GDPR POLICY
YOUR RIGHTS UNDER GDPR
The European Union has promulgated a new privacy and security framework called the General Data Protection Regulation (“GDPR”). It imposes a number of obligations on data controllers and data processors and affords data subjects a number of important rights, including access and rectification. This document is intended to provide transparency regarding Proxima Platform operations in the United States (“Proxima Platform”) as required under Articles 13 and 14 of the GDPR when we process “personal data” from the EU..
Proxima Platform acts as both a “Data Controller” and a “Data Processor” under the GDPR. Proxima Platform acts as a data controller with respect to personal data it collects from its clients and prospective clients (i.e., its own customer relationship management data), and personal data about EU citizens it licenses from others (i.e., EU personal data Proxima Platform licenses to its clients).
Proxima Platform acts as a data processor under GDPR to the extent it processes personal data about EU citizens on behalf of its clients. In this instance, our clients are considered data controllers. QM Ventures processes the personal data according to contract and written instructions from the data controller.
This privacy notice focuses on the personal data that Proxima Platform collects and processes that is used for insight, recognition, and contact purposes.
Who we are
The name of our company is Proxima Platform, LLC. Our principal place of business is 1657 North Miami Avenue, Miami FL 3316 USA. Individuals wishing to contact us about data protection issues may reach us at:
Consumer Advocate
Proxima Platform
1657 North Miami Avenue, Miami FL 33136
or by calling 001-7186122213 or by emailing us at privacypolicyqmventures@gmail.com. Our data protection officer is Mr. James Fedolfi, who may be reached at our principal place of business or by emailingjfedolfix@yahoo.com
What kinds of personal data we may hold about you
Proxima Platform holds personal data such as names, addresses, ages, dates of birth, emails, telephone numbers, behavioral data, lifestyle and demographic data. This information may be kept in its identifiable form, or in an aggregated form (so that individuals cannot be identified), for the purposes listed below. This information is 1st Party Data collected by the individual.
We do not hold any sensitive personal data on people, as defined by GDPR.
What we do with personal data
We use personal data to create solutions to be used for insight, recognition, and contact purposes.
Insight: we use this data to create a marketing picture of individuals. This includes demographics such as age, income, hobbies and interests that relate to people’s lifestyle choices and market specific predictors such as technology and financial product ownership. We use a combination of actual data held (at individual level or summarized at household, address, postcode or other geographical level) and derived information (through statistical modeling or by applying a logical rule set) which indicates an individual’s likelihood of having a particular attribute, e.g. a person’s likelihood to have pets or to fall within a particular marketing segment such as “technology early adopters.” The resulting dataset is then used by others to make marketing more relevant as further explained in the next section.
Recognition: we use this data for matching and linking to other databases. For example, an advertiser sends us a list of names and addresses, we then match those names and addresses to our product. Where there is a match, we add the lifestyle information we hold on those matched individuals to the advertiser file; or instead of adding lifestyle information we append a persistent key to the advertiser file which can then be used to recognize records that have the same key appended to them. In some cases, we may do both. Another example is where an advertiser sends us names and email addresses, we then match those names and emails addresses to our file and where there is a match we add the “bricks and mortar” address we hold on those individuals to the advertiser file.
Contact: we use contact information from this data to create a direct marketing file. For example, we create a file of names and addresses of individuals which is used for marketing.
Businesses using our solutions to contact people, need to ensure they may do so in accordance with data protection law.
With whom we may share your personal data
We share information with our clients – such as brands, agencies and marketing companies – in all industry sectors to help them deliver better marketing experiences to people. They may use this personal data for the following purposes:
•to send you relevant marketing communications
•to improve the relevance of marketing communications through the use of lifestyle and demographic insight data
•to clean, validate, and enhance marketing databases
•to undertake research and analysis
•for product development and testing
•for identity verification, fraud detection, and prevention
•to support client relationships
•to connect and link your data to other marketing and advertising databases and platforms
•for campaign planning, management and strategic decision making.
Some examples of the industry types you can expect data to be used in are: pharmaceutical, automotive, charity, education, , retail, leisure, financial services (including, retail banking, investments, insurance,), politics, health/mobility, home improvements, mail order, market research, publishing, media, consumer products, travel, telecoms and utilities.
We share data directly with brands and via agencies. We also share data (usually in a form where individuals cannot be directly identified) with other marketing companies such as social media and programmatic platforms. We make sure the recipients of our data are reputable entities by conducting appropriate checks on them. Before we share our data, we enter into written agreements with recipients which contain data protection terms that safeguard your data.
Personal data used in Proxima Platform’s data products and services may also be passed to and used by members of the Proxima Platform group of companies, worldwide. We may also pass data to other companies that process personal data on our behalf to help us conduct our business. When we do so, we ensure that appropriate contractual safeguards are put in place.
Proxima Platform may also disclose personal data as required by law and to comply with legal process.
Data retention, security, and transfers
The data we hold is non-sensitive personal data and not subject to any sector specific data retention requirements. Our data retention periods are as follows:
DATA USE RETENTION PERIOD
INSIGHT We retain data for as long it is useful in our products, either as an actual variable or in order to derive other variables
RECOGNITION We retain data for as long as it improves the matching and linking ability of our recognition products
CONTACT We retain data for as long as we are comfortable it is accurate and can be relied upon
Personal data that is not used for any purpose is deleted. If a data subject under GDPR objects to us processing their data, we will remove it from our data products, and then from our environment in accordance with our data deletion cycle, unless we have a valid justification to hold on to it, such as to resolve disputes or comply with our legal obligations. We also retain personal data which is necessary to keep on a suppression file so if we obtain someone’s data again, we will know not to use it.
Data transfers
Where business needs exist, Proxima Platform intends to transfer your personal data to entities outside the US and EU. However, your personal data will not be transferred unless a valid transfer mechanism is in place legitimizing such a transfer. In the case of transfers referred to in Article 46, 47, or the second paragraph of Article 49(1), this will typically involve EU model clauses or the EU-US Privacy Shield Framework. Safeguards afforded by the EU model clauses may be accessed here:https://ico.org.uk/media/1571/model_contract_clauses_international_transfers_of_personal_data.pdf
Information about the EU-US Privacy Shield Framework may be accessed here:www.privacyshield.gov.
Your rights
Individuals may request access to, deletion or correction of their personal data, or restrict or object to the use of their data by writing to us at
Consumer Advocate
Proxima Platform
1657 North Miami Avenue, Miami FL 33136
or by calling 001-7186122213 or emailing at privacypolicyqmventures@gmail.com
In the event of a complaint, you may contact the relevant supervisory authority in your country.
Other data protection information
Proxima Platform uses and shares personal data based on its legitimate commercial interests, and those of its partner businesses, for direct marketing, fraud prevention, information security, and organizational purposes, in accordance with Article 6(1)(f) of the GDPR. We take great care to handle all personal data in accordance with data protection law and to ensure that it is never used in ways that unduly prejudice individuals’ interests. Users of our data are prohibited by contractual restrictions from using our data in a way which discriminates unfairly against individuals or produces legal or similar effects. You have the right to object to this processing if you wish and if you wish to do so please inform us by using one of the contact channels in the preceding section.
Effective: August 19 2021