Privacy FAQs

As a company that finds its roots in the European Union, and that considers compliance to privacy legislation a core principle of its organisation, Cardify has created these Privacy FAQs based upon the foundations of the EU General Data Protection Regulation (GDPR) (Regulation (EU) 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).

As GDPR currently is the most advanced and elaborate data protection legislation in the world, Cardify uses GDPR as its main benchmark for its companywide privacy program.

Seeing the global activities of Cardify, it goes without saying that with these Privacy FAQs, in addition to GDPR, also want to take into account the principles of other applicable data protection legislations (such as the California Consumer Privacy act of 2018, the UK Data Protection act 2018, or, the Swiss Data Protection act).

The principles of such other data protection legislations have either already been incorporated through GDPR (in most of the cases) or either have specifically been added to these Privacy FAQs.

These Privacy FAQs are provided for convenience only and want to provide as much information as Cardify is able to provide under applicable data protection laws (e.g. sections 13/14 GDPR).

Cardify is acting as "Processor" / "Service Provider" in respect of the operation of the Products and Services and not as data controller (see FAQ B12), which means that the Customer Policy shall always have priority over these Privacy FAQs.

In no way do these Privacy FAQs or the publication thereof mean that Cardify is taking up a role as data "Controller" under these Privacy FAQs or taking up additional liabilities or responsibilities than as legally applicable between a controller and processor.

The publication of, or getting acceptance against, the Customer Policy (or absence thereof) occurs solely under the responsibility of the Cardify Customer.

Where the Data Subject already has accepted the Customer Policy (or where such (updated) Customer Policy subsequently becomes applicable) that cover Your interaction, directly or indirectly (e.g. through an integration or through a software client), with the Products and Services and/or certain Customer Content managed thereon, the Customer Policy shall apply instead of these Privacy FAQs.

Unless the Customer Policy applies (see FAQ A2) these Privacy FAQs apply to the interactions, direct or indirect (e.g. through an integration or through a software client), that the Data Subject may have with the Products and Services and/or certain Customer Information managed thereon.

These Privacy FAQs are being provided under the responsibility of the Cardify Customer, who is acting as data "Controller" for the processing activities covered under these Privacy FAQs (see FAQ B12).

These Privacy FAQs do NOT apply in situations other than explained above or in situations where the Cardify Privacy Policy applies (Cardify acting as data "Controller", including in respect of Cardify's use of its own Products and Services).

Cardify is offering Products and Services mainly in the field of sales enablement / lead intelligence that measures, analyses and reports on the persona, engagement and behaviour of individuals with information being made available to them through the Products and Services ("Customer Information"), including "Cardify Essential" and "Cardify Pro". These Products and Services are offered unde a "Software as a Service" model, which is a software licensing and delivery model in which software is centrally hosted and made available to multiple users over a network, including through interacting products (including front-end clients, apps, Web-Interface, plugins, or connectors to third-party applications).

To the extent the Data Subject is interacting with the Products and Services (see the then current Products and Services offerings at (getcardify.com/product), and/or the Customer Information managed thereon, the Data Subject's engagement therewith is measured, analysed and reported back to the Cardify Customer.

The aim is to provide the Cardify Customer through the Products and Services with the information, insights, analytics and tools to help the Cardify Customer to streamline and improve interactions by and between their internal collaborators (e.g. sales teams, marketing teams,...) and/or third parties (e.g. potential buyers).

Except in the limited cases as explicitly stated in the Cardify Privacy Policy for which Cardify is data "Controller" (see FAQ B12), Personal Data in respect of the Products and Services is not processed for any other purpose.

For avoidance of doubt, under these Privacy FAQs, Cardify does NOT process the Personal Data for any other purposes than as described in this FAQ B1.

Under these Privacy FAQs, Cardify does NOT process the Personal Data for any other purposes than for the Products and Services (see FAQ B1) as data "Processor" on instruction and for the benefit of the Cardify Custmer (as being the data "Controller") (see FAQ B12).

As Cardify is not the owner of the dataset containing the Personal Data, Cardify does NOT sell, trade or otherwise commercialise Personal Data as being processed through the Products and Services to or for the benefit of anyone else than the Cardify Customer, nor does Cardify use the Personal Data for Cardify's direct marketing purposes.

Depending on the role within the Products and Services (see FAQ B7) certain categories of Personal Data may be processed as follows:

• Contact information (e.g. name, email address, telephone number, social profiles...)
• Professional information (e.g. company, role, company address, estimated revenue...)
• Account information (e.g. password, profile picture, device information, logon information,...)
• Usage/behavior statistics (e.g. sessions, in app views, shares, channel subscriptions, # of interactions with the Customer Information, type of interactions with the Customer Information...)
• Connection information (e.g. IP address, geolocation,...)
• Customer Information (e.g. documents, presentations, audio, video,... as uploaded onto and managed by the Products and Services)
• Information from third party integrations (connected calendars, CRM data, Marketing data,...)

The Products and Services process Personal Data for and on behalf of Cardify Customer. It is the Carify Customer who is acting as data "Controller" (see FAQ B12) and therefore who determines what Personal Data of which Data Subject to process.

This information is also made available to the Cardify Customer via the Cardify Web Portal as part of Cardify's Products and Services offering. In case you require more input, you can contact Cardify via privacy@getcardify.com.

Seeing the scope of the Products and Services (see FAQ B1), the Products and Services are NOT intended or equipped to Process any Personal Data in respect of genetic data, biometric data, data concerning health (e.g. HIPAA regulated data) or data concerning a natural person's sex life or sexual orientation, nor any Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or such other data that the applicable data protection legislation indicates being "regulated" or "sensitive" ("Sensitive Personal Data").

The Cardify Customer - as being data "Controller" (see FAQ B12) - is responsible for ensuring that no such Sensitive Personal Data is being Processed through the Products and Services, or where it does, that it does so under its own assessment and responsibility.

Cardify does not provide for additional means or provide additional effort in order to have Sensitive Personal Data processed through the Products and Services.

Seeing the scope of the Products and Services (see FAQ B1), the Products and Services are NOT intended or equipped to Process any data that is regulated by the Payment Card Industry Security Standards Council (PCI SSC), nor do the Products and Services offer features that are subject to the Payment Card Industry Data Security Standards (PCI DSS).

The Cardify Customer - as being data "Controller" (see FAQ B12) - is responsible for ensuring that no such PCI regulated data is being Processed through the Products and Services, or where it does, that it does so under its own assessment and responsibility.

The Products and Services are NOT intended or equipped to process Personal Data for any automated decision-making processes or techniques which create or deny rights to the Data Subject.

The Cardify Customer - as being data "Controller" (see FAQ B12) - is responsible for ensuring that no automated decision-making processes or techniques are being added to the Products and Services, or where it does, that it does so under its own assessment and responsibility.

You can interact with the Products and Services through the following roles:

• "Administrator": someone generally managing the Products and Services (e.g. managing User accounts, having privileges for making Customer Information available for use by the User through the Products and Services, being able to generally/individually monitor usage statistics);
• "User": someone who through the Products and Services is i) interacting with the Customer Information being made available to him by interacting with the Third-Party Data Subject, ii) making Customer Information available to a Third-Party Data Subject, and/or iii) monitoring that Third-Party Data Subject's engagement with such information, as well as the related usage statistics;
• "Third-Party Data Subject" someone (usually the prospect / potential buyer) receiving specific information from the User through the Products and Services usually in respect of a potential business transaction to be negotiated/concluded with the User, and being allowed access to the Products and Services and/or Customer Information managed thereon, by or on behalf of the Cardify Customer (either under or outside of an account).

Each of these roles will generate their specific analytics as to the way how they interact with the Products and Services and/or Customer Information managed thereon.

The Third-Party Data Subject is able to re-share Customer Information via the Products and Services. When re-sharing such Customer Information via the Products and Services with a second Third-Party Data Subject, the first Third-Party Data Subject needs to ensure:

• being allowed to process the email address of the second Third-Party Data Subject for that purpose; and
• living up to the respective applicable law or regulation in respect of fraudulent and misleading activity or sending unsolicited email, mass emails, or spam (e.g. EU e-privacy regulations).

The Cardify Customer may activate or use certain integrations with third party applications, through different methods (e.g. the API of the Products and Services, iFrame, linking to third-party URL's, ...).

Such integration may lead to the fact that third-party applications receive access to certain Personal Data or Customer Information either directly from the Data Subject or through the Products and Services.

Such activation, implementation, combination and/or Customer Information offering occurs solely under the responsibility of the Cardify Customer and the Customer Policy. Consequently, Cardify does not take any responsibility for this.

Under these Privacy FAQs, Personal Data of Data Subjects may be made available:

• within the functionality of the Products and Services (as determined by the Cardify Customer) to:
  • Users - Administrators - Privileged Users; and
  • Third-Party Data Subjects (e.g. in respect of collaborative functionalities of the Products and Services such as Shared Spaces)
• within the functioning of the architectural set-up (incl. maintenance & support) of the Products and Services, to:
  • Cardify (including its collaborators); and
  • the respective Sub-Processors ((including their collaborators), providing processing activities for the Products and Services (see FAQ B13).

Disclosures within the functioning of the architectural set-up shall:

• be limited to the Personal Data as required for the specific purpose in question of the respective recipient; and
• take into account the necessary provisions on confidentiality, integrity, availability and security of the Personal Data involved.

To the extent required as per applicable Data Protection law, Cardify shall remain responsible towards the Cardify Customer for such Sub-Processors to ensure that the processing by such Sub-Processors remain in line with the applicable data protection legislation.

Where applicable to the Products and Services in question, Third-Party Data Subject interactions with Customer Conent occurring under "Ingognito Mode" will be attributed to, and aggregated under the analytics of, the User Account linked to the "Ingognito Mode".

The Products and Services, are typically solutions that aim at selling products, negotiating a sales transaction and/or providing learning capabilities within professional organisations. As such, the Products and Services are not aimed towards children and minors, nor should it be used for such purpose.

The Products and Services do not knowingly process Personal Data of children and minors.

If a parent or guardian becomes aware that his or her child has provided Personal Data that is processed by the Products and Services without their consent, he or she should contact the Cardify Customer who is the data "Controller" (see FAQ B12).

It is the Cardify Customer who:

• Manages user accounts to the Products and Services (e.g. password reset, access rights, third-party integrations, suspending accounts, grouping users, assigning channels,...);
• Manages the Customer Information being made available through the Products and Services;
• Determines which Data Subjects to interact with through the Products and Services (and thus whose Personal Data are to be processed);
• Requests Data Enrichment to complete Customer Information;
• Determines for which purpose the Products and Services are to be used.

It is therefore the Cardify Customer who legally is acting as the so-called data "Controller".

Therefore, all inquiries the Data Subject may have, or rights the Data Subject may want to exercise with regard to the processing of one's Personal Data through the Products and Services, need to be addressed to the Cardify Customer (see FAQ E2). Should Cardify receive such request directly from a Data Subject, Cardify can legally only pass such request on to the Cardify Customer. Cardify is legally not allowed to respond to such request, unless as instructed by the Cardify Customer.

Seeing the above, Cardify is only offering the means allowing the Cardify Customer to interact with the Data Subject through the Products and Services, and as Cardify is merely acting upon instructions of the Cardify Customer, this means that Cardify is processing the Data Subject's Personal Data as a so-called data "Processor" for and on behalf of the Cardify Customer.

Notwithstanding the above, in the limited cases as explicitly stated in the Cardify Privacy Policy (see FAQ A3), certain Personal Data resulting from the relationship between Cardify and the Cardify Customer, may be processed by Cardify s being the data " Controller" (e.g. as required for Cardify as a controller to administer the (contractual) relationship between Cardify and its Customer, or, providing support). More info can be found in the Cardify Privacy Policy (Controller).

Te Products and Services make use of two types of sub-processors; 1) "Core Sub-processors" and 2) "Feature dependent Sub-processors".

Core Sub-processors (e.g. hosting partners) are subprocessors that are key to the functioning of the Products and Services and without whom Cardify cannot guarantee the functioning of the respective Products and Services, or to meet the contractual warranties and service levels.

Feature dependent Sub-processors are sub-processors that offer a certain functionality that is either not present in all versions of the Products and Services, either are optional (and thus can be switched off). To the extent required as per applicable Data Protection law, Cardify shall remain responsible towards the Cardify Customer for such Sub-Processors to ensure that the processing by such Sub-Processors remain in line with the applicable data protection legislation.

As part of the Cardify Products and Services Pro version, Cardify uses feature dependent Sub-processors to scrape certain publicly available data sources on behalf of the Cardify Customer (such as, but not limited to, public websites, social media such as Google or LinkedIn, public databases or other Internet & IT platforms).
For example, when a Data Subject"s email address is provided to a Cardify Customer, and solely on the consent of that Data Subject, Cardify will use this Sub-processor to collect additional information on behalf of the Cardify Customer on mentioned publicly available databases in order to collect more professional information and to create a full record. This information may include but is not limited to company statistics, company location and contact information, role, LinkedIn profile, correct writing of the Third Party Data Subject"s name,...

To perform these activities, Cardify makes use of Clearbit.

Clearbit only processes professional data, regardless of where an individual is based. This usually includes things like their job role and details about their employing company. This means that Clearbit does not provide or collect sensitive information data such as age, health, web browsing history, health records, or economic status. If you wish to be removed from the Clearbit database, please click here to opt-out.

For more information on which sub-processors are used in the Products and Services as well as the respective details of the processing activity (location of processing, duration of processing etc.), please contact your account manager.

In case you require more input on this topic, you can contact Cardify privacy@getcardify.com.

Cardify transfers Personal Data to third countries if and when required by:

• Its and its affiliates' employees and collaborators;
• Third-party technology and service providers as used for the purposes described in this Privacy Policy (see Sub-Processors) ;
• Third-party maintenance & support recipients (including related service/technology providers);
• Other third parties to the extent Cardify has good faith belief that such disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request from a public or law enforcement authority; (b) national security (c) protect the safety of any person from death or serious bodily injury; (d) prevent fraud or abuse; (e) as necessary to protect or enforce our legal rights & those of our collaborators as well as the integrity of our Product and Services.

Such disclosures shall always be limited to the Personal Data as required for the specific purpose of the recipient while taking into account the necessary provisions on confidentiality, integrity, availability and security of the data involved.

In the current set-up of the Cardify organisation, such export of personal data is required to guarantee the functioning of the respective Products and Services, or to meet the contractual warranties and service levels.

To the extent required as per applicable Data Protection law, where such export occurs, Cardify shall ensure that such transfer occurs under the necessary legal provisions as required by the applicable legislation.

To the extent data is being (re)transferred outside of the European Economic area and/or or United Kingdom, Cardify shall ensure to that such (re)transfer occurs under such instruments as allowed per the GDPR and providing for an adequate level of protection of Your Personal Data (e.g. adequacy decision of the EU commission (e.g. EU-US Privacy Shield), binding corporate rules, or EU standard contractual clauses,...).

Before each Administrator and/or User's Personal Data is processed, consent from those Data Subjects will be sought at the moment of creation of their account.

The legal basis for processing Third-Party Data Subject's Personal Data is dependent on the privacy setting (as determined by the Cardify Customer), for example, where processing of Third-Party Data Subject's Personal Data uses the setting of:

⇒ Seeking prior consent from the Third-Party Data Subject:

• consent will be sought at the moment of first interaction with the Products and Services or the Customer Information made available thereon.

⇒ Informing the Third-Party Data Subject:

• an information banner can be made to appear at the moment of first interaction with the Products and Services or the Customer Information made available thereon, referring such Third-Party Data Subject to an applicable privacy policy.
• An information footer can be enabled in the emails that are send out of the Products and Services to a Third-Party Data Subject.

In respect of EEA residents, consent is an allowed basis for the lawful processing of Personal Data (see section 6,1 (a) GDPR). Additionally, certain Personal Data is processed based on legitimate interest (e.g. see section 6,1 (f) GDPR) because:

⇒ necessary for technical reasons, e.g.:

• IP address is used to determine origin of the request resulting in certain privacy settings becoming applicable or not;
• email address of a (re-shared) Third-Party Data Subject is used for the technical aspects of delivering the message to the recipient under an SMTP protocol;
• email pixel is incorporated in emails sent out (without reporting back if outside of policy coverage);
• in order to capture consent.

Data in Cardify hosted environment (production):

• Cardify Customer Instance: The Cardify Customer instance (including all data it then contains) remains available on production environment for up to 90 days following closure of the Cardify Customer Instance (e.g. where the contract with the Cardify Customer has expired).
• Administrator/User ("Cardify Essential" & "Cardify Pro"): Subject to the above, from the moment the respective account is closed (as part of account management done by the Cardify Customer), the account and the Personal Data it then contains remains available on production environment for up to 90 days following account closure. After such period, the respective Personal Data of that Administrator/User is deleted, resulting in the fact that analytics are anonymised.
• Thir-Party Data Subject ( "Cardify Content"): Subject to the above, as long as the respective Third-Party Data Subject is interacting with or through the Products and Services and for a certain period after the last interaction such Party has had with or through the Products and Services (period as determined and set by the Cardify Customer) the respective Personal Data of that Third-Party Data Subject is deleted, resulting in the fact that analytics are anonymised.
• Deletions on production environments occur in weekly runs.

Data in Cardify hosted environment (backup):

• Backups of the production environment are made on a daily as well as weekly basis;
• Backups are kept for up to 90 days in addition to the above;
• Data will be permanently and irrevocably deleted in backup after such 90-day period.

Cardify has several organisational as well as product related initiatives in that regard.

Organisational initiatives include:

• Dedicated privacy website & FAQ's in respect of the Cardify privacy program: www.Cardify.com/gdpr-information-hub/ and www.Cardify.com/gdpr
• Vetting by Cardify of its vendors & subprocessors: Each vendor to Cardify is vetted by Legal in the areas of security, contractual terms and privacy related matters (e.g. data processing agreements, and applicable transfer mechanisms (e.g. EU standard contractual clauses / Privacy Shield)). Special attention is given to subprocessor that are acting as subprocessor with regard to the Products and Services.
• Contractual documents / privacy policies: Our contractual documents are state-of-the-art and contain the necessary provisions, including in respect of data processing agreements, end-to-end confidentiality, and privacy policies (meeting all necessary legal requirements).

Product related initiatives include:

• EU Data centres / US CDN opt out: Cardify's principle hosting infrastructure is located within the EU at a first-class world-renowned hosting partner.
• Product engineering: All new product capabilities that are to be introduced within the Products and Services are vetted and checked for privacy compliance and follow three key cornerstones: (i) the GDPR principles of "privacy by design" and "privacy by default", (ii) giving flexibility to both EU customers and non-EU customers to allow for localized application of the Products and Services - while (iii) keeping all changes as simple as possible.
• Elaborate privacy settings: The Products and Services provide for elaborate privacy settings allowing e.g. for a localized approach in a granular way or enabling/disabling tracking options.

Cardify has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (a) the pseudonymisation and encryption of personal data; (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.

Cardify shall thereto take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.

While Cardify aims to implement industry-leading safeguards designed to protect Personal Data, we cannot guarantee that any Personal Data which was incidentally processed by the Cardify Customer (e.g. regulated or sensitive Personal Data, see FAQ's B4 and B5) is maintained at levels of protection to meet specific needs or obligations the Cardify Customer may have relating to that type information.

To the extent the activities of the Cardify Customer are covered by the scope of an applicable data protection legislation (e.g. GDPR, CCPA, UK Data Protection Act, Swiss Data Protection act), such applicable data protection legislation may require that the processing of the personal data by the Products and Services is covered under a data processing agreement concluded between Cardify and its Customer.

Cardify thereto makes available a complete DPA for that reflects the unique aspects of the Products and Services and containing all specifics - as required per the applicable data protection law - in order for the Cardify Customer to meet his legal obligations (e.g. standard contractual clauses).

You can obtain this DPA at first request via privacy@getcardify.com.

When making use of the Products and Services the following technology may be used to store nformation on the device you use to connect to the Products and Services ( "Device") or access information already stored on your Device:

• Cookie: a tiny data file that may be placed on Your Device when making use of the Products and Services that stores certain information and makes it available to the publisher of the cookie;
• Embedded scripts: programming code that is designed to collect information about your interactions with the Products and Services, such as the links you click on. The code is temporarily loaded onto your Device from a web server or a third-party service provider, and is active while your Devices is connected to the Products and Services.
• Web Beacons: Small graphic images (also known as "1×1 GIFs" or "clear GIFs") that is designed to collect information about your interactions with the Products and Services, such as the emails you open. Web Beacons are temporarily loaded onto Your Device from a web server when making use of the Products and Services.

The Cookies/Embedded scripts/Web Beacons used within the Products and Services enables certain features and functionalities of the Products and Services.

A Cookies/Embedded script/Web Beacons does not contain or collect information in isolation, but when read by a server via Your web browser or through the Products and Services, it can provide information to such server (e.g. to facilitate a more user-friendly service by registering users' preferences, detect errors, account information, device identification, statistical data,...).

The Products and Services use the following Cookies/Embedded script/Web Beacons:

COMING SOON

Unless where otherwise indicated in the table above, these Cookies/Embedded script/Web Beacons are essential to the Products and Services, without which Cardify can't provide the Products and Services as warranted to the Cardify Customer, or guarantee the correct functioning of the Products and Services.

Apart from the Cardify_SESSION Cookie in the Prospect microsite environment, the Cookies/Embedded scripts/Web Beacons are an inherent and essential part of the Products and Services and are necessary in order for Cardify to be able to provide for the Products and Services as warranted towards the Cardify Customer, or guarantee the correct functioning of the Products and Services.

The Cardify_SESSION cookie in the Prospect microsite environment, is optional and placing this cookie on an end user Device is dependent i) the applicable privacy settings as determined by the Cardify administrator, and ii) the corresponding consent given (or not) by the Prospect in question to become subject to the profiling towards the Customer Content shared. If consent was provided, this cookie will be placed and has a validity period of 14 days, after which consent will be asked again to confirm continued tracking. Deleting this cookie restricts further processing of Personal Data of the Prospect in question.

Deleting or disabling a Cookie can be done by using the following options:

• Web browser
  Most web browsers (e.g. Internet Explorer, Mozilla Firefox, Safari, and Google Chrome) have cookies automatically enabled. You can decide on whether and to what extent cookies will access Your end device by changing your browser settings.
• Online assistance
  More information on cookies and the way to manage or refuse cookies per browser type (e.g. Internet Explorer, Mozilla Firefox, Chrome, Safari,...) can be found at https://www.allaboutcookies.org , https://www.aboutcookies.org or http://www.youronlinechoices.eu
• Tools
  Certain tools (e.g. "Ghostery", "Disconnect",... ) may provide you with more granular options in order to manage cookies

Subject to such right being entrusted by Applicable Data Protection Law (E.g. GDPR, CCPA, UK Data Protection act 2018), Data Subjects may have the right to:

• Obtain access to and/or rectification of one's Personal Data as processed by the Products and Services;
• Request to receive one's Personal Data in a format at the discretion of the Cardify Customer (e.g. excel, .CSV file, via the Cardify API,...), that allows for the data portability of such data to a similar service;
• Withdraw one's consent for processing of one's Personal Data (be advised that such leaves unharmed and does not affect the prior lawful processing of one's Personal Data, or the continuation of processing of (part of) Your Personal Data as allowed under an applicable legal ground (see FAQ B15)
• The restriction of processing of Your Personal Data under article 18 GDPR and/or right to object to the processing of Your Personal Data under article 21 GDPR.

Please check the applicable data protection legislation for the ability to exercise such rights.

As Cardify is merely the data "Processor" (see FAQ B12) such rights need to be exercised towards the Cardify Customer, as being the data "Controller". In order to exercise such rights, You may be required by the Cardify Customer to provide proof of Your identity by providing an official document (e.g. ID Card, driver's license,...).

As Cardify is merely the Data "Processor" (see FAQ B12), in order to exercise Your rights (see FAQ E1), You need to contact the Cardify Customer. In order to exercise such rights, You may be required by the Cardify Customer to provide proof of Your identity by providing an official document (e.g. ID Card, driver's license,...).

Should Cardify receive such request directly from You, Cardify can legally only pass such request on to the Cardify Customer. Cardify is legally not allowed to respond to such request, unless as instructed by the Cardify Customer.

Should Cardify receive a request directly from a Data Subject, Cardify can legally only pass such request on to the Cardify Customer. Cardify is legally not allowed to respond to such request, unless as instructed by the Cardify Customer.

From the moment it is established that the Data Subject request is related to a processing activity for which the Cardify Customer is data "Controller", and to the extent the Cardify Customer is identified, Cardify shall pass on such request without undue delay to the respective Cardify Customer, in order for the Cardify Customer to respond to such request.

In case You as a Data Subject have a complaint about the way Cardify is processing Personal Data, You can always contact the Cardify Legal Department directly at privacy@getcardify.com and we will listen to Your complaint and see if we can help You to resolve this.

If You have an unresolved complaint, You always have the right to log a complaint with the competent "data protection authority". Information on the competent data protection authority and the way of logging a complaint can be found here (or the URL as updated by the European Commission).

Cardify BV, located in Belgium, acts as so-called "main establishment" in the EEA under GDPR. As a result, the competent Data Protection Authority for Cardify BV is the Belgian DPA (Drukpersstraat 35, 1000 Brussel / +32 (0)2 274 48 00 / contact@apd-gba.be / dataprotectionauthority.be).