Last updated: November 20 2018
Hammerstone, Hammerstone Inc, Catena Media Financials US LLC and Catena Operations Ltd meaning (“Company” or “we” or “us” or “our”) is a part of the Catena Media group, engaged in lead generation online and content publishing regarding financial information and services. Catena Media group has its headquarters in Malta with subsidiaries in several countries worldwide.
Please note that the Website is not intended for anyone under 18 years of age. We do not intentionally collect or use any information from children.
Legal bases for processing your personal data
We process your personal data for the purposes set out in this section and where we are satisfied that:
• you have provided your consent to us using the data in that way, or
• our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to send you communications if we think appropriate to inform you about similar products or services, or to carry out analytics across our datasets), in a way that is proportionate and respects your privacy; or
• Contract – for example if you have a subscription and in order to handle invoicing, payments or refunds; or
• Legal requirement – for example when necessary to comply with accounting rules or mandatory disclosure to law enforcement
How long do we keep your personal data?
We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 1. We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.
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What are your rights?
You have a number of rights in relation to your personal data. More information about each of these rights can be found by referring to the table set out further below.
To exercise your rights you may contact us as by sending an email to [email protected] or by letter to our representative in the EU: Catena Operations Ltd, c/o Data protection officer, Quantum Place, Triq ix-Xatt, Ta´Xbiex, Gzira, Malta GZR 1052.
Right What this means
Access You can ask us to:
– confirm whether we are processing your personal data;
– give you a copy of that data;
– provide you with other information about your personal data, for example what data we have, what we use it for, who we disclose it to, whether we transfer it outside the EU and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any Automated Decision Making or Profiling, to the extent that information has not already been provided to you in this Policy.
Rectification You can ask us to rectify inaccurate personal data.
We may seek to verify the accuracy of the data before rectifying it.
Erasure You can ask us to erase your personal data, but only where:
– it is no longer needed for the purposes for which it was collected; or
– you have withdrawn your consent (where processing was based on consent); or
– following a successful right to object (see ‘Objection’ below); or
– it has been processed unlawfully; or
– to comply with a legal obligation.
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:
– for compliance with a legal obligation; or
– for the establishment, exercise or defence of legal claims;
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request
You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
– its accuracy is contested (see Rectification), to allow us to verify its accuracy; or
– the processing is unlawful, but you do not want it erased; or
– it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
– you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal data following a request for restriction, where:
– we have your consent; or
– to establish, exercise or defend legal claims; or
– to protect the rights of another natural or legal person.
Portability You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another Data Controller, but in each case only where:
– the processing is based on your consent or on the performance of a contract with you; and
– the processing is carried out by automated means.
Objection You can object to any processing of your personal data which has our ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
We have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Supervisory Authority You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.