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1. Introduction and Overview.

This Privacy Policy describes how GTOWizard.com (“Website”, “we”, “our”, or “us”), collects, uses, and shares information about you as well as your rights and choices about such use and sharing, and applies to your use of any online service location that posts a link to this Privacy Policy and all features, content, and other services that we own, control, and make available through such online service location, including, but not limited to, www.gtowizard.com collectively, the “Service”). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection).

By using the Service, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.  

If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below.

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2. Information Collection

‍A. Information You Provide

‍We collect information you provide directly via the Service, such as when you register an account, update your profile, access our content, make a purchase, participate in a survey or promotion, contact customer support, or apply for a job.  We may use Service Providers (defined below) to collect this information.

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The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information we collect include the following:

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Account data: If you connect your Facebook or Google to create an account, we use information from those accounts (such as your email, name or profile picture). This is dependent on the privacy policies or settings for those accounts. We do not collect passwords and similar security information for authentication and account access.

‍Other Data: We collect your saved favorite situations, statistics and history of your answers in practice mode and hand histories you provide to us. Your hand histories and other related data are stored at servers equipped with modern security standards.

Content: We collect the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide to customer support on email or on our Discord server.

Resume Data: We collect data as necessary to consider you for a job opening if you submit an application to us, such as your employment history, transcript, writing samples, and references.

You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.  

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1. Information Collected Automatically.

We automatically collect information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:

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Service Use Data: We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the products you purchase, the time of day you browse, your referring and exiting pages, and other similar information.

Device Connectivity and Configuration Data: We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising Id (e.g., IDFA or AAID), and other device identifiers.

Location Data: We collect data about your device’s location, which can be precise (e.g., latitude/longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level).

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We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:

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Log Files: A log file is a file that records events that occur in connection with your use of the Service, such as your service use data.

Cookies: A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.

‍Pixels: A pixel (also known as a web beacon) is codeembedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.  

Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.

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For further information on Tracking Technologies and your rights and choices regarding them, see the sections entitled “Third Parties” and “Your Rights and Choices” below.

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1. Information from Other Sources.

We also obtain information about you from other third party sources. We protect data obtained from these third parties according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources vary over time, but may include:

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Social networks when you reference our Service or grant permission to Website to access your data on one or more of these services.

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Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.

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Publicly-available sources such as open government databases or other data in the public domain.

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For further information on Third Party Services, see the section entitled “Third Parties” below.

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3. Use of Information.

We use information about you for our legitimate interests, including to:

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Manage our Service, including your registration and account.

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Perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service.

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Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.

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Prevent and address fraud, breach of policies or terms, and threats or harm.

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Monitor and analyze trends, usage, and activities.

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Conduct research, including focus groups and surveys.

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Improve the Service or other GTOWizard’s websites, apps, marketing efforts, products and services.

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We also use information about you with your consent, including to:

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Send you communications regarding our and third party products, offers, rewards, events, and services that may be of interest to you.

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Develop and display content, features, and advertising tailored to your interests on our Service as well as on other platforms and services.

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Fulfill any other purpose disclosed to you and with your consent.

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We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.

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4. Sharing of Information.

‍We share information about you as follows, but never share any of your Hand Histories as mentioned in 2.A section of this Privacy Rules. We consider your hand histories as the most valuable information you provide to us therefore we have put maximum effort into making them as secure as possible, and storing them at servers with the highest modern standards of security.

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Service Providers: We may share your information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as payment processing, data analytics, marketing and promotional services, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.  

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Affiliates: We may share your information with our related entities including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing, and technical operations.

Business Partners: We may share your information with our business partners in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities. For example, we may share information about you with a retailer for purposes of providing you with product support.

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Third Parties: We may share your information with third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Service) and in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.

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Merger or Acquisition: We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

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Security and Compelled Disclosure: We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.

Consent: We may share your information for any other purpose disclosed to you and with your consent. Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

5. Third Parties.

‍A. Third Party Services.

Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). These Third Party Services may use Tracking Technologies to independently collect information about you and may solicit information from you. The information collected and stored by third parties, whether through our Service, a Third Party Service, a Third Party Feature (defined below), or a third party device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

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1. Third Party Features.

We may allow you to connect our Service to a Third Party Service or offer our Service through a Third Party Service (“Third Party Features”). If you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature, and you should carefully review the third party’s privacy policy and terms of use. Some examples of Third Party Features include the following:

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Liking, Sharing, and Logging-In: We may embed a pixel or SDK on our Service that allows you to “like” or “share” content on, or log-in to your Website’s account through, Third Party Services, including social networks such as Facebook, Twitter, Instagram or Discord. If you choose to engage with such a Third Party Service through our Service, we may collect any information you have authorized the Third Party Service to share with us (such as your user ID, public profile information, e-mail address and other account and profile data). Likewise, if you choose to engage with such a Third Party Service through our Service or visit our Service while logged in to that Third Party Service on your device, the Third Party Service may receive information about your activities on our Service and be able to associate that information with information the Third Party Service already has about you.

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Brand Pages and Chatbots: We may offer our content on social networks such as a Facebook and Twitter, Instagram, Youtube, Discord or online forums. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on a Third Party Service (e.g., by using a hashtag associated with Website in a tweet or post), we may use your reference on or in connection with our Service.

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Voice-Activated Skills: We may offer skills through Alexa and other voice-activated platforms, and use the voice processing and other technologies discussed in the section entitled “Information Collected Automatically” above. Any information you provide to us when you engage with our skills is treated in accordance with this Privacy Policy.

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Platform Linking: We may offer you the ability to link your Website account to a Third Party Service in order to retrieve certain data about your account on that Service. For example, if you link your Website account to social media platform such as Facebook or Twitter, the linking may allow us to obtain information such as your e-mail address and profile picture. For more information about how these platforms handle your information, please refer to their respective privacy policies and terms of use.

1. Analytics and Interest-Based Advertising.

Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements on the Service and/or on Third Party Services. These third parties may use Tracking Technologies on our Service and Third Party Services (including in e-mails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and Third Party Services or third party devices after you have left the Service (“Interest-based Advertising”).

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We may serve ads on Third Party Services, such as Facebook and Google, that are targeted to reach people (or similar people) on those services that have visited our Service or that are also identified in one of more of our databases (“Matched Ads”). This is done by matching common factors between our data and the data of Third Party Services. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out. We are not responsible for such Third Party Services’ failure to comply with your opt-out instructions.

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For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.

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6. Your Rights and Choices.

6. Deletion of Data (Right to Be Forgotten).

You are entitled to the deletion of personal data that have been processed by us on the basis of Your consent within the meaning of Article 6(1)(a) of the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (‘Regulation’) or on the basis of legitimate interest within the meaning of Article 6(1)(f) of Regulation (i.e. Your personal data used for the purposes of marketing activities) at any time by indicating such request in an email addressed to hello@gtowizard.com.

However, please note that Your personal data may be processed by us on the basis of Article 6(1)(b) of Regulation for the purposes of fulfilling the rights and obligations under the service contract and on the basis of Article 6(1)(c) of Regulation for the purposes of fulfilling our public law obligations. For such reason, we might be required to retain some of Your personal data and therefore not all of Your personal data processed on this legal basis may be deleted right away.

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6. Review and Update of Account Information.

You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service by messaging us on our Discord server set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

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1. Tracking Technology Choices.

Cookies and Pixels: Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

1. Communications.

E-mails. You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or Websites’s ongoing business relations.

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Please note that your opt-out is limited to the e-mail address and will not affect subsequent subscriptions.  

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1. Unlinking Your Accounts.

If you have linked your Website account with certain Third Party Services, such as Google or Facebook, Twitter or Discord you may unlink your accounts at any time by visiting your Website account settings. Please note that unlinking your accounts will not affect any information previously shared through the linking. Website is not responsible for any Third Party Service data practices, and we recommend that you carefully review their privacy policies and terms of use.

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7. Data Security.

‍We to help protect your information from implement and maintain reasonable administrative, physical, and technical security safeguards loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

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8. Changes to this Privacy Policy.

‍We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your e-mail address.  

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11. PokerArena feature - Gameplay Data Collection and Use

‍PokerArena by GTO Wizard collects and stores gameplay data to enable core features such as matchmaking, performance tracking, and post-game analysis. Your data is never publicly visible to other players without your explicit consent.

11. In Casual mode, only your nickname will be visible to other players during games.
12. In Competitive mode, public sharing of gameplay data (e.g., rating, win rate, EV score, leaderboard position) only begins after you explicitly consent via an in-app privacy prompt. This prompt appears the first time you attempt to enter Competitive mode.

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12. PokerArena feature - What We Collect

‍When you sign up or log in and complete your profile (including selecting a public username and country flag), we generate a unique internal user ID (not visible to you or other players) and begin collecting gameplay data tied to your account. This includes:This data is securely stored on our servers and remains private unless otherwise stated below.

12. Rating
13. Number of games played
14. Win rate
15. EV score
16. GTO score
17. Summaries of played hands (used privately for analysis in GTO Wizard)

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13. PokerArena feature - What Will Be Shared (and When)

‍You can withdraw your consent at any time in the app settings. If you do, access to Competitive mode will be disabled.

Casual mode: Your nickname will be visible to other players during games. No gameplay statistics are shared.

13. Competitive mode: Your gameplay statistics — including rating, win rate, EV score, GTO score, and leaderboard position — will be publicly visible on the global leaderboard, but only after you explicitly agree to this in the app.

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15. Contact Us.

‍If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us by messaging us at our Discord (https://discord.gg/ht3QxrP) server to user @GTOWizard Matt.

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Website is operated by:

10. Amagama s.r.o. C 209011, ID 01598341 - held at the Municipal Court in Prague Kaprova 42/14, Prague 11000, Czech Republic

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The company amagama s.r.o. processes your personal data for the purpose of sending you commercial communications (marketing offers) based on so-called legitimate interest. You can object to this processing of your personal data at any time and commercial communications will no longer be sent to you. More detailed information about the processing of your personal data, including more information about the legitimate interest of the controller, can be found below.

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1. IDENTITY AND CONTACT DETAILS OF THE CONTROLLER

1. The controller of your personal data is the company amagama s.r.o., with registered office at Kaprova 42/14, Staré Město, 110 00 Praha 1, Czech Republic, company ID: 015 98 341, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, entry no. 209011 (hereinafter referred to as the “Controller").
2. The contact details of Controller are as follows: delivery address Kaprova 42/14, Staré Město, 110 00 Praha 1, e-mail address hello(at)gtowizard(dot)com.
3. Controller did not appoint a data protection officer.

2. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

1. The legal basis for the processing of your personal data is that such processing is necessary for the purposes of the legitimate interests of Controller or a third party within the meaning of Article 6(1)(f) of Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the "Regulation").
2. This information obligation is fulfilled in relation to personal data processed by Controller solely for the purpose of sending commercial communications based on the legitimate interests of Controller. It does not apply to the processing of personal data carried out by Controller for other purposes and on another legal basis, in which case the information obligation will be fulfilled separately by Controller.

3. PURPOSE OF THE PROCESSING OF PERSONAL DATA

1. The purpose of the processing of your personal data is the sending of commercial communications by the administrator to you.
2. There is no automatic individual decision-making by Controller within the meaning of article 22 of Regulation.

4. LEGITIMATE INTERESTS OF THE CONTROLLER

1. You have been a customer (user) of Controller and at the same time Controller has provided you with the opportunity, when collecting your personal data, to clearly, distinctly, free of charge and in a simple manner not to consent to the use of your electronic contact details for sending commercial communications.
2. When sending commercial communications, Controller complies with generally binding legal regulations.
3. Recital 47 of Regulation states, inter alia, that “processing of personal data for direct marketing purposes may be regarded as processing carried out for legitimate interest.”
4. Controller has carried out an assessment of whether it is possible to process your personal data for the purpose of sending commercial communications and has also carried out the necessary proportionality test, balancing the interests in protecting you against the interests of the controller. The controller has concluded that, in view of the previous fulfilment of the prerequisites set out in generally binding legal regulations, and in view of the fact that you may at any time refuse the further sending of commercial communications to you, it does not appear that your interests or fundamental rights and freedoms requiring the protection of the personal data voluntarily provided by you take precedence over the Controller's legitimate interests in sending commercial communications.
5. In view of the above and the fact that you could have reasonably expected the processing of your personal data for the purpose of sending commercial communications, Controller considers that the legal basis for the processing of your personal data for the purpose of sending commercial communications to you is the legitimate interest of Controller (article 2.1).

5.  STORAGE PERIOD OF PERSONAL DATA

1. Your personal data will be processed by Controller for a period of three (3) years from the termination of the contract with Controller, but no longer than until you object or make a similar request against the processing of personal data for the purpose of sending commercial communications from your side, including exercising the right to erasure of your personal data.

6.  OTHER RECIPIENTS OF PERSONAL DATA

1. Other recipients of your personal data will be persons providing technical services related to the operation of the software or sending commercial communications (as processors) for Controller based on Controller's instructions.
2. Controller does not intend to transfer your personal data to a third country (to a country outside the EU) or to an international organization.

7.  RIGHTS OF THE DATA SUBJECT

1. Under the conditions set out in Regulation, you have the right to request from Controller access to your personal data, the right to rectification or erasure of your personal data, or restriction of their processing.
2. If you believe that the processing of your personal data has infringed or is infringing Regulation, you have the right, among other things, to file a complaint with a corresponding supervisory authority.
3. You have the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling, where the profiling relates to such direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data will no longer be processed for these purposes. This is without prejudice to the processing of your personal data based on another legal basis or for another purpose.‍‍

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