Your privacy is important to us.

We process your Personal Data in accordance with applicable data protection regulations, in particular the General Data Protection Regulation 2016/679 of April 27, 2016 (hereinafter abbreviated as "AVG"), as well as the provisions of this privacy policy.

This privacy policy provides you with more information about what Personal Data we process, why we process it, how we obtain it, how long we keep it, and with whom we share it when you use our services. It also tells you about your privacy rights. 

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***Please read this privacy policy carefully!***

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This privacy policy applies to all users (current, past or future) and third parties. This policy does not apply to third-party applications, websites, product, services of platforms that may be accessed through links that are provided on our Application. These are owned and operated independently from Us, and they have their own separate privacy policy. We cannot accept liability for the actions of policies of these third parties and we are not responsible for the content or privacy practices of these third parties. 

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1. Who is responsible for processing your Personal Data? 

The controller of your Personal Data is the following legal entity:

In case of questions regarding the processing of your Personal Data, you can always contact us by email to info@arabiansathome.com with reference 'GDPR'.

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2. The definition of specific terms in this privacy policy

Words in Bold Type have meanings defined under the following conditions. 

• Agreement means the Agreement you enter in with us by using our services and accepting our Terms & conditions;
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for the election of directors or other managing authority;
• Application refers to Arabians@home, the software program provided by the Company;
• Company (referred to as either ‘The Company’, ‘The Controller’, ‘We’, ‘Us’ or ‘Our’ in this Agreement) refers to ASEEL AQUINE BV.
• Content means application content available on the Application which is also accessible on the Application on user's profiles through stories, articles, photos and videos and questions/answers on the forum;
• Country refers to Belgium;
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet;
• Personal Data is any information that relates to an identified or identifiable individual;
• Processing means any operation or set of operations involving Personal Data or a set of Personal Data, whether or not carried out by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of data.
• Profile means a unique account created for you to access our Service or parts of our Service;
• Service refers to the application
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used;
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

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3. What is our legal basis to process your Personal Data? 

Performance of the contract:

We process your Personal Data so that you can use Our Services in accordance with the agreement you enter into with us when you use our services. For more details check our ‘Terms and Conditions’. 

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Consent: 

In certain cases, you must provide prior consent for the processing of your Personal Data. You can withdraw your consent at any time (see your rights).

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Legitimate interest:

We can use your Personal Data as necessary for our legitimate interest. We will not process your Personal Data if it appears that your interests, or your fundamental rights and freedoms, override ours. Where we rely on legitimate interest, you have the right to object to the use of certain information (see your rights). 

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Legal obligation:

We may, in exceptional circumstances, be required to transfer your Personal Data in response to a court order or to comply with mandatory laws and/or regulations. If reasonably possible, we will attempt to inform you in advance, unless the giving of such information is prohibited or restricted by law.

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Public interest:

We may process information as necessary for the public interest, such as conducting research or educational purposes. 

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4. How do we collect and use Your Personal Data?

Category 1: Identification and contact details

Personal Data: Which Personal Data do we collect? 

1. Profile information (name, email address, telephone number, username)
2. Contact details  (e-mail address, telephone number, username)

Purpose: Why do we collect this Personal Data?

• To provide features of our Service;
• To contact you and to attend and manage your request to Us;
• Information supplied by the user to identify themselves to the controller and other users. This creates a personal profile that distinguishes users from one another;
• Informing users about new products and services and news about Our Application;
• To manage your Profile;
• For business transfers we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

Legal basis:

• Performance of the contract for obligated information You provide to Us to create your profile and to use our services;
• Consent for additional information You consent to provide us to facilitate the use of Our Application;
• Legitimate interest for the identification of Users and for business transfers. 

Data source: We receive this information directly from the user

Sharing with third parties: We share Your Personal Data with our board members, independent contractors and the Service providers we work with to improve Our services. These third parties have limited access rights.

Data retention or deletion: We keep your profile information for the lifetime of your Contract. You can always request to delete your Profile, or we ourself can end your contract because of violation of our terms and conditions. 

We keep your information as long as we need it to comply with legal obligations or protect Our or other’s interests and when it’s needed in relation to a legal claim, complaint, litigation or regulatory proceedings. 

In case you gave your consent to the processing of certain Personal Data, we will process such data until you withdraw your consent.

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Category 2: Activity information

Personal Data: Which Personal Data do we collect? 

1. Created public Content like stories, articles or question/answers on the forum
2. Provided Content through camera roll of the user by uploading images/videos
3. Use of the camera feature for live images/videos
4. Private messages 
5. Group messages
6. Review of Content and messages after a complaint (ex. harmful messages)
7. Interaction of the User with the Content of other Users
8. Likes on stories
9. Friends

Purpose: Why do we collect this Personal Data?

• To provide and maintain Our Services;
• Creating an online community through a platform where people interested in Arabian horses can share Content and engage with each other;
• In response to a user's complaint, review the Content of designated Content or the Content of certain posts if it is indicated that they do not conform to our guidelines and contain harmful content;
• Review published content for compliance with Our terms and conditions;
• For business transfers we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

Legal basis:

• Performance of the contract for handling complaints and compliance with Our terms and conditions;
• Consent for Content you post on Our Application;
• Legitimate interest for business transfers; 
• Public interest for Content You provide to us that have educational purposes.

Data source: We receive this information directly from the users.

Sharing with third parties: We share Your Personal Data with our board members, independent contractors and the Service providers we work with to improve Our services. These third parties have limited access rights.

Data retention and deletion: We keep your information as long as we need it to provide and operate our Services and to comply with legal obligations or protect Our or other’s interests and when it’s needed in relation to a legal claim, complaint, litigation or regulatory proceedings. 

We store Your Content for the lifetime of your Contract. You can always request to delete any Content, or we ourself can delete Content because of a violation of our terms and conditions. For created Content we use a case-by-case basis to decide whether there is a legitimate interest for us and we preserve your information even after you request deletion as long as we need it for the obtained purposes.  

In case you gave your consent to the processing of certain Personal Data, we will process such data until you withdraw your consent.

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Category 3: Sensitive data

Personal Data: Which Personal Data do we collect? 

1. Sensitive information provided by the user through stories, articles or questions/answers on the forum (ex. Sex, religion, political and medical information)
   

Purpose: Why do we collect this Personal Data?

• Possibility for You to share any information with special protections with other users by posting Content on our Application.

Legal basis:

• Consent for Your Content which contains any information with special protections.

Sharing with third parties: We share Your Personal Data with our board members, independent contractors and the Service providers we work with to improve Our services. These third parties have limited access rights.

Data retention and deletion: We will process such data until you withdraw your consent.

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Category 4: App information 

Personal Data: Which Personal Data do we collect? 

1. Product performance information

Purpose: Why do we collect this Personal Data?

• To continue to ensure the proper functioning of the Application and further development of the Application to the needs of the Users. 

Legal basis:

• Performance of the contract for product performance.
• Legitimate interest when this information is necessary for the operation of our Application.

Data source: We receive this information directly from the users and through information provided to us by the Service providers we work with for the operation and performance for Our Application. 

Sharing with third parties: We share Your Personal Data with our board members, independent contractors and the Service providers we work with to improve Our services. These third parties have limited access rights.

Data retention and deletion: We keep your information as long as we need it to provide and operate our Services and to comply with legal obligations or protect Our or other’s interests and when it’s needed in relation to a legal claim, complaint, litigation or regulatory proceedings.

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Category 5: Marketing

Personal Data: Which Personal Data do we collect? 

1. Contact details  (e-mail, address, telephone number)

Purpose: Why do we collect this Personal Data?

• Informing users about new products, services and news about our Application;
• Advertising. 

Legal basis:

• Consent
• Legitimate interest when the information we need to share is important for the operation of our Application

Data source: We receive this information directly from the user.

Sharing with third parties: We share Your Personal Data with our board members, independent contractors and the Service providers we work with to improve Our services. These third parties have limited access rights.

Data retention and deletion: We keep your information as long as we need it to provide and operate our Services and to comply with legal obligations or protect Our or other’s interests and when it’s needed in relation to a legal claim, complaint, litigation or regulatory proceedings. 

In case you gave your consent to the processing of certain Personal Data, we will process such data until you withdraw your consent.

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We engage to collect Personal Data necessary only for the realization of the purposes and means we have established. Below you can find what Personal Data we process for each category of Personal Data, why we process it, how we obtain it, how long we keep it, and with whom we share it. We process the following Personal Data divided into different categories:

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5. Are you required to provide Your Personal Data?

Regarding the Personal Data processed in the context of the performance of the contract or a legal obligation resting on the Company, You are obliged to provide this information in order to use the Application.  If you do not wish to provide us with this information, a contract cannot be concluded and you cannot use Our Services. 

If you are a child under 13 years old, we may not process your Personal Data. Children under 13 years old will not be able to create a profile and use our Application. Children between the ages of 13 and 16 need permission from their parents or guardian to use our Application.

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6. Do we transfer Your Personal Data?

Your Personal Data will not be sold, transferred or communicated to third parties in any way, except in the situations provided for in the current privacy policy or unless you have expressly and prior consented to it.

Your Personal Data is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to -  and maintained on – computers and servers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

The Application is a global application so we may collect Personal Data of third country users and transfer data to countries where our Services are available. 

For international data transfers we rely on appropriate mechanisms to make sure there that appropriate safeguards are in place whenever Your Personal Data is transferred. 

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7. What are my rights? 

You may exercise the rights specified below by sending an e-mail to: info@arabiansathome indicating the right you wish to exercise and the reference ‘GDPR’. Please attach a copy of the front of your identity card. This will allow us to identify You. Without valid identification, we cannot act on Your request to exercise Your rights. 

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In principle, exercising your rights is free of charge. 

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We will respond to your request within a period of 1 month. Depending on the complexity of your request, this period can be extended by 2 months. It may be possibly we decide to disregard your request in a justified manner. We will inform you within one month about our decision.  

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Access to Your Personal Data:

You have the right to obtain access to your Personal Data.

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If possible, we will provide you with a copy of your Personal Data after your request. If this is not possible, we will provide you with an overview of the Personal Data processed. For additional copies, we may charge a reasonable fee due to administrative costs. This information/copy will be provided to you electronically.

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This right of access does not affect the rights or freedom of others, including trade secret or intellectual property and in particular the copyright that protects the software. If a third party (e.g. IT administrator, supplier, ...) is mentioned in the documents you request, the identity of these persons will be shielded from transmission.

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Rectification of Your Personal Data

You have the right to correct or complete Your Personal Data that is incorrect or incomplete.  

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After your request for correction or completion, we will check the accuracy of this data and adjust it if necessary.

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You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

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Erasure of Your Personal Data

You have the right to obtain the erasure of Your Personal Data.

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We take into account the available technology and implementation costs and shall take the necessary measures to inform other controllers processing this Personal Data of this erasure request.

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Please note that we shall have the right to retain Personal Data for a longer period of time if this is necessary for the exercise of the right to freedom of expression and information, for the performance of a task in the public interest or in the exercise of public authority, for reasons of public interest in the area of public health, for archiving in the public interest, scientific or historical research or statistical purposes or for the establishment, exercise or substantiation of legal claims.

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Object to process Your Personal Data

You have the right to object at any time, for reasons relating to your particular situation, to the processing of your Personal Data. You may exercise this objection when your Personal Data is processed on the basis of:

• the public interest or;
• a legitimate interest;
• in the context of direct marketing.

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We may override this right to object if we can demonstrate that we have compelling legitimate grounds for processing this Personal Data and that these grounds outweigh Your interests, rights and freedom. Or when we can demonstrate that the processing of this Personal Data is related to the establishment, exercise or support of a legal claim.

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Right to restriction of processing

You have the right to obtain the restriction of the processing of your Personal Data in the following cases:

• During the time we need to verify the accuracy of Your Personal Data when You have exercised your right of rectification;
• Pending Our response, when you have exercised a valid right to object;
• when the processing is unlawful but you prefer to restrict this processing, instead of erasing the Personal Data concerned;
• when we no longer needs this Personal Data but you need it for the establishment, exercise or substantiation of a legal claim.

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When you have properly exercised your right to restrict processing, we will only further process this Personal Data:

• With your consent;
• for the establishment, exercise or substantiation of a legal claim or;
• to protect the rights of another natural person or legal entity or;
• for important reasons of public interest for the Union or for a Member State. 

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This restriction does not apply to the storage of your Personal Data. 

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If we will lift the restriction on processing, you will be notified in advance.

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Right to data portability

You have the right to obtain a copy of the Personal Data concerning you in order to transfer it, possibly directly, to another Controller. However, this right to portability only applies to Personal Data:

• processed on the basis of the explicit consent of the Data Subject;
• processed through automated processes (For example: profile).

This right is exercisable only to the extent technically feasible for Us and if the processing of this Personal Data is not necessary for the fulfilment of a legal obligation incumbent on the Company.

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Right to withdraw Your consent

Where the processing is based on Your consent you have the right to withdraw your Consent at any time by informing Us about your withdrawal or by deleting Your Content or profile. 

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8. Can we change this privacy policy? 

We reserve the right to adapt the provisions of this privacy policy to the necessities of our business, the evolution of its policies and changes in regulations, administrative positions or case law. The latest version of this policy is the only valid one.

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9. Do we use cookies? 

We only use strictly necessary cookies. For Our Application, we require certain necessary cookies to run Our Services:

• We use preference cookies to help us remember the way you like to use Our Service.

So long as the cookie is not strictly necessary, you may opt in or out of cookie use at any time. 

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10. How do we keep your Data safe? 

We have appropriate organizational safeguards and security measures in place at the technical and organizational levels to protect Your Personal Data from destruction, loss, falsification, modification, unauthorized access or inadvertent notification to third parties. 

Access to your Personal Data is only possible for responsible persons and/or employees for whom it is necessary in the function of their duties. We require the same level of security from the Recipients with whom we cooperate. 

You yourself must respect the necessary security standards at all times by avoiding all unauthorized access or improper use of your login and access code. You are solely responsible for the use of Our Application, your IP address and your identifying information, as well as its confidentiality.

In the unfortunate event of a Personal Data breach, we will notify You and any applicable regulator when we are legally required to do so. 

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11. How can you file a complaint? 

If you are not satisfied with the way We handle your Personal Data, You may file a complaint with your national supervisory authority if you are based in the EAA. Please visit this website for a list of local data protection authorities: https://edpb.europa.eu/about-edpb/about-edpb/members_en  

In Belgium, you can address this complaint to the Belgian Data Protection Authority: https://www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen