach where
we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably
necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your personal data for a longer period in the event
of a complaint or if we reasonably believe there is a prospect of litigation in
respect to our relationship with you.

To determine the appropriate retention period for personal data, we
consider the amount, nature and sensitivity of the personal data, the potential
risk of harm from unauthorised use or disclosure of your personal data, the
purposes for which we process your personal data and whether we can achieve
those purposes through other means, and the applicable legal, regulatory, tax,
accounting or other requirements.

By law we have to keep basic information about our customers
(including Contact, Identity, Financial and Transaction Data) for six years
after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below
for further information.

In some circumstances we will anonymise your personal data (so that
it can no longer be associated with you) for research or statistical purposes,
in which case we may use this information indefinitely without further notice
to you.

Under certain circumstances, you have rights under data protection
laws in relation to your personal data. Please review the GLOSSARY below to
find out more about these rights.

If you wish to exercise any of the rights set out above, please
contact us.

No fee usually required

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 is clearly unfounded, repetitive or excessive. Alternatively, we
could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal data (or to
exercise any of your other rights). This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. We
may also contact you to ask you for further information in relation to your
request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month.
Occasionally it could take us longer than a month if your request is particularly
complex or you have made a number of requests. In this case, we will notify you
and keep you updated.

  1. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and
most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process
your personal data for our legitimate interests. We do not use your personal
data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests
against any potential impact on you in respect of specific activities by
contacting us
.

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access
to your personal data (commonly 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.

Request correction of the personal data that we hold about
you. This enables you to have any incomplete or inaccurate data we hold about
you corrected, though we may need to verify the accuracy of the new data you
provide to us.

Request erasure of your personal data. This enables you
to ask us to delete or remove personal data where there is no good reason for
us continuing to process it. You also have the right to ask us to delete or
remove your personal data where you have successfully exercised your right to
object to processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your
request of erasure for specific legal reasons which will be notified to you, if
applicable, at the time of your request.

Object to processing of your personal data where we are
relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your information which
override your rights and freedoms.

Request restriction of processing of your personal data. This enables you
to ask us to suspend the processing of your personal data in the following
scenarios:

  • If you want us to establish the
    data’s accuracy.
  • Where our use of the data is
    unlawful but you do not want us to erase it.
  • Where you need us to hold the
    data even if we no longer require it as you need it to establish, exercise or
    defend legal claims.
  • You have objected to our use of
    your data but we need to verify whether we have overriding legitimate grounds
    to use it.

Request the transfer of your personal data to you or to a
third party. We will provide to you, or a third party you have chosen, your
personal data in a structured, commonly used, machine-readable format. Note
that this right only applies to automated information which you initially
provided consent for us to use or where we used the information to perform a
contract with you.

Withdraw consent at any time where we are relying on consent to
process your personal data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain products or services to you. We
will advise you if this is the case at the time you withdraw your consent.

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