# Legal Our policies and agreements governing the use of Astrada's services. **Last updated:** July 23, 2024 ## 1. Our approach to privacy Fidel Limited, DBA Astrada ("Astrada", "we", "our", or "us") is committed to protecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies in relation to the Service. Astrada provides the following components to third party providers of transaction data-enabled services ("Clients") for the enrollment of cards and the sharing of relevant transaction data: (i) the enrollment SDK, the API, any related software or websites (such as www.astrada.co) made available by Astrada to support services to the Clients. Please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this Privacy Policy. Astrada is the controller responsible for the personal information we hold about you. If you have any questions about this Privacy Policy or how we use your personal information, please contact us. ## 2. Personal information we collect and how we use it **Processing for access to the Site.** The table below sets out the categories of personal information we may collect in relation to providing the Site Services, how we use that information and the corresponding legal basis which we rely on to process the personal information. | Category of data subject | Category of information | How we use it | Legal basis | | --- | --- | --- | --- | | Clients | Contact information and basic personal and professional details. Such as name, phone number, address, e-mail address. | We use this information to operate, maintain and provide the features and functionality of the Service. | Performance of a contract and legitimate interests. | | Clients, visitors to the Site | Contact information and basic personal and professional details. | We use this information to send news, alerts and marketing communications. | Consent and legitimate interests. | | Clients, visitors to the Site | Correspondence, comments and feedback. | We use this information to monitor and improve the Service, and to address your questions. | Legitimate interests. | | Clients, visitors to the Site | Location information. | We may use an approximate location to ensure content is relevant to the city or country from which the Services are being accessed. | Legitimate interests. | | Clients, Merchants, visitors to the Site | Preferences. | We use this information to provide notifications and display our Service accordingly. | Legitimate interests. | **Processing of data that includes transaction information.** | Category of data subject | Category of information | How we use it | Legal basis | | --- | --- | --- | --- | | Clients, Client customer, End Users | Payment and transaction information. | We use this information to facilitate transactions and support features of spend management services. | Performance of a contract and legitimate interests. | **Processing for analytics purposes.** We also automatically collect personal information indirectly about how you access and use the Service. | Category of data subject | Category of information | How we use it | Legal basis | | --- | --- | --- | --- | | Clients, visitors to the Site | Information about how the Services are accessed and used. | We use this information to determine products and services that may be of interest for marketing purposes. | Legitimate interests. | | Clients, Merchants, visitors to the Site | Technical information about user devices and software. | We use this information to present the Service to users and to enhance and personalise the user experience. | Legitimate interests. | ## 3. Disclosure of your Personal Information We will share your personal information with the following categories of recipients: - **Service providers and advisors.** Third party vendors and other service providers. - **Purchasers and third parties in connection with a business transaction.** Personal information may be disclosed to third parties in connection with a transaction. - **Law enforcement, regulators and other parties** as required by law. We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. ## 4. Storing and Transferring your Personal Information **Security.** We implement appropriate measures to protect your personal information against destruction, loss, change or damage. All personal information will be stored on secure servers. **International transfers of your personal Information.** Your personal information may be transferred to and stored in countries outside your jurisdiction. If you are located in the European Economic Area ("EEA"), your personal information may be processed outside the EU. **Retention of your information.** We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for legitimate business interests. ## 5. Your Rights in Respect of your Personal Information In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold: - **Right of access and portability.** The right to obtain access to your personal information. - **Right to portability.** The right to request the transfer of your personal information. - **Right to rectification.** The right to obtain rectification of your personal information without undue delay. - **Right to erasure.** The right to obtain the erasure of your personal information without undue delay in certain circumstances. - **Right to restriction.** The right to obtain the restriction of the processing of your personal information in certain circumstances. - **Right to object.** The right to object to the processing of your personal information. ## 6. Links to Third Party Sites The Service may contain links to third party websites. Please check the individual policies before you submit any information to those websites. ## 7. Our Policy Towards Children The Service is not directed at persons under 16 and we do not knowingly collect personal information from children. ## 8. Changes to this Policy We may update this Privacy Policy from time to time and so you should review this page periodically. Changes are effective when posted. ## 9. Contacting Us You can contact us with any query related to this Privacy Policy by emailing us at [support@astrada.co](mailto:support@astrada.co).