Privacy Policy

 

Privacy Policy

 

Last Updated: September 8, 2019

PLEASE NOTE: The Restless Privacy Policy is effective as of the “Last Updated” date stated above.

Restless IVS operates the Restless service ("Restless Service"). The Restless Service allows you to access, download, and read our magazines. Restless’ Privacy Policy is designed to help you understand how we collect and use your information. By using or accessing the Restless Service, you are accepting the practices described in this Privacy Policy. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy. We encourage you to review the Privacy Policy whenever you access the Restless Service to stay informed about our information practices.

 

Information Gathered by Restless

This Privacy Policy covers our treatment of “personally identifiable” information (meaning it can be used to specifically identify you as a unique person) or “non-personally identifiable” information (meaning it cannot be used to specifically identify you) that we may collect in your use of the Restless Service. We use both types of information, and combinations of both types. This Privacy Policy does not apply to the practices of any other company or individual that we do not own or control. 

Visitors: For visitors to our website and registered users, we log certain information, such as your IP address, browser type and usage data, for example, how much time you spent reading, which publications you read, and which pages you accessed. In addition, if you access the Restless Service via our mobile application, we also collect mobile device IDS such as IDFA (iOS) and Android ID.

Registration: If you choose to register with us, Restless may ask you to provide your name, email address and physical address. Restless also asks each user to create an account ID and password. Restless may ask you to provide demographic information, such as age, gender, interests or occupation to enhance our ability to provide a more personalized experience for users. We may also, via a third-party service, collect credit card information for any paid services or purchases.

Cookies and Web Beacons: Restless uses "cookies" – small files containing a string of characters sent to your computer that uniquely identifies your browser – in addition to Flash shared browser objects to administer its website and provide a more tailored and user-friendly service to you. For example, we may use cookies or Flash objects to count the number of unique computers accessing our website. You can set your browser to refuse cookies from the Restless Service if you choose. When you access the Restless Service or open one of our HTML emails, we may automatically record certain information from your system by using different types of tracking technology. This "automatically collected" information may include IP Address, a unique ID, version of software installed, system type, the content and pages that you access on the Restless Service, and the dates and times that you visit the Restless Service. You can usually instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Restless Service or all functionality of the Restless Service.

For further information about cookies, please visit www.allaboutcookies.org.

 

Payment Card Information

To use certain aspects of the Restless Service, we may require credit or debit card account information. By submitting your credit or debit card account information through the Restless Service, you expressly consent to the sharing of your information with third party merchants, subscription and billing processors, and payment processors. These third parties may store your credit or debit card account information so you can use the Restless Service in the future. We transmit your credit or debit card account information to these third parties, but do not store such information. We cannot guarantee that transmissions of your credit or debit card account information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third-party service providers. We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.

 

Restless Uses of Information

We may use information we collect about you as follows:

  • To provide and improve the Restless Service.

  • To permit our users to set up an account.

  • To respond to your comments, questions and requests and provide customer service.

  • To send you notices, updates, security alerts and other administrative messages.

  • To communicate with you about products, services, offers and events offered by Restless.

  • To manage orders, process transactions and send you related information.

  • To link or combine with information we get from others to help provide you with better service.

  • To detect, investigate and/or prevent fraudulent, unauthorized or illegal activity.

  • To diagnose problems with the Restless Service.

  • To analyze and monitor how users utilize the Restless Service.

  • To carry out other purposes for which the information was collected.

 

When Restless Discloses Information

We will never use your personal data for any other purposes than those listed in this Privacy Policy. The only exception being if we obtain your written consent, or inform you of a new purpose for processing that is also compatible with the original purpose for which we collected the personal data, in accordance with applicable laws and regulations. Restless does not share your personally identifiable information, including any of your user profile data that you create, with other organizations for their marketing or promotional uses. Please be aware, however, that Restless may share personally identifiable information about our users with third parties, including: (a) with your consent or as otherwise stated in this Privacy Policy; (b) when we believe it is necessary pursuant to a subpoena or other judicial or administrative order; (c) where required by law; (d) to enforce or apply our Privacy Policy, our Terms of Service or our other policies or agreements; (e) at our sole discretion, where we deem necessary to respond to claims, to protect the safety of any individual or the public, or to protect the rights or property of the Restless Service or any third party or (f) in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where personally identifiable information may be disclosed or transferred as one of our business assets. We may disclose personally identifiable information to (i) affiliated companies or (ii) vendors, service providers or other partners who support our business such as providing web site hosting, maintenance, and security services; fulfilling orders; conducting data analysis and creating reports; offering certain functionality; offering customer service support; and assisting Restless in improving the Restless Service and creating new service features. Restless may also disclose anonymous or aggregated user information to third parties.

 

Changing or Deleting Your Information

You have the ability to modify your account-specific information, through the edit function on your profile. If you wish to deactivate your Restless Service account, you may do so. Removed information such as your account ID, geolocation information connected to your user ID, and any documents that you have uploaded to the Restless Service may persist in backup copies for a reasonable period of time. In addition, we may retain certain information as required by law, for legitimate business purposes, or as part of our regular retention practices. We may also retain cached or archived copies of information about you. However, we will not process personal data for a longer period than is necessary for fulfilling the purpose of such processing, as set out in this Privacy Policy. Your personal data will be anonymized or deleted once it is no longer relevant for the purposes for which it was collected.

See below for examples of the retention periods that we apply: 

  • Preventing, detecting and investigating money laundering, terrorist financing and fraud: minimum five (5) years after termination of the business connection

  • Bookkeeping regulations: five (5) years 

  • Details on performance of an agreement: up to ten (10) years after end of customer relationship to defend against possible claims

The above is only for explanatory purposes and the retention times may differ from country to country.  

 

Your Data Protection Rights

While Restless is in control of some of your personal data it is important that you know that you have a range of important rights under EU law. Please note that there are exceptions to these rights, so access may be denied e.g. where we are legally prevented from making a disclosure. 

Every user is entitled to the following:

  1. The right to be informed– You have the right to be informed about how we process your personal data. This is done via this Privacy Policy. However, you are always welcome to contact us if you have any further questions.

  2. The right to access– You have the right to request Restless for copies of your personal data. We may charge you a small fee for this service.

  3. The right to rectification– You have the right to request that Restless correct any information you believe is inaccurate. You also have the right to request Restless to complete information you believe is incomplete.

  4. The right to erasure– You have the right to request that Restless erase your personal data, under certain conditions.

  5. The right to restrict processing– You have the right to request that Restless restrict the processing of your personal data, under certain conditions.

  6. The right to object to processing– You have the right to object to Restless’ processing of your personal data, under certain conditions.

  7. The right to data portability– You have the right to request that Restless transfers the data that we have collected to another organization, or directly to you, under certain conditions.

If you choose to object to our further processing of your personal data as described in this Privacy Policy, please note that we may no longer be able to provide you with the services you have requested and may therefore terminate relevant agreements with you, see relevant terms and conditions for more information. In addition, we may continue to process your personal data for other legitimate purposes, such as to fulfil an agreement with you, to protect our interests in connection with legal proceedings and to fulfil our legal obligations. 

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: ct@restless.dk.

 

Data Security

Restless takes security very seriously. We will use commercially reasonable efforts to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. However, we cannot ensure or warrant the security of any information you provide to us or guarantee that information on the Restless Service may not be accessed, disclosed, altered, or destroyed by unauthorized persons.

 

International Transfer

Your information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. For example, if you are located outside Denmark and choose to provide information to us, your personal information may be transferred to Denmark and processed there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

If we transfer your personal data to a third country, i.e. a country outside of the European Economic Area (“EEA”) we will comply with all applicable laws in respect of such transfer, including making sure that your personal data is kept secure, and ensure that appropriate safeguards are in place to ensure there is adequate protection. 

Our preferred basis for transfer is the use of Standard Contractual Clauses. You can access a copy of the relevant EU model-clauses used by us for transfers by browsing to www.eur-lex.europa.eu and searching for 32010D0087. 

To the extent that any personal data is transferred to service providers in the US we base such transfer on Standard Contractual Clauses and the EU-US Privacy Shield. To learn more about Privacy Shield, which is an agreement on protection of personal data between the EU and the US, please read here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us- privacy-shield_en or https://www.privacyshield.gov/welcome 

 

Children Under 13

IF YOU ARE UNDER 13 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS THE RESTLESS SERVICE AT ANY TIME OR IN ANY MANNER.

The Restless Service is not directed to children under 13. Restless does not knowingly collect personal information from anyone under the age of 13. If you are under 13, please do not use the Restless Service or send any information about yourself to us, including your name, address, telephone number, or email address. If you are the parent or legal guardian of a child under 13 who has become a member of the Restless Service, then please contact Restless at ct@restless.dk to have that child's account terminated and information deleted.

 

Web Browser “Do Not Track” Notice

We currently do not participate in any "Do Not Track" (“DNT”) frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your information. Your DNT settings, however, may affect third party services we may use.

 

Privacy Policies of Other Websites

The Restless website contains links to other websites. Our privacy policy applies exclusively to our website meaning that in the event of accessing a link through the Restless website, the user is requested to read the privacy policy of the third-party. 

 

Contacting Restless

Please contact Restless with any questions at:

            Restless IVS

            Klempegårdsvej 32

            4140 Borup

            Denmark

Or by email: ct@restless.dk