1. Introduction

ASilva Innovations is committed to ensuring the protection of personal data in compliance with the General Data Protection Regulation (GDPR). This policy outlines our practices for handling personal data and the rights of individuals under the GDPR.

2. Individual Rights

2.1 Consent: We obtain consent from individuals for the processing of their personal data through clear, specific, and unambiguous means. Consent is obtained through explicit actions, and we ensure that individuals are aware of what they are consenting to. Consent cannot be inferred from silence, pre-ticked boxes, or inactivity. Individuals have the right to withdraw their consent at any time, and this right is communicated to them during the consent process.

2.2 New Rights for Individuals

• Right to be Forgotten: Individuals can request the deletion of their personal data, and we will notify relevant downstream recipients of such requests.
• Right to Data Portability: Individuals can request a copy of their personal data in a common, machine-readable format.

2.3 Access Requests

Individuals have the right to access their personal data. We will process access requests within one month, extendable by an additional two months in complex cases. Requests deemed manifestly unfounded or excessive may be refused, with clear refusal policies and justifications in place.

3. Internal Procedures

3.1 Privacy by Design and DPIA

We incorporate data privacy principles into the design of our systems and perform Data Privacy Impact Assessments (DPIAs) when processing data using new technologies or in high-risk scenarios. DPIAs help identify and mitigate potential privacy issues before the project proceeds.

3.2 Data Privacy Officer

ASilva Innovations has appointed a Data Privacy Officer (DPO) responsible for overseeing GDPR compliance. The DPO’s role includes advising on data protection matters, monitoring compliance, and serving as a point of contact for data subjects and supervisory authorities.

3.3 Contracts & Privacy Documentation

We regularly review and update our Privacy Notices, Privacy Statements, and internal data policies to ensure GDPR compliance. Contracts with third-party processors are updated to include mandatory GDPR provisions.

4. Supervisory Authorities

4.1 One-Stop Shop

Organizations operating in multiple EU countries will have a lead supervisory authority that serves as the central point of contact for enforcement, ensuring consistent compliance and communication.

4.2 Reporting Breaches

We notify the relevant supervisory authority of any personal data breach within 72 hours of becoming aware of it, except where data is anonymized or encrypted. Breaches likely to cause harm to individuals are similarly reported to the affected individuals.

5. Scope and Accountability

5.1 Scope

GDPR applies to ASilva Innovations if we process or control the data of EU citizens, even if we are based outside the EU.

5.2 Accountability

We maintain comprehensive records of our data processing activities and implement technical and organizational measures to ensure compliance. Staff training is conducted regularly to reinforce GDPR principles.

6. Penalties

ASilva Innovations acknowledges the severe penalties for GDPR violations, which can be up to €20 million or 4% of global annual turnover, whichever is greater. We are committed to upholding data protection standards to avoid such penalties.

7. Review and Updates

This policy will be reviewed periodically and updated as necessary to reflect changes in legal requirements or organizational practices.For any questions or concerns regarding this policy, please contact our Data Privacy Officer at admin@asilvainnovations.com.

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Updated on 07/17/2022