EU Privacy Policy
Introduction

These Privacy policy (the "Policy") are designed to provide compliance for use of the website located at www.manu.co (the “Site") owned or operated by HunomadTech LLC. (“we" or “us"), and any other MANU branded websites, products, services, downloadable software, mobile applications, interactive features, widgets, and resources offered by HunomadTech through traditional Internet websites, mobile devices or social media platforms (all of which are collectively referred to as the “MANU Services" or “Service").

I. OBJECTIVE

The aim of this EU Privacy Policy (this "Policy") is to provide adequate safeguards for the handling of Personal Data.

II. SCOPE

"Automated Decisions" are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

"Controller" means a person or organisation which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

"Data Subject" means an individual for whom MANU Processes Personal Data.

"Employee" means any current, former or prospective employee, temporary worker, intern or other non-permanent employee of MANU and HunomadTech or any current or prospective subsidiary or affiliate of MANU and HunomadTech.

"European Economic Area ("EEA")" means the following countries: Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Republic of Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, The Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, the UK.

"Personal Data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity and includes information, that relates to an identified or identifiable Customer, Employee or Supplier's representative; can be linked to that Customer, Employee or Supplier's representative; and is recorded in any form.

"Processing" is defined as any action that is performed on Personal Data, whether in whole or in part by automated means, such as collecting, modifying, using, disclosing, or deleting such data. This Policy does not cover data rendered anonymous or where pseudonyms are used that do not allow for, directly or indirectly, the identification of an individual. The use of pseudonyms involves the replacement of names or other identifiers with substitutes, so that identification of individual persons is either impossible or at least rendered considerably more difficult. This Policy shall apply again if the protections offered through anonymisation no longer apply.

III. APPLICATION OF EU DATA PROTECTION LAWS

This Policy is designed to provide compliance with all relevant applicable data protection laws in the EEA, and in particular the General Data Protection Regulation ("GDPR"). We will handle Personal Data in accordance with local law at the place where the Personal Data is processed.

IV. PRINCIPLES FOR PROCESSING PERSONAL DATA

We respect the privacy of Data Subjects and is committed to protecting Personal Data. We will observe the following principles when processing Personal Data:
• Data will be processed fairly and in accordance with applicable law.
• Data will be collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes.
• Data will be relevant to and not excessive for the purposes for which they are collected and used. For example data may be rendered anonymous if deemed reasonable, feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses.
• Data Subjects in the EU may be asked to provide their clear and unequivocal consent for the collection, processing and transfer of their Personal Data.
• Data will be accurate and, where necessary kept up up-to-date. Reasonable steps will be taken to rectify or delete Personal Data that is inaccurate or incomplete.
• Data will be kept only as it is necessary for the purposes for which it was collected and processed. Those purposes are described in this Policy.
• Data will be deleted or amended following a relevant request by the Data Subject, provided such request complies with applicable law.
• Data will be processed in accordance with the Data Subject's legal rights (as described in this Policy or as provided by law).
• Appropriate technical, physical and organisational measures will be taken to prevent unauthorised access, unlawful processing and unauthorised or accidental loss, destruction or damage to data. In case of any such violation with respect to Personal Data, We will take appropriate steps to end the violation and determine liabilities in accordance with applicable law and will cooperate with the competent authorities.

V. TYPES OF DATA PROCESSED

With regard to Customer contact information, we collect and processes the following categories of Personal Data:
• First and last name
• Email address
• Telephone number
• Location

VI. WAYS OF OBTAINING PERSONAL DATA

We obtain Personal Data through various sources:
• As submitted by the customer through the services;
• Collected from publicly available databases;
• The use of third party vendors who compile databases

VII. PURPOSES FOR PERSONAL DATA PROCESSING

We process Personal Data for legitimate purposes related mostly to direct marketing in a business-to-business context. We do not process for purposes of marketing to individual consumers.
In addition, we may process Personal Data for business operational purposes. The foregoing limited purposes will be taken into consideration before any type of processing of Personal Data occurs
For customer/supplier-specific Personal Data, the purposes of processing may include:
• Management of our relationships with its customers and suppliers
• Processing payments
• Carrying out obligations under its contracts with customers and suppliers

In the event of a change of the foregoing, we will inform affected Data Subjects of new processes or applications, new purposes for which the Personal Data are to be used, and the categories of recipients of the Personal Data.

VIII. SECURITY AND CONFIDENTIALITY

We are committed to implementing and maintaining appropriate technical, physical and organisational measures to protect Personal Data against unauthorised access, unlawful processing, accidental loss or damage and unauthorised destruction.

IX. RIGHTS OF DATA SUBJECTS

Any person has the right to be provided with information as to the nature of the Personal Data stored or processed about him or her by us and may request deletion or amendments. Data Subjects may contact manu@manu.co to review, update, and revise their Personal Data.
If access is denied, the Data Subject has the right to be informed about the reasons for denial. The person affected may contact any competent regulatory body or authority to resolve the issue. We will handle in a transparent and timely manner any type of complaint resolution or inquiry about Personal Data.
If any information is inaccurate or incomplete, the Data Subject may request that the data be amended. If the Data Subject demonstrates that the purpose for which the data is being processed in no longer legal or appropriate, the data will be deleted, unless applicable laws require otherwise.

X. AUTOMATED DECISIONS

We don't make Automated Decisions for customer data. If Automated Decisions are made, affected persons will be given an opportunity to express their views on the Automated Decision in question and object to it. However, we may use cookies for analytics, user experience optimisation, ad personalisation and measurement.

XI. CONTACT INFORMATION

We will ensure that this Policy is observed and duly implemented. All Employees who have access to Personal Data must comply with this Policy.
If at any time, a person believes that Personal Data relating to him or her has been Processed in violation of this Policy, he or she should report the concern. In addition, we are to answer any questions related to its Processing of Personal Data.

Please contact us at manu@manu.co