Privacy Policy

This privacy statement is effective as of June 4, 2023. Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.

Unless stated otherwise, this privacy statement applies to all of Aequil Living Inc Ltd.’s externally facing web applications, services, websites and other data processing activities where Aequil Living Inc Ltd. is acting as a data controller.

This page tells you what you need to know about how Aequil Living Inc Ltd. ("Aequil Living inc Ltd."; "we") protect the personal data we process and control relating to you (“your personal data”; "your data") and which rights you have in relation to the processing of your personal data.

1. How does Aequil Living Inc Ltd. protect your personal data?

Aequil Living Inc Ltd. protects your personal data in accordance with applicable laws and our data privacy policies. In addition, Aequil Living Inc Ltd. maintains the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

The following sections provide further details as to how Aequil Living Inc Ltd. processes your personal data:

Which categories of personal data do we collect and how do we process such personal data?

We collect personal data of our clients and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.

The personal data we collect include the categories of personal data described in the sections “How do we use personal data when you visit Aequil Living Inc Ltd.’s website?”, “How do we use cookies (and other tracking technologies)?”, “How do we use personal data when you visit our offices?” and “How do we use personal data for marketing purposes?”, as well as any other categories of personal data referred to in this privacy statement or in other statements you have received.

Below is also a chart describing the categories of personal data we collect:

Category of personal information

Types of personal information acquired by category

Personal details, contact details, and identifiers.

Firstname, Lastname, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address) and occasionally, when necessary for specific purposes, gender, date of birth, age, place of birth.

Commercial information.

History and records of the products and services you have obtained from Aequil Living Inc Ltd.. Correspondence between you and us when it is sent to a dedicated mailbox or via other electronic communication means for the purpose of processing account receivable payments and commercial follow-up.

Marketing and research information

  1. Identifiers – the IP address, social media handle or other online identifiers of a person, e-mail address/mobile number if used for direct marketing, and name and address
  2. Demographic data provided by analytics tools- (e.g. income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers)
  3. Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services and content, information about your mobile device including (where available) type of device, device identification number, mobile operating system.

Cookies and geolocation data

As described below, we also may collect geolocation data in some circumstances. Please see our Cookies policy for more details regarding our use of cookies.

Except for certain information that is required by law or by Aequil Living Inc Ltd. Policies, your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, clients and vendors. Except where certain information is required by law or by Aequil Living Inc Ltd. policies (including management of an employment relationship with Aequil Living Inc Ltd.), your decision to provide any personal data to us is voluntary. Please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.

For which purposes and on which legal basis do we use your personal data?

Aequil Living Inc Ltd. uses your personal data only where required for specific purposes. Please view the table below for a list of the purposes for which Aequil Living Inc Ltd. uses your personal data and an overview of the legal basis for each such purpose.

Purpose

Legal basis

Facilitating communication with you (including facilitating meetings; communication in case of emergencies, and to provide you with requested information).

Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.

Operating and managing our business operations including or being part of the provision of our services to our clients and their employees/contractors and their customers, for example in collecting their data as part of surveys/assessments, data analytics, Marketing research or other purposes.

Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.

Complying with legal requirements.

Necessary for the compliance with a legal obligation to which we are subject.

Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).

Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.

Improving the security and functioning of our website, networks and information.

Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.

Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance and/or to provide a better user experience. This includes marketing analytics and analytics related to the organization of events/meetings.

Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.

Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing purposes?” below).

Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.

Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms.

We will process your personal information for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.

To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal information, only where such consent is required by mandatory law.

We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

Will we share your personal data with third parties?

We may transfer personal data to our service providers and professional advisors, public and governmental authorities. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and Aequil Living Inc Ltd.’s internal policies. If you would like more information on the categories of personal information we may share please read the section titled "Which categories of personal data do we collect and how do we process such personal data?”

For example, we may disclose personal information to third parties for other business purposes as follows:

• We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;

• To protect and defend the legal rights, safety, and security of Aequil Living Inc Ltd., our affiliates, users, or the public, including to protect against fraud and malicious activity; and

• For other business purposes described in this privacy statement or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent.

We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses (a copy of which can be obtained through the contact information included below). Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.

What about sensitive data?

We do not generally seek to collect sensitive data as defined in the second paragraph below (also known as special categories within the EEA) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term "sensitive data" refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

What about data security?

We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.

We adopt market leading security measures to protect your personal data. This includes :

• Our webhosting company holds an ISO27001 certification, which indicates that we adhere to the highest and strictest information security standards (https://www.godaddy.com/trust-center/compliance).

• Our CMS provider Webflow holds a ISO 27001 certification and the CIS Critical Security Controls

• Payment processor, Stripe is a certified Level 1 Service Provider. Webflow never has access to sensitive payment details (https://webflow.com/security).

• Email marketing tool, Klaviyo has its own security measures presented in its data processing agreement (https://www.klaviyo.com/legal/data-processing-agreement)

What are the sources we get your personal information from?

The personal information we obtain come from:

• Website web form

• When you register to our website

• Marketing system like mailing system

In section 4, you can find more information on the sources of your personal information for marketing purposes.

How long will your personal data be retained by us?

We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

• We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).

• We will only keep the data while your account is active or for as long as needed to provide services to you.

• We retain your data for as long as needed in order to comply with our global legal and contractual obligations.

Which rights do you have with respect to the processing of your personal data?

You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

• Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.

• Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.

• Object to the processing of your personal data: this right entitles you to request that Aequil Living Inc Ltd. no longer processes your personal data.

• Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.

• Request the restriction of the processing of your personal data: this right entitles you to request that Aequil Living Inc Ltd. only processes your personal data in limited circumstances, including with your consent.

• Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to Aequil Living Inc Ltd., or request Aequil Living Inc Ltd. to transmit such personal data to another data controller.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting Aequil Living Inc Ltd. . Please note that this will not affect Aequil Living Inc Ltd.’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to Aequil Living Inc Ltd. first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against Aequil Living Inc Ltd. with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).

Contact us to exercise any of your rights.

2. How do we use personal data when you visit aequilliving.com’s website?

In addition to the information set out above, the following sections describe how we use personal data when you visit aequilliving.com’s website:

Which personal data do we gather?

Aequil Living inc Ltd. collects personal data at its websites in two ways:

- directly (for example, when you provide personal data to sign up for a newsletter or register to buy products);

- indirectly (for example, through our website's technology).

We may collect and process the following personal data:

• Personal data that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts. Pages that collect this type of personal data may provide further information as to why your personal data are needed and how it will be used. It is completely up to you whether you want to provide it.

• If you contact us, we may keep a record of that correspondence.

• We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

• Our website or mobile applications can collect personal information about your computer or your mobile device, including (where available) your IP address, operating system, type of device, device identification number, mobile operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.

• Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies section below for more information.

Do we include (links to) websites and programs of third parties?

Our websites may include:

• Links to and from the sites of our partner networks, advertisers and affiliates

• Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.

We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.

How do we use personal data that we collect from our websites?

We use personal data for the purposes described in the section “For which purposes and on which legal basis do we use your personal data?” above, as well as to provide you with information you request, and for other purposes which we would describe to you at the point where it is collected. For example:

• Links to and from the sites of our partner networks, advertisers and affiliates.

• Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section below for more information.

3. How do we use cookies (and other tracking technologies)?

In addition to the information set out above, this section describes how we use cookies and other tracking technologies.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.

Please see our Cookies policy for more details including for information about your choices with respect to advertising and social media cookies and for access to our cookie consent manager. By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies policy.

4. How do we use personal data for marketing purposes?

In addition to the information set out above, the following sections describe how we use personal data for marketing purposes:

What are the sources of marketing data?

TBD.

Do we send targeted e-mails?

We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from Aequil Living inc Ltd., we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Targeted e-mails from Aequil Living Inc Ltd. may include additional data privacy information, as required by applicable laws.

Do we maintain Customer Relationship Management (CRM) databases?

Aequil Living Inc Ltd. uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Aequil Living Inc Ltd. professionals based on their personal interactions with you.

Do we share personal data with third parties?

In addition to the third parties mentioned in the section “Will we share your personal data with third parties?" above, we may share your personal data with marketing agencies.

What are your rights regarding marketing communications?

You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.

5. Contact us

Please contact us here if:

• You have a general question about how Aequil Living Inc Ltd. protects your personal data.

• You wish to exercise your rights in relation to your personal data rights

• You wish to make a complaint about Aequil Living Inc Ltd.’s use of your data.

You can also contact Aequil Living Inc Ltd. as data controller of your personal data via our Data Privacy Officer (preferably electronically) or via letter, clearly marked for the attention of the Data Privacy Officer, on the this address:

Aequil Living Inc Ltd.

33B Beauchamp Place, London, SW3 1NU, UK

6. Region specific disclosures

TBD.