Last updated: September 11, 2023
The document explains the personal data we collect, how and where we may use it, how we protect it, who has access to it, with whom we share it, and how you may correct it.
We deal with your personal data in a confidential and responsible way.
Personal data according to the European legislation definition (GDPR - Regulation 2016/679 means:
any information relating to an identified or identifiable natural person ('data subject'); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity;
We will only process data pursuant to purposes and means you determine. In these cases, we will provide you with separate data processing agreements.
1.1 In order to provide our services, we collect information. Some information you provide directly to us, some we collect automatically through our Services, and some is collected from third parties. In this Notice, "Personal Data" refers to data that could be used to identify you as an individual.
1.2 Safenetclub.com offers data security products and services. Our goal is to ensure information and network security by providing quality products and services while also respecting privacy and personal data of customers.
SSH Invest Holding GmbH
Blankenheimer Strasse 25
Phone: +49 221 530 00665
Email: [email protected]
3. Changes to this Policy
3.1 We reserve the right to modify this Policy at any time, and when required by law, we will notify you of changes to this Policy. If we make any material changes, we will notify you via posting this information on your account.
4. Personal data collected
4.1 Safenetclub.com may collect personal information from its users in several different ways. The Company undertakes to ensure your personal data is:
- 4.1.1 processed lawfully, fairly, and in a transparent manner in relation to you;
- 4.1.2 collected for specified, explicit and legitimate purposes (f. e. prevention of money laundering and terrorist financing, performance of Services, etc.), and not further processed in a manner that is incompatible with those purposes;
- 4.1.3 adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- 4.1.4 accurate and, where necessary, kept up to date;
- 4.1.5 kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed;
- 4.1.6 processed in a manner that ensures appropriate security of your personal data.
4. Personal data collected
4.2 Safenetclub.com follows the above indicated principles strictly during the processing of your personal data and request the same from the data processors which it may use to process personal data on behalf of the Company.
4.3 Personal data directly provided by a user - for example, when you complete a website form, we might ask your name, surname and/or email address so we can contact you with updates, notices, or to provide support.
4.4 All these data are being used for contacting you on your specific request or, if you subscribed for our newsletter or commercial communication, for marketing purposes. The legal basis for processing these data is consent of the data subject in receiving that respective information or subscribing to our newsletter.
4.5 As regards your subscription to our newsletter or commercial communications, we will keep our communication going, until you withdraw your consent or you don't engage with our email in the past 5 years.
4.6 All these data are used exclusively for website improvement or statistical purposes, but also for improving our web services and ensuring their security. Most of these data is being used only as aggregated data. The data is kept only as long as they are necessary for these purposes. The legal basis for this collection is legitimate interest for Improving our website for the ensuring the security of your website.
5. What kind of personal data do we collect?
5.1. General: We process such personal data that you as a user of the Website make available to us, for example upon registration or when using the Website (the „Data").
5.2. Website Use: If you visit our website, we process only personal data that your browser communicates to our server. We collect the following data, which is necessary for us in order to display the website correctly and guarantee the necessary stability and security:
- 5.2.1 IP-address;
- 5.2.2 browser, operating system, interface, language and version of the browser software.
5.3. Registration Data: Upon registration we collect and process the following information:
- 5.3.1 registration details: date of registration, password; personal information: full name; email address; address, zip code, city, region, country;
- 5.3.2 payment information:
- 5.3.3 email address;
5.4. Product Use Data: Data processed when using the Services is processed by us only as a processor, not as a controller.
6. The reason we collect personal information
6.1. Purpose: The processing of Data pursues the following purposes:
- 6.1.1 comply with applicable laws and regulations;
- 6.1.2 provide and improve the Services;
- 6.1.3 security and stability of the Services.
6.2. Lawfulness of Processing: The lawfulness of processing stems from:
- 6.2.1. your consent, where we have asked your explicit consent (para.1 subpara. a GDPR); and
- 6.2.2. the necessity for the performance of contract fulfillment, as your data is needed for a satisfactory use of the Services (para 1 subpara. b GDPR); and
- 6.2.3. the necessity for the purposes of the legitimate interests pursued by the Company or by a third party (para 1 subpara. f GDPR).
6.3. Legitimate Interests: The legitimate interests to analyze and improve the Website, to support you with any to protect the security, integrity, performance and functionality of the Services, and to provide you with advertisements.
7. Protecting the Personal data
7.1 Confidentiality and data protection are of vital importance for us. Access to the collected personal data is restricted only to Safenetclub.com employees and data processors that need access to this information. All Safenetclub.com information security policies are ISO 27001 certified.
8. Sharing of Information
8.1 We will never sell or rent your personal information. We will only share your Information in the following circumstances:
- 8.1.1 with your consent or at your instruction;
- 8.1.2 in connection with offers on the Website;
- 8.1.3 certain information you may choose to share may be displayed publicly,
- 8.1.4 in order to prevent fraud or other illegal or unauthorized activities;
- 8.1.5 if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
- 8.1.6 with law enforcement officials, courts, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our Service Agreement or any other applicable policies;
- 8.1.8 with third parties where aggregate Information is disclosed which cannot be reasonably be used to identify you.
9. Your personal data rights
9.1 According to European Union applicable data protection legislation, data subjects shall:
- 9.1.1 access or receive certain data about the personal information we process about you;
- 9.1.2 have your personal information rectified;
- 9.1.3 object to the processing of your personal information or ask us to restrict processing or delete your personal information;
- 9.1.4 withdraw your consent to our processing of your personal information; and
- 9.1.5 not be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
9.2 For exercising these rights, you may send a written request, dated and signed and send via email to [email protected]
10. Children's Privacy
10.1. Some of Safenetclub's Services provide security features that parents may use to monitor their child's activity online, physical location, or use of a registered device.
10.2. These Services require parental consent, and we do not knowingly use the Personal Data we collect from children's devices for any purpose except to deliver the Services. These products allow parents to delete their child's profile at any time.
10.3. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please contact us as described below.
10.4. If you are under the age of 18, you must have your parent's permission to access the Services.
10.5. Safenetclub urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission.
10.6. If you learn that your child has provided us with Personal Data without your consent, you may alert us by contacting us.
10.7. If we learn that we have collected any Personal Data from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child's account.
12. Publication date