GDPR Statement

Last updated: Feb 14. 2024

Almanach Group LTD (“we,” “our,” or “us”) strives to comply with the European Union General Data Protection Regulation ("GDPR"). We provide the following "GDPR Statement,” which is supplemented by our "GDPR Notice.” Terms not defined in this GDPR Statement are defined in our Terms of Use, available at: www.Richobo.com/termsofuse.

We recognize the sensitive nature of the personal data we collect and the importance of protecting it. The GDPR requires us to obtain consent from European Union ("EU") residents before using their data in any way. It also entitles them to access their data and ask for it to be removed and forgotten from any databases on request. Below is a list of privileges and how you can exercise these privileges and rights included with GDPR.

A) You have a right to consent to how we use your data. Below is a list of the data points we collect and how they are used. We never abuse your information. Along with consenting, you also have the right to withdraw your consent.

B) We collect data, including:

• • First Name – used as a contact point reference;
• • Last Name – used as a contact point reference;
• • Nickname – used as a contact point reference;
• • E-mail Address – used as a contact point;
• • Phone Number – used as a contact point;
• • Gender – used to better categorize our users;
• • Age – used to assure you are eligible to use the Platform and to better categorize our users;
• • Picture of your government-issued ID – to verify your identity;

C) Your data is used for marketing e-mails and marketing promotions such as newsletters and informational updates.

D) Your data is stored for an indefinite matter of time if you don’t notify us via the below methods to remove it. In the case that we try to contact you and your e-mail address is no longer viable, your information will be declared inactive and we will not continue to attempt contact. If your contact information is updated with viable information, our records will be declared active as long as you haven’t exercised your right to revoke consent or be forgotten.

E) Under GDPR you have the right to ask for all the data collected on you. Your data is stored in a secure database. It will take up to 72 hours to retrieve and send you collected data. The data will be provided in the form on a spreadsheet and sent via personal e-mail.

F) Your right to be forgotten refers to your right to have your information wiped from our database. If you wish for your information to be removed please e-mail us at [email protected] and we’ll confirm your information is removed via personal e-mail within 72 hours.

G) If you wish to submit a formal complaint against how your data is being used, collected, or stored by us, contact us at [email protected].

H) If you’ve consented to receive messages from us and need to revoke that consent, please contact us at [email protected] and we’ll update our records and ensure your data is not stored. We’ll confirm your withdrawal via personal e-mail within 72 hours.

GDPR Notice

1. Purpose of this notice

This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing. Definitions of certain terms within this notice are explained in the "Definitions" section below.

2. The Data Controller for Personal Data

The Data Controller for the personal data processed by us is: Almanach Group LTD (“Almanach”).

Almanach will also become a Data Controller if it collects additional personal data directly from a Data Subject. In these circumstances, Almanach will be acting under a ‘Legitimate Interest’ to legally process the data for the management of verification services for the Data Subject and to fulfill the contractual requirements for its Client. Almanach also acts as a Data Controller for any personal data held regarding its own employees, and legally processes this data under its Contract of Employment with those Data Subjects.

3. Your Rights

As a Data Subject you have rights under the GDPR. These rights can be seen below. We will always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.

4. Contact Details

You can contact the Data Protection Officer within Almanach at [email protected].

5. Data Protection Principles

We have adopted the following principles to govern its collection and processing of Personal Data:

• • Personal Data shall be processed lawfully, fairly, and in a transparent manner.
• • The Personal Data collected will only be those specifically required to fulfill verification services. Such data may be collected directly from the Data Subject. Such data will only be processed for that purpose.
• • Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.
• • The Data Subject has the right to request access to and rectification or erasure of their personal data, to object to or request restriction of processing concerning the data, or to the right to data portability. In each case such a request must be put in writing.
• • The Data Subject has the right to make a complaint directly to a supervisory authority within their own country.
• • Personal Data shall only be processed based on the legal basis explained in this Notice, except where such interests are overridden by the fundamental rights and freedoms of the Data Subject which will always take precedent. If the Data Subject has provided specific additional Consent to the processing, then such consent may be withdrawn at any time (but may then result in an inability to fulfill verification services).

6. Transfers to Third Parties

Personal Data shall not be transferred to a country or territory outside the European Economic Area (EEA) unless the transfer is made to a country or territory recognized by the EU as having an adequate level of Data Security, or is made with the consent of the Data Subject, or is made to satisfy the Legitimate Interest of Almanach in regard to its contractual arrangements with its clients.

All internal group transfers of Personal Data shall be subject to written agreements under our Intra Group Data Transfer Agreement (IGDTA) for internal Data transfers which are based on Standard Contractual Clauses recognized by the European Data Protection Authority.

7. Definitions

A. Personal Data (Article 4 of the GDPR): ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

B. Processing (Article 4 of the GDPR): means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not 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, erasure or destruction.

C. Legal Basis for Processing (Article 6 of the GDPR): At least one of these must apply whenever personal data is processed:

• • Consent: the individual has given clear consent for the processing of their personal data for a specific purpose.
• • Contract: the processing is necessary for compliance with a contract.
• • Legal obligation: the processing is necessary to comply with the law (not including contractual obligations).
• • Vital interests: the processing is necessary to protect someone’s life.
• • Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.
• • Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

D. Data Controller (Article 4 of the GDPR): this means the person or company that determines the purposes and the means of processing personal data.

E. Data Processor (Article 4 of the GDPR): means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.

F. Data Subject Rights (Chapter 3 of the GDPR) each Data Subject has eight rights. These are:

• • The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
• • The right of access; this is your right to see what data is held about you by a Data Controller.
• • The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
• • The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
• • The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
• • The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
• • The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
• • Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.