GDPR Policy

 **Gibemart GDPR Compliance Policy**

**Effective Date:** July 2025

**1. Introduction**

Gcommission ("we," "our," or "us") is committed to complying with the General Data Protection Regulation (GDPR) (EU) 2016/679, ensuring the lawful, fair, and transparent processing of personal data. This policy outlines our GDPR compliance measures, including data subject rights, data protection principles, and responsibilities.

**2. Scope**

This policy applies to:

*   All personal data processed by Gcommission.
*   Employees, contractors, and third-party processors handling EU/UK user data.
*   Users ("data subjects") residing in the European Union (EU), European Economic Area (EEA), and the UK.

**3. GDPR Principles**

We adhere to the following GDPR principles:

*   **Lawfulness, Fairness, and Transparency** – Data is processed legally, ethically, and with clear consent.
*   **Purpose Limitation** – Data is collected only for specified, legitimate purposes.
*   **Data Minimization** – Only necessary data is collected and retained.
*   **Accuracy** – Personal data is kept up to date and corrected when errors are found.
*   **Storage Limitation** – Data is retained only as long as necessary.
*   **Integrity & Confidentiality** – Data is secured against unauthorized access, loss, or damage.
*   **Accountability** – We maintain records to demonstrate compliance.

**4. Lawful Basis for Processing**

We process personal data under one or more of the following lawful bases:

*   **Consent** – Users explicitly agree to data processing (e.g., account registration, marketing emails).
*   **Contractual Necessity** – Data required to fulfill user agreements (e.g., processing transactions).
*   **Legal Obligation** – Compliance with applicable laws (e.g., tax records).
*   **Legitimate Interest** – Where processing is necessary for business operations (e.g., fraud prevention).

**5. Data Subject Rights**

Under GDPR, users have the following rights:

| Right | Description | How to Exercise |
| :--- | :--- | :--- |
| **Right to Access** | Request a copy of personal data held. | Submit a request via support@gcommission.com. |
| **Right to Rectification** | Correct inaccurate or incomplete data. | Update profile settings or contact support. |
| **Right to Erasure ("Right to Be Forgotten")** | Request deletion of personal data. | Email support@gcommission.com. |
| **Right to Restriction of Processing** | Limit how data is used. | Submit a request with justification. |
| **Right to Data Portability** | Receive data in a structured, machine-readable format. | Available for automated processing. |
| **Right to Object** | Opt out of processing (e.g., direct marketing). | Unsubscribe or adjust account settings. |
| **Rights Related to Automated Decision-Making** | Request human intervention for automated profiling. | Contact support for review. |

We respond to requests within 30 days (may extend for complex cases).

**6. Data Security Measures**

We implement technical and organizational safeguards, including:

*   Encryption (SSL/TLS for data transmission).
*   Access Controls (role-based permissions for employees).
*   Regular Security Audits (vulnerability assessments).
*   Data Breach Response Plan (notification within 72 hours if required).

**7. Data Transfers Outside the EU/UK**

If data is transferred outside the EU/UK, we ensure:

*   Adequacy Decisions (e.g., EU-US Data Privacy Framework compliance).
*   Standard Contractual Clauses (SCCs) with third-party processors.

**8. Third-Party Processors**

We use GDPR-compliant vendors (e.g., payment processors, cloud hosting). Contracts include:

*   Data processing agreements (DPAs).
*   Confidentiality and security obligations.

**9. Data Retention & Deletion**

Personal data is retained only as long as necessary (e.g., transaction records for tax compliance).
Inactive accounts may be deleted after 24 months of inactivity.

**10. Data Protection Officer (DPO)**

For GDPR-related inquiries, contact our DPO:
📧 Email: dpo@gcommission.com

**11. Updates to This Policy**

Changes will be posted on our website with prior notice where required.

**Contact Information**

For GDPR requests or concerns:
🔗 GDPR Request Form
📧 support@gcommission.com

Gcommission reserves the right to update this policy in accordance with legal requirements.

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