5. why and on what legal grounds is your data processed?
5.1 In case we use consent, we shall Process Personal Data precisely within the limits of the consent.
5.2 We mostly Process Personal Data for entering into and performance of an Agreement; mainly for the following Purposes:
(5.2.1) in order to provide the Services that we offer;
(5.2.2) In order to be able to send information, free samples and products to our Clients;
(5.2.3) to register Clients and for classes and telecalls;
(5.2.4) to store and distribute the recordings of classes and telecalls to enable Clients play back classes or telecalls they attended.
5.3 We may also use legitimate interest which means the interest of us in the management and direction of our business in order to be able to offer the best possible Services for you. We shall Process Personal Data on a legal basis of legitimate interest only after careful consideration, based on which the Personal Data Processing is necessary and is in compliance with the interests and rights of a Data Subject (after carrying out the so-called three-step test, i.e. assessing our interests and your rights). In particular, Personal Data Processing may take place on the basis of a legitimate interest for the following purposes:
(5.3.1) for the administration and analysing the Client base to improve the availability, selection and quality of Services and products, and to make the best and more personalised offers to the Client upon the Client’s consent;
(5.3.2) for the identifiers and Personal Data collected upon the use of websites and other Services. We shall use the collected data for web analysis or for the analysis of information society services, for ensuring and improving the functioning, for statistical purposes and for analysing the behaviour and using experience of Visitors/ Clients and for providing better and more personalised Services;
(5.3.3) for the organisation of campaigns, including organisation of personalised and targeted campaigns, carrying out Client and Visitor satisfaction surveys, and measuring the effectiveness of the performed marketing activities;
(5.3.4) for the organisation of campaigns, including organisation of personalised and targeted campaigns, carrying out Client and Visitor satisfaction surveys, and measuring the effectiveness of the performed marketing activities;
(5.3.5) for monitoring of the service. We may record the messages and instructions given in its premises as well as by means of communication (e-mail, telephone, etc.), as well as information and other operations carried out by us; we can use those recordings as needed to evidence instructions or other operations;
(5.3.6) for network, information and cyber security considerations, for example for fighting against piracy and for ensuring the security of the Websites, as well as for the measures taken for making and storing backup copies;
(5.3.7) for corporate purposes, in particular for the financial management;
(5.3.8) for the establishment, exercise or defence of legal claims.
5.4 For performing a legal obligation, we shall Process Personal Data to perform the obligations set forth by law or to exercise the uses permitted by law. Legal obligations derive, for example, from adhering to the rules of payment processing and prevention of money laundering.
5.5 In case Personal Data Processing is carried out for a new purpose, different from those for which the Personal Data were originally collected, or is not based on the consent given by the Data Subject, we shall carefully assess the permissibility of such new Processing. In order to determine whether the Processing for the new purpose is in compliance with the purpose for which the Personal Data were originally collected, we shall take into consideration, inter alia, the following:
(5.5.1) any link between the purposes for which the Personal Data were collected and the intended further purposes Processing;
(5.5.2) the context of collecting the Personal Data, in particular regarding the relationship between you and us;
(5.5.3) the nature of the Personal Data, in particular whether any special categories of Personal Data, or Personal Data are processed;
(5.5.4) possible consequences of the intended further processing for the Data Subjects;
(5.5.5) existence of appropriate protection measures which may consist in, for example, encryption and pseudonymisation.