User register of the Elevate.ac service
Use of personal details (purpose of register)
Personal details are collected to make communication and use of service possible. Details can be used for communication between service providers and users and also for direct communication between users. Some personal details are visible on the profile page of the user, but those details are voluntary (except name).
The handling of personal details is not outsourced, but the register data is stored on a server that is rented from a third party company.
Information content of the register
The following information may be stored in the register:
- Personal details: Name, email address, phone number, street address
- Account details: username, password (stored in encrypted format)
- The description text that the user may write about him/herself
- The offers and requests the user has posted to the service
- The given and received feedback and badges
- Statistical data about service usage, e.g. number times the user has logged in
Regular sources of information
Personal details are given by the user on registration to the service or when using it later.
Regular handovers of the information
Information considering users of a single Elevate community may be handed over to the client who has founded that community or to the community administrators appointed by that client.
Transfers of the information outside the EU and the European Economic Area
Information may be stored to a server that may be located inside or outside of the EU and the European Economic Area
Register protection principles
The information is stored on computers. The access to the information is restricted with passwords and physical access to the computers is restricted by the server hosting company.
HEADLINES: Members retain IP over their own original content, and any raw footage produced by Elevate on their behalf. Elevate is building a catalogue of content including masterclasses and premium learning. Instead of a standard model of building an IP portfolio, Elevate represents the best interests of its members. For more details ask email@example.com.
By using Elevate.ac, you agree to these terms.
By using the Elevate.ac services (herein after "Elevate.ac's service", "Elevate.ac" or just “Elevate”) information.
- You may not use the Service for any illegal or unauthorized purpose. You must not, in the use of the Service, violate any laws in your jurisdiction or the UK (including but not limited to copyright laws).
- Payments and Refunds
- If you sign up for a free trial on a paying account, and you do not cancel or become a full member within 14 days, you will be sent an e-mail inviting you to begin paying for your subscription. If you choose not to pay once your trial has expired, your account will be suspended until payment is received. If you enter your payment information before the trial has ended, your trial ends on that day.
- The Service is billed in advance on a monthly basis and is non-refundable. There will be no refunds or credits for partial months of service, upgrade/downgrade refunds, or refunds for unused months with an open account.
- If you choose to save your details when paying for Elevate.ac's service, Elevate.ac reserves the right to take payment for invoices from that card.
- All payments are to be made in USD unless otherwise agreed.
- Elevate.ac reserves the right to change our monthly fees upon 30 days notice from us. Fee change notices may be posted to the Service or on the Elevate.ac website.
- Cancellation and Termination
- You alone are responsible for the proper cancellation of your account. You may cancel your account by emailing info@Elevate.ac.com.
- Elevate.ac may cancel or suspend your account immediately without notice for any of the following reasons:
- Failure to pay an invoice or late payment (payment delayed by 5 days or more).
- Illegal activity involving or in any way relating to use or misuse of Elevate.ac.
- Any attempt by your users to extract data from the Elevate.ac system which you do not rightly have access to or damage Elevate.ac such that such access is made easier for others.
- Any damage (intentionally or otherwise) to the service Elevate.ac offers by your users.
- Any activity by your users which results in a significant increase in the costs to Elevate.ac of providing the Elevate.ac service.
- Any activity by your users which defames Elevate.ac or damages its reputation.
- In the event of cancellation or long-term suspension Elevate.ac will provide exports of your data using all Elevate.ac's standard export features free of charge unless prevented from doing so by law. If any further data is required Elevate.ac will make a reasonable effort to provide that data in a usable format charging a reasonable hourly rate for that work.
- If you cancel the Service before the end of your current paid up month, your cancellation will take effect immediately and you will receive one final invoice usage in the month of cancellation.
- Such termination of the Service will result in the deactivation or deletion of your Account or your access to your Account, and the forfeiture and relinquishment of all Content associated with your Account.
- Elevate.ac reserves the right to refuse service to any new customer for any reason.
- Elevate.ac reserves the right to modify the service at any time without notice. Unless otherwise agreed all customers will be provided with the same service as defined by their pricing tier.
- Copyright and Content Ownership
- Other than by specific negotiation with content provider, Elevate.ac owns the intellectual property rights to any and all protectable components of the Service, including but not limited to the name of the Service, artwork and end-user interface elements contained within the Service, many of the individual features, and the related documentation and video content. You may not copy, modify, adapt, reproduce, distribute, reverse engineer, decompile, or disassemble any aspect of the Service which Elevate.ac owns.
- Other than by specific negotiation with content provider, Elevate.ac claims intellectual property rights in perpetuity over Content you may provide to the Service as a Content Provider. By using the Service to promote your company, yourself, or any cause as a Content Provider, you agree that others may view your Content. As a Content Provider, Content copyright transferred to Elevate.ac is made with full title guarantee, in that: (i) that the Content Provider has the right to dispose of the copyright; (ii) that the Content Provider will do all that he or she (or it) reasonably can to grant the title purported to be granted; and (iii) that the copyright is transferred free from encumbrances, charges and adverse rights.
- Where associate agreements, revenue share, or commission is agreed with a Content Provider, this is done by separate negotiation with the Content Provider, and does not negate clause 5.1 and 5.2 above.
- How We Use Your Information (Data Protection)
- We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers. We may use third party service providers to help us operate our business or administer activities on our behalf. We may share your information with these third parties as part of our business operations.
- We treat your end user database with the greatest respect and will never share its contents with another user of Elevate.ac.
- Individuals can access material on Elevate.ac provided by multiple Content Providers, and these Content Providers will have access only to the user data of those individuals who have completed their Content, as a specific and restricted database.
- We may use your review, profile picture and abbreviated name on our website and in social media posts to promote Elevate.ac and our content providers.
- General Conditions
- Your use of the Service is at your sole risk. The service is provided on an "as is" and "as available" basis.
- We may, but have no obligation to, remove Content and Accounts containing Content that we determine in our sole discretion are unlawful, offensive, threatening, libelous, defamatory, pornographic, obscene or otherwise objectionable or violates any party’s intellectual property or these Terms of Service.
- You agree not to resell, duplicate, reproduce or exploit any part of the Service without the express written permission of Elevate.ac.
- It is your responsibility to check every invoice and payment order to make sure they are correct before receiving or dispensing funds.
- Elevate.ac does not warrant that (i) the service will meet your specific requirements, (ii) the service will be uninterrupted, timely, secure, or error-free, (iii) the results that may be obtained from the use of the service will be accurate or reliable, (iv) the quality of any products, services, information, or other material purchased or obtained by you through the service will meet your expectations, and (v) any errors in the Service will be corrected.
- Elevate.ac, its affiliates and its sponsors are neither responsible nor liable for any direct, indirect, incidental, consequential, special, exemplary, punitive or other damages arising out of or relating in any way to your use of the Service. Your sole remedy for dissatisfaction with the Service is to stop using the Service.
- If any provision of the Terms of Service is held invalid or otherwise unenforceable, the enforceability of the remaining provisions shall not be impaired thereby.
- The failure of Elevate.ac to exercise or enforce any right or provision of the Terms of Service shall not constitute a waiver of such right or provision. The Terms of Service constitutes the entire agreement between you and Elevate.ac and govern your use of the Service, superseding any prior agreements between you and Elevate.ac (including, but not limited to, any prior versions of the Terms of Service).
- Questions regarding the Terms of Service should be sent to support@Elevate.ac.com
- Customer support can be reached at support@Elevate.ac.com
- Any dispute over these terms of service and any disagreement between Elevate.ac and its customers will be judged under the laws of the United Kingdom.
- Fee Calculations
Elevate.ac fees are made up of different options:
- A fixed monthly fee “all you can eat”, charged in advance through the User account.
- An Elite membership fee, paid in advance or per month, allowing for Content hosting and management thereof, paid in advance through the User account or through direct contract with Elevate.ac.
- Other fee calculation and payment methods remain at Elevate.ac’s sole discretion, through negotiation with Users and/or Content Providers.
- Responsible Elevate.ac entity
- Elevate.ac is the controller of your Personal Data as described in this Privacy Statement, unless expressly specified otherwise.
- For the avoidance of doubt, this Privacy Statement does not apply to the extent we process Personal Data in the role of a processor on behalf of our customers, including where we offer to our customers various cloud products and services through which our customers (and/or their affiliates): (i) create their own Content running on our platform; (ii) sell or offer their own products and services; (iii) send electronic communications to other individuals; or (iv) otherwise collect, use, share or process Personal Data via our cloud products and services.
- Elevate.ac is not responsible for the privacy or data security practices of our Content Providers, which may differ from those set forth in this Privacy Statement.
- Processing activities covered
This Privacy Statement applies to the processing of Personal Data collected by us when you:
- Visit our websites that display or link to this Privacy Statement
- Visit our branded social media pages
- Visit our offices
- Receive communications from us, including emails and phone calls
- Use our cloud products and services as an authorized user (for example, as an employee of one of our customers who provided you with access to our services) where we act as a controller of your Personal Data
In the case that our websites and services contain links to other websites, applications and services maintained by third parties, the information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which you should review to better understand those third parties’ privacy practices.
- What Personal Data do we collect?
The Personal Data that we collect directly from you includes the following:
- If you express an interest in obtaining additional information about our services, request customer support, use our "Contact Us" or similar features, register to use our websites, or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, email address or username and password
- If you use and interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data
- If you use and interact with our services, we automatically collect information about your device and your usage of our services, through log files and other technologies, some of which may qualify as Personal Data
- If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request and
- If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival.
- If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information set out in the “Contacting us” section below.
- What device and usage data we process?
We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons and similar technologies to automatically collect information that may contain Personal Data from your computer or mobile device as you navigate our websites, our services or interact with emails we have sent to you.
Device and usage data
As is true of most websites, we gather certain information automatically on connection with the use of the website by individual users. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our websites and to guarantee their security and continued proper functioning.
In addition, we gather certain information automatically as part of your use of the cloud products and services. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches and other actions you take, operating system and system configuration information and date/time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, as well as to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities and for the security of Elevate.ac generally (in addition to the security of our products and services). Some of the device and usage data collected within the services, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device and usage data is primarily used for the purposes of identifying the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers (where we act as a processor).
Cookies, web beacons and other tracking technologies on our website and in email communications
When you visit our websites, we or an authorized third party may place a cookie on your browser and/or device, which collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track usage, determine your browsing preferences and improve and customize your browsing experience.
We also use web beacons on our websites and in email communications. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. Such technologies are used to operate and improve our websites and email communications.
Notices on behavioural advertising and opt-out for website visitors
As described above, we or third parties may place or recognize a unique cookie on your browser when you visit our websites for the purpose of serving you targeted advertising (also referred to as “online behavioural advertising” or “interest-based advertising”). To learn more about targeted advertising and advertising networks or opt out, please visit the opt-out pages of the Network Advertising Initiative.
To manage the use of targeting and advertising cookies on this website, click the Cookie Preferences link in the footer of the page or consult your individual browser settings for cookies. To learn how to manage privacy and storage settings for Flash cookies, click here. Various browsers may also offer their own management tools for removing HTML5 local storage.
Opt-Out from the setting of cookies on your individual browser
In addition to utilizing the user preference centre, where available, you may opt-out from the collection of non-essential device and usage data on your web browser (see the "What device and usage data we process" section, above) by managing your cookies at the individual browser level. In addition, if you wish to opt-out of interest-based advertising click here for N.America or click here for EU).
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Therefore, we do not currently commit to responding to browsers' DNT signals with respect to our websites. Elevate.ac takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
Telephony log information
If you use certain features of our services on a mobile device, we may also collect telephony log information (like phone numbers, time and date of calls, duration of calls, SMS routing information and types of calls), device event information (such as crashes, system activity, hardware settings, browser language), and location information (through IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers).
- Purposes for which we process Personal Data and the legal bases on which we rely
We collect and process your Personal Data for the purposes and on the legal bases identified in the following:
- Promoting the security of our websites and services: We process your Personal Data by tracking use of our websites and services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others;
- Providing necessary functionality: We process your Personal Data to perform our contract with you for the use of our websites and services; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to provide you with the necessary functionality required during your use of our websites and services;
- Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
- Handling contact and user support requests: If you fill out a “Contact us” web form or request user support, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
- Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you;
- Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent;
- Assessing and improving user experience: We process device and usage data as described in the section above, which in some cases may be associated with your Personal Data, in order to analyze trends in order to assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the service offering, or where we seek your valid consent;
- Reviewing compliance with applicable usage terms: We process your Personal Data to review compliance with the applicable usage terms in our customer’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
- Assessing capacity requirements: We process your Personal Data to assess the capacity requirements of our services the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements of our service offering;
- Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users’ experiences;
- Registering office visitors: We process your Personal Data for security reasons, to register visitors to our offices and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices and our confidential information against unauthorized access;
- Displaying personalized advertisements and content: We process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our websites or, where necessary, to the extent you have provided your prior consent (please see the "Your rights relating to your Personal Data" section, below, to learn how you can control how the processing of your Personal Data by Salesforce for personalized advertising purposes);
- Sending marketing communications: We will process your Personal Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the "Your rights relating to your Personal Data" section, below, to learn how you can control the processing of your Personal Data by Salesforce for marketing purposes); and
- Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
- Where we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.
- Who do we share Personal Data with?
We may share your Personal Data as follows:
- With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment for the purposes and pursuant to the legal bases described above such service providers comprise companies located in the countries in which we operate
- If you use our services as an authorized user, with your affiliated customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies
- With third-party social media networks, advertising networks and websites, which usually act as separate controllers, so that Elevate.ac can market and advertise on third party platforms and websites
- With the Content Provider upon course / module completion.
- If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by third party, with such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
- We may also share anonymous usage data with Elevate.ac’s service providers for the purpose of helping Elevate.ac in such analysis and improvements. Additionally, Elevate.ac may share such anonymous usage data on an aggregate basis in the normal course of operating our business for example, we may share information publicly to show trends about the general use of our services.
- How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the "Purposes for which we process Personal Data and the legal bases on which we rely" section, above). We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
For further information on applicable data retention periods, please contact us by using the information in the “Contacting us” section, below.
- Your rights relating to your Personal Data
You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the EEA, these rights may include:
- To access your Personal Data held by us (right to access)
- To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification)
- To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure right to be forgotten)
- To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing)
- To transfer your Personal Data to another controller, to the extent possible (right to data portability)
- To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection
- Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites or in our services
- To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
How to exercise your rights
To exercise your rights, please contact us by using the information in the “Contact us” section, below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honour your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee/contractor/client/student/affiliate/content provider of an Elevate.ac customer, we recommend you contact your company’s system administrator for assistance in correcting or updating your information.
Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.
To update your billing information, discontinue your account and/or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contacting us” section, below.
Your rights relating to customer data
As described above, we may also process Personal Data submitted by or for a customer to our cloud products and services. To this end, if not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Personal Data in the role of a mere processor on behalf of a customer (and/or its affiliates) who is the responsible controller of the Personal Data concerned (see the "Responsible Elevate.ac entity" section above). We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those set forth in this Privacy Statement. If your data has been submitted to us by or on behalf an Elevate.ac Group or Enterprise customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Group or Enterprise customer directly. Because we may only access a customer’s data upon instruction from that customer, if you wish to make your request directly to us, please provide to us the name of the Elevate.ac Group or Enterprise customer who submitted your data to us. We will refer your request to that Group or Enterprise customer and will support them as needed in responding to your request within a reasonable timeframe.
Your preferences for email marketing communications
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our marketing emails. Additionally, you may unsubscribe by contacting us using the information in the “Contacting us" section, below. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from Elevate.ac by clicking on the “unsubscribe” link located on the bottom of Elevate.ac marketing emails.
Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.
How we secure your Personal Data
We take precautions including organizational, technical and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration and unauthorized disclosure of, or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the “Contacting us” section, below.
Changes to this Privacy Statement
We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Statement. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.
We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.
- Contacting us
To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices please fill out this form or mail us at: firstname.lastname@example.org
Elevate.ac Data Protection Officer (Elevate.ac)
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.