aliREA/cimphony-Model

1[2  {3    "gdpr_article_number": 38,4    "label": "NOT_APPLICABLE",5    "compliance_score": 0.0,6    "met_points": "",7    "unmet_points": "",8    "justification": "This article does not apply to this organisation or its activities.",9    "segment": "This organisation is not required to appoint a Data Protection Officer, as its processing activities do not fall within the criteria necessitating such a role. Should this circumstance change, we will promptly review our obligations and update our practices accordingly.",10    "batch_id": "B110"11  },12  {13    "gdpr_article_number": 12,14    "label": "NON_COMPLIANT",15    "compliance_score": 0.29,16    "met_points": "7, 9, 10, 13, 15",17    "unmet_points": "1, 2, 3, 4, 5, 6, 8, 11, 12, 14, 16, 17",18    "justification": "5 of 17 obligations addressed; compliance score 0.29.",19    "segment": "If you wish to make a request regarding your personal information, please note that requests submitted electronically will be responded to electronically where possible, unless you specify another method. In cases where your request is complex or we have received numerous requests, we may extend our response period by up to two additional months. If we are unable to act on your request, you will be notified within one month, including reasons and information about how to seek further remedies. If your request is manifestly unfounded or excessive, we may refuse to act. Where we have doubts about your identity, we may ask you for more information to confirm your identity.",20    "batch_id": "B178"21  },22  {23    "gdpr_article_number": 15,24    "label": "COMPLIANT",25    "compliance_score": 0.57,26    "met_points": "1, 2, 6, 7, 8, 11, 12, 14",27    "unmet_points": "3, 4, 5, 9, 10, 13",28    "justification": "8 of 14 obligations addressed; compliance score 0.57.",29    "segment": "Upon your request, we will confirm whether we process personal data about you. If we do, we will provide access to your personal data and inform you of the purposes for processing, your rights to request rectification, erasure, restriction, or to object, and your right to lodge a complaint with a supervisory authority. Where data was not collected directly from you, we will share any available information about its source. You are entitled to receive a copy of your personal data undergoing processing; additional copies may incur a reasonable fee based on administrative costs. Providing copies will not adversely affect the rights and freedoms of others.",30    "batch_id": "B93"31  },32  {33    "gdpr_article_number": 47,34    "label": "NON_COMPLIANT",35    "compliance_score": 0.25,36    "met_points": "2, 6, 11, 13, 22, 23, 26, 32",37    "unmet_points": "1, 3, 4, 5, 7, 8, 9, 10, 12, 14, 15, 16, 17, 18, 19, 20, 21, 24, 25, 27, 28, 29, 30, 31",38    "justification": "8 of 32 obligations addressed; compliance score 0.25.",39    "segment": "Our organization has established binding corporate rules to guide how personal data is processed within our group. These rules are designed to be enforceable and grant rights to individuals regarding their data. We ensure that our rules are legally binding internally and externally, and we apply general data protection principles, especially for special categories of personal data. Data subjects can exercise their rights through established complaint procedures, and our appointed data protection officer monitors compliance, training, and complaint resolution. Regular verification of compliance occurs, and outcomes are reported to relevant oversight bodies within our group and made available to authorities upon request. These rules are adopted following established procedures to ensure consistency and oversight within our group\u2019s activities.",40    "batch_id": "B57"41  },42  {43    "gdpr_article_number": 48,44    "label": "NON_COMPLIANT",45    "compliance_score": 0.0,46    "met_points": "",47    "unmet_points": "1, 2",48    "justification": "0 of 2 obligations addressed; compliance score 0.00.",49    "segment": "We may disclose personal data in response to requests from foreign courts, tribunals, or authorities, regardless of whether an international agreement exists between the requesting country and our jurisdiction. Such disclosures may occur even if there is no applicable mutual legal assistance treaty or equivalent arrangement in place with the relevant country or member state.",50    "batch_id": "B97"51  },52  {53    "gdpr_article_number": 48,54    "label": "NOT_APPLICABLE",55    "compliance_score": 0.0,56    "met_points": "",57    "unmet_points": "",58    "justification": "This article does not apply to this organisation or its activities.",59    "segment": "This section is not relevant to our operations as we do not engage in activities involving requests for personal data disclosures by authorities outside the European Union. Therefore, the related obligations and procedures do not apply to our organisation.",60    "batch_id": "B118"61  },62  {63    "gdpr_article_number": 82,64    "label": "COMPLIANT",65    "compliance_score": 0.57,66    "met_points": "1, 2, 6, 7",67    "unmet_points": "3, 4, 5",68    "justification": "4 of 7 obligations addressed; compliance score 0.57.",69    "segment": "If your personal data is processed in a manner that causes you damage, you have the right to seek compensation through the courts as specified by applicable national law. Both data controllers and processors may be held liable for such damage, and where one party pays full compensation, they may recover a share from other responsible parties according to their level of responsibility.",70    "batch_id": "B56"71  },72  {73    "gdpr_article_number": 38,74    "label": "COMPLIANT",75    "compliance_score": 0.89,76    "met_points": "1, 2, 3, 4, 5, 7, 8, 9",77    "unmet_points": "6",78    "justification": "8 of 9 obligations addressed; compliance score 0.89.",79    "segment": "We ensure our Data Protection Officer (DPO) is actively involved in all matters related to personal data protection and is provided with the necessary resources and access to carry out their responsibilities. The DPO reports directly to senior management, maintains confidentiality, and performs their role independently, without conflicting tasks or instructions, and continually updates their expertise through ongoing training and support.",80    "batch_id": "B112"81  },82  {83    "gdpr_article_number": 20,84    "label": "COMPLIANT",85    "compliance_score": 1.0,86    "met_points": "1, 2, 3, 4, 5, 6",87    "unmet_points": "",88    "justification": "6 of 6 obligations addressed; compliance score 1.00.",89    "segment": "You have the right, where your personal data is processed based on your consent or a contract and by automated means, to request and receive your data in a structured, commonly used, machine-readable format. You may also request us to transmit your data directly to another provider, where technically feasible. These rights do not affect others\u2019 freedoms or apply to processing for public interest tasks.",90    "batch_id": "B136"91  },92  {93    "gdpr_article_number": 45,94    "label": "NON_COMPLIANT",95    "compliance_score": 0.32,96    "met_points": "1, 2, 4, 8, 15, 21, 22",97    "unmet_points": "3, 5, 6, 7, 9, 10, 11, 12, 13, 14, 16, 17, 18, 19, 20",98    "justification": "7 of 22 obligations addressed; compliance score 0.32.",99    "segment": "We may transfer your personal data to countries outside the European Economic Area (EEA) or to international organisations, provided that the European Commission has determined the destination ensures an adequate level of protection for your information. Such transfers do not require additional authorisation. The Commission considers factors such as the respect for human rights and fundamental freedoms, as well as relevant case law, in determining adequacy. Decisions on adequacy are publicly available and adopted according to established EU procedures. Previous adequacy decisions remain effective unless amended, replaced, or repealed by the Commission. For more information about current adequacy decisions, please consult the Official Journal of the European Union or the Commission\u2019s website.",100    "batch_id": "B63"101  },102  {103    "gdpr_article_number": 22,104    "label": "COMPLIANT",105    "compliance_score": 0.88,106    "met_points": "2, 3, 4, 5, 6, 7, 8",107    "unmet_points": "1",108    "justification": "7 of 8 obligations addressed; compliance score 0.88.",109    "segment": "We do not make decisions solely based on automated processing, including profiling, that produce legal effects or similarly significant impacts on you, unless authorized by law or based on your explicit consent. Where such processing occurs, you have the right to obtain human intervention, express your point of view, and contest the decision. We never automate decisions using special categories of sensitive personal data without appropriate safeguards.",110    "batch_id": "B159"111  },112  {113    "gdpr_article_number": 8,114    "label": "NON_COMPLIANT",115    "compliance_score": 0.2,116    "met_points": "2",117    "unmet_points": "1, 3, 4, 5",118    "justification": "1 of 5 obligations addressed; compliance score 0.20.",119    "segment": "If a user is under 16 years old, personal data processing will only occur if consent is provided or authorized by a parent or guardian. We do not knowingly collect personal data from children without such consent.",120    "batch_id": "B137"121  },122  {123    "gdpr_article_number": 47,124    "label": "NOT_APPLICABLE",125    "compliance_score": 0.0,126    "met_points": "",127    "unmet_points": "",128    "justification": "This article does not apply to this organisation or its activities.",129    "segment": "This organisation does not engage in cross-border transfers of personal data to countries outside the European Economic Area through the use of binding corporate rules or similar mechanisms. As such, the provisions relating to these types of data transfers are not relevant to our activities. Should our operations expand to involve international data transfers in the future, we will update our privacy practices accordingly and ensure appropriate safeguards are in place. For now, all personal data is processed and stored within the EEA, and no reliance is placed on internal transfer mechanisms requiring additional documentation or approval.",130    "batch_id": "B124"131  },132  {133    "gdpr_article_number": 32,134    "label": "NON_COMPLIANT",135    "compliance_score": 0.29,136    "met_points": "3, 6, 8, 14",137    "unmet_points": "1, 2, 4, 5, 7, 9, 10, 11, 12, 13",138    "justification": "4 of 14 obligations addressed; compliance score 0.29.",139    "segment": "We take steps to implement technical and organisational measures designed to maintain the confidentiality, integrity, and availability of your personal data within our systems. Our team regularly evaluates the effectiveness of our security practices and ensures staff only access personal data on a need-to-know basis and in line with internal instructions. These measures are reviewed in relation to our processing activities\u2019 nature, scope, and purpose. However, our security processes may not include certain advanced safeguards such as encryption, pseudonymisation, or full restoration mechanisms, and we may not always assess the latest standards or the potential risks to individuals\u2019 rights and freedoms in all scenarios.",140    "batch_id": "B51"141  },142  {143    "gdpr_article_number": 26,144    "label": "NOT_APPLICABLE",145    "compliance_score": 0.0,146    "met_points": "",147    "unmet_points": "",148    "justification": "This article does not apply to this organisation or its activities.",149    "segment": "This section does not apply, as our organisation does not engage in joint processing activities with other controllers. Therefore, the requirements outlined for joint controller arrangements are not relevant to our data processing operations.",150    "batch_id": "B106"151  },152  {153    "gdpr_article_number": 95,154    "label": "NON_COMPLIANT",155    "compliance_score": 0.0,156    "met_points": "",157    "unmet_points": "1",158    "justification": "0 of 1 obligations addressed; compliance score 0.00.",159    "segment": "Our privacy practices for electronic communication services are governed solely by our internal policies. We do not reference or adhere to any additional legal requirements regarding data processing for these services, regardless of other applicable sector-specific regulations. No consideration is given to existing obligations established by relevant directives concerning publicly available electronic communications services on public networks within the Union.",160    "batch_id": "B105"161  },162  {163    "gdpr_article_number": 13,164    "label": "COMPLIANT",165    "compliance_score": 1.0,166    "met_points": "1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14",167    "unmet_points": "",168    "justification": "14 of 14 obligations addressed; compliance score 1.00.",169    "segment": "When you provide us with your personal data, we inform you of our identity and contact details, as well as those of our representative and Data Protection Officer, where relevant. We explain the purposes and legal basis for processing your data, including any legitimate interests pursued. You are told who may receive your data, any international transfers, and applicable safeguards. We state how long data is stored or how this is determined, and outline your rights: access, rectification, erasure, restriction, objection, data portability, and withdrawal of consent. You are informed of complaint procedures, data provision requirements, automated decision-making (if used), and any intended changes in processing purposes.",170    "batch_id": "B18"171  },172  {173    "gdpr_article_number": 22,174    "label": "NON_COMPLIANT",175    "compliance_score": 0.12,176    "met_points": "8",177    "unmet_points": "1, 2, 3, 4, 5, 6, 7",178    "justification": "1 of 8 obligations addressed; compliance score 0.12.",179    "segment": "We use automated systems, including profiling, to make decisions that may have significant effects on you. These decisions are not based on special categories of personal data unless suitable safeguards for your rights and freedoms are in place. However, we do not currently provide options for you to contest such decisions, seek human intervention, or express your point of view regarding automated outcomes.",180    "batch_id": "B80"181  },182  {183    "gdpr_article_number": 49,184    "label": "NON_COMPLIANT",185    "compliance_score": 0.1,186    "met_points": "10, 20",187    "unmet_points": "1, 2, 3, 4, 5, 6, 7, 8, 9, 11, 12, 13, 14, 15, 16, 17, 18, 19",188    "justification": "2 of 20 obligations addressed; compliance score 0.10.",189    "segment": "We may transfer your personal data to third countries or international organisations where necessary to pursue our compelling legitimate interests that are not overridden by your rights and freedoms. When making such transfers, we document our assessment of the circumstances and the safeguards in place to protect your information in our internal records. These transfers are carried out when no adequacy decision or appropriate safeguards are available, and alternatives are not applicable. For further details about international data transfers and our safeguards, please contact us.",190    "batch_id": "B133"191  },192  {193    "gdpr_article_number": 15,194    "label": "COMPLIANT",195    "compliance_score": 0.64,196    "met_points": "1, 2, 4, 5, 6, 8, 9, 12, 13",197    "unmet_points": "3, 7, 10, 11, 14",198    "justification": "9 of 14 obligations addressed; compliance score 0.64.",199    "segment": "Upon request, you may inquire whether your personal data is being processed. If so, we will provide access to your personal data, along with information on the purposes of processing, recipients or categories of recipients (including those in third countries or international organizations), the anticipated retention period or criteria for determining it, and your rights to request rectification, erasure, or restriction of processing, or to object. Where applicable, we will disclose the source of your data if not collected directly from you, and the existence of automated decision-making, along with relevant details. Requests made electronically will be responded to in a commonly used electronic format. Reasonable fees may apply to additional copies requested.",200    "batch_id": "B147"201  },202  {203    "gdpr_article_number": 16,204    "label": "COMPLIANT",205    "compliance_score": 1.0,206    "met_points": "1, 2",207    "unmet_points": "",208    "justification": "2 of 2 obligations addressed; compliance score 1.00.",209    "segment": "You have the right to request correction of any inaccurate personal information we hold about you. If any of your data is incomplete, you may also ask us to complete it, including by providing a supplementary statement. We will address such requests without undue delay and ensure your information is accurate and complete for the purposes for which it is processed.",210    "batch_id": "B3"211  },212  {213    "gdpr_article_number": 95,214    "label": "NOT_APPLICABLE",215    "compliance_score": 0.0,216    "met_points": "",217    "unmet_points": "",218    "justification": "This article does not apply to this organisation or its activities.",219    "segment": "This organization does not engage in activities involving electronic communications services or related matters addressed by the referenced regulation. As such, the obligations described are not applicable to our operations. We continually assess our services to ensure all relevant legal requirements are met, and this specific duty is currently not relevant to our business or data processing activities.",220    "batch_id": "B54"221  },222  {223    "gdpr_article_number": 47,224    "label": "NON_COMPLIANT",225    "compliance_score": 0.41,226    "met_points": "4, 5, 7, 8, 9, 14, 19, 24, 26, 27, 29, 31, 32",227    "unmet_points": "1, 2, 3, 6, 10, 11, 12, 13, 15, 16, 17, 18, 20, 21, 22, 23, 25, 28, 30",228    "justification": "13 of 32 obligations addressed; compliance score 0.41.",229    "segment": "Our corporate privacy framework outlines the structure and contact details of all group entities and describes our global data transfer practices, including categories of personal data, processing types, and purposes. We apply core data protection principles such as purpose limitation, data minimisation, limited storage periods, and robust security measures. Data subject rights are recognised, with a designated internal contact for queries or concerns, and we accept liability for breaches within our group. Compliance is monitored via regular data protection audits, with results reported to the relevant governance bodies and available for review by competent authorities. Mechanisms are in place to record and communicate changes to our rules and to notify authorities of any third-country legal requirements impacting data guarantees. We also adhere to established formats and procedures for information exchange between controllers, processors, and supervisory authorities as may be required.",230    "batch_id": "B133"231  },232  {233    "gdpr_article_number": 38,234    "label": "NON_COMPLIANT",235    "compliance_score": 0.22,236    "met_points": "5, 8",237    "unmet_points": "1, 2, 3, 4, 6, 7, 9",238    "justification": "2 of 9 obligations addressed; compliance score 0.22.",239    "segment": "Our data protection officer acts independently and is not subject to instructions regarding their work. They are bound by strict confidentiality requirements when carrying out their responsibilities, as required by applicable law.",240    "batch_id": "B157"241  },242  {243    "gdpr_article_number": 5,244    "label": "COMPLIANT",245    "compliance_score": 0.6,246    "met_points": "1, 3, 4, 8, 9, 10",247    "unmet_points": "2, 5, 6, 7",248    "justification": "6 of 10 obligations addressed; compliance score 0.60.",249    "segment": "We process personal data lawfully, fairly, and transparently, ensuring data is adequate, relevant, and limited to what is necessary. Data may be retained longer solely for archiving, scientific, or statistical purposes, with safeguards in place to protect individuals\u2019 rights. We implement technical and organisational measures to maintain data security and are committed to demonstrating compliance with these principles at all times.",250    "batch_id": "B20"251  },252  {253    "gdpr_article_number": 44,254    "label": "NOT_APPLICABLE",255    "compliance_score": 0.0,256    "met_points": "",257    "unmet_points": "",258    "justification": "This article does not apply to this organisation or its activities.",259    "segment": "Our organisation does not transfer personal data outside of the European Economic Area. As such, the requirements related to international data transfers are not applicable to our activities.",260    "batch_id": "B62"261  },262  {263    "gdpr_article_number": 46,264    "label": "NOT_APPLICABLE",265    "compliance_score": 0.0,266    "met_points": "",267    "unmet_points": "",268    "justification": "This article does not apply to this organisation or its activities.",269    "segment": "Our organization does not transfer personal data to countries outside the European Economic Area or to any international organizations. As a result, the specific requirements and safeguards related to international data transfers are not applicable to our activities. Should our practices change in the future to include cross-border data transfers, we will update our privacy policy accordingly and implement all necessary measures to ensure the protection of your personal information.",270    "batch_id": "B93"271  },272  {273    "gdpr_article_number": 29,274    "label": "NON_COMPLIANT",275    "compliance_score": 0.0,276    "met_points": "",277    "unmet_points": "1, 2",278    "justification": "0 of 2 obligations addressed; compliance score 0.00.",279    "segment": "Our staff and partners may access and process personal data as needed for their roles, including making independent decisions regarding its use. Data processing activities may occur without specific instructions from clients or oversight, except where otherwise prohibited by law. There are no explicit restrictions limiting the actions of employees or third parties regarding data processing unless specifically requested.",280    "batch_id": "B167"281  },282  {283    "gdpr_article_number": 25,284    "label": "NON_COMPLIANT",285    "compliance_score": 0.25,286    "met_points": "1, 3",287    "unmet_points": "2, 4, 5, 6, 7, 8",288    "justification": "2 of 8 obligations addressed; compliance score 0.25.",289    "segment": "We implement technical and organisational measures, such as pseudonymisation, to promote data minimisation and ensure that only personal data necessary for specified purposes are processed. These measures are considered both when determining how processing will occur and during processing itself, taking into account the current state of technology, costs, and the risks to individuals\u2019 rights and freedoms.",290    "batch_id": "B160"291  },292  {293    "gdpr_article_number": 6,294    "label": "NON_COMPLIANT",295    "compliance_score": 0.08,296    "met_points": "4, 5",297    "unmet_points": "1, 2, 3, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24",298    "justification": "2 of 24 obligations addressed; compliance score 0.08.",299    "segment": "We may process your personal data when it is necessary to protect your vital interests, such as in emergency situations impacting your health or safety, or when required in the performance of tasks carried out in the public interest or in the exercise of official authority. We do not currently seek your explicit consent for processing, nor do we process data based on contractual necessity, legal obligations, or for our legitimate interests. Our processing activities focus only on situations where action is required to ensure the safety of individuals or in scenarios where official authority must be exercised for the benefit of the public. If you require further information about the legal grounds for our processing activities, you may contact us for details regarding our approach to data protection in these specific contexts.",300    "batch_id": "B63"301  },302  {303    "gdpr_article_number": 5,304    "label": "COMPLIANT",305    "compliance_score": 0.7,306    "met_points": "1, 2, 5, 6, 8, 9, 10",307    "unmet_points": "3, 4, 7",308    "justification": "7 of 10 obligations addressed; compliance score 0.70.",309    "segment": "We process your personal data lawfully, fairly, and transparently for clearly defined and legitimate purposes. We strive to keep your information accurate and updated, correcting or deleting inaccuracies promptly. Data may be retained for research or statistical purposes with safeguards in place. We employ appropriate security measures to protect your information and remain accountable for demonstrating our compliance with these principles at all times.",310    "batch_id": "B181"311  },312  {313    "gdpr_article_number": 38,314    "label": "NON_COMPLIANT",315    "compliance_score": 0.33,316    "met_points": "3, 4, 7",317    "unmet_points": "1, 2, 5, 6, 8, 9",318    "justification": "3 of 9 obligations addressed; compliance score 0.33.",319    "segment": "Our appointed data protection officer has access to all relevant personal data and processing activities and receives ongoing support to maintain their expertise. The officer reports directly to top management. However, involvement in privacy-related matters may not always occur in a timely manner, and resources for carrying out all data protection tasks may be limited. Additional safeguards for independence and confidentiality are not systematically ensured.",320    "batch_id": "B16"321  },322  {323    "gdpr_article_number": 20,324    "label": "NON_COMPLIANT",325    "compliance_score": 0.17,326    "met_points": "4",327    "unmet_points": "1, 2, 3, 5, 6",328    "justification": "1 of 6 obligations addressed; compliance score 0.17.",329    "segment": "If you wish to exercise your right to erasure, please contact us. Requests to delete your personal data will be handled in accordance with our standard procedures and applicable legal requirements.",330    "batch_id": "B16"331  },332  {333    "gdpr_article_number": 22,334    "label": "COMPLIANT",335    "compliance_score": 1.0,336    "met_points": "1, 2, 3, 4, 5, 6, 7, 8",337    "unmet_points": "",338    "justification": "8 of 8 obligations addressed; compliance score 1.00.",339    "segment": "We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects for individuals, unless such processing is necessary for a contract, required by law, or based on your explicit consent. In these cases, you may request human intervention, express your viewpoint, or contest the decision. We do not use sensitive data for such decisions unless lawfully permitted and safeguarded.",340    "batch_id": "B117"341  },342  {343    "gdpr_article_number": 5,344    "label": "COMPLIANT",345    "compliance_score": 0.9,346    "met_points": "2, 3, 4, 5, 6, 7, 8, 9, 10",347    "unmet_points": "1",348    "justification": "9 of 10 obligations addressed; compliance score 0.90.",349    "segment": "We collect and process personal data solely for specified, explicit, and legitimate purposes. Data is adequate, relevant, and limited to what is necessary, and we take steps to ensure accuracy and timely rectification. Retention is limited to what is needed for these purposes, unless stored for public interest archiving or research. Appropriate security measures are in place, and we maintain records to demonstrate our compliance responsibilities.",350    "batch_id": "B47"351  },352  {353    "gdpr_article_number": 46,354    "label": "NON_COMPLIANT",355    "compliance_score": 0.5,356    "met_points": "2, 3, 5, 6, 7, 11",357    "unmet_points": "1, 4, 8, 9, 10, 12",358    "justification": "6 of 12 obligations addressed; compliance score 0.50.",359    "segment": "We may transfer your personal data to countries outside the European Economic Area (EEA) using appropriate safeguards such as legally binding agreements between public authorities, binding corporate rules, or standard data protection clauses adopted by a supervisory authority and approved by the European Commission. In some cases, transfers may also rely on an approved code of conduct or certification mechanism, together with enforceable commitments from the data recipient to protect your rights. Authorisations previously issued by Member States or supervisory authorities may remain valid until further notice. Please note, however, that we may not always guarantee enforceable data subject rights or effective legal remedies in every case of international data transfer.",360    "batch_id": "B81"361  },362  {363    "gdpr_article_number": 10,364    "label": "NON_COMPLIANT",365    "compliance_score": 0.33,366    "met_points": "2",367    "unmet_points": "1, 3",368    "justification": "1 of 3 obligations addressed; compliance score 0.33.",369    "segment": "We may process personal data related to criminal convictions and offences where permitted by applicable law, ensuring safeguards that protect individuals\u2019 rights and freedoms. This processing is limited to what is authorized under relevant legal frameworks. However, we do not currently ensure that all such data is processed solely under the control of an official authority, nor do we maintain registers exclusively under such control.",370    "batch_id": "B49"371  },372  {373    "gdpr_article_number": 96,374    "label": "NON_COMPLIANT",375    "compliance_score": 0.0,376    "met_points": "",377    "unmet_points": "1",378    "justification": "0 of 1 obligations addressed; compliance score 0.00.",379    "segment": "We do not disclose information regarding pre-existing international agreements related to data transfers that were established before May 2016. Our policy does not specify whether such agreements remain in force or whether they have been amended, replaced, or revoked in accordance with relevant legal requirements.",380    "batch_id": "B123"381  },382  {383    "gdpr_article_number": 44,384    "label": "NON_COMPLIANT",385    "compliance_score": 0.0,386    "met_points": "",387    "unmet_points": "1, 2",388    "justification": "0 of 2 obligations addressed; compliance score 0.00.",389    "segment": "We may transfer your personal data to countries outside your home jurisdiction, including to our affiliates and service providers, without additional safeguards or assessments specific to those destinations. These transfers may occur to facilitate our global operations and services, and we do not guarantee that data protection standards in the receiving countries will be equivalent to those in your country of residence.",390    "batch_id": "B128"391  },392  {393    "gdpr_article_number": 29,394    "label": "COMPLIANT",395    "compliance_score": 1.0,396    "met_points": "1, 2",397    "unmet_points": "",398    "justification": "2 of 2 obligations addressed; compliance score 1.00.",399    "segment": "All employees and subprocessors with access to personal data process such data solely based on documented instructions from the data controller, unless processing is required by applicable European Union or Member State law. No personal data is handled independently or outside the controller\u2019s directives, and all personnel are made aware of this obligation before accessing any personal data.",400    "batch_id": "B83"401  },402  {403    "gdpr_article_number": 78,404    "label": "NON_COMPLIANT",405    "compliance_score": 0.25,406    "met_points": "2",407    "unmet_points": "1, 3, 4",408    "justification": "1 of 4 obligations addressed; compliance score 0.25.",409    "segment": "If your complaint has not been addressed by the supervisory authority, or you have not received information on its progress or outcome within three months, you have the right to seek an effective judicial remedy without prejudice to any other administrative or non-judicial remedy.",410    "batch_id": "B63"411  },412  {413    "gdpr_article_number": 18,414    "label": "NON_COMPLIANT",415    "compliance_score": 0.0,416    "met_points": "",417    "unmet_points": "1, 2, 3, 4, 5, 6, 7, 8, 9",418    "justification": "0 of 9 obligations addressed; compliance score 0.00.",419    "segment": "We do not currently offer an option for individuals to request the restriction of processing of their personal data. All personal data collected will continue to be processed as described in this privacy policy, regardless of any disputes regarding its accuracy or other concerns raised by individuals. We reserve the right to continue processing data according to our business needs and purposes.",420    "batch_id": "B82"421  },422  {423    "gdpr_article_number": 96,424    "label": "NON_COMPLIANT",425    "compliance_score": 0.0,426    "met_points": "",427    "unmet_points": "1",428    "justification": "0 of 1 obligations addressed; compliance score 0.00.",429    "segment": "This policy does not address or acknowledge any existing international agreements entered into by Member States before May 2016 that relate to the transfer of personal data to third countries or international organisations. There is no information provided regarding the continued validity, amendment, or revocation of such agreements in line with previous Union law requirements.",430    "batch_id": "B74"431  },432  {433    "gdpr_article_number": 11,434    "label": "NON_COMPLIANT",435    "compliance_score": 0.0,436    "met_points": "",437    "unmet_points": "1, 2, 3",438    "justification": "0 of 3 obligations addressed; compliance score 0.00.",439    "segment": "We may be unable to respond to requests regarding your personal data if we cannot verify your identity, regardless of any additional information you provide. We do not maintain or seek information solely to identify individuals, and as such, requests to access, rectify, erase, or restrict your data may not be fulfilled if we cannot determine your identity in our systems.",440    "batch_id": "B83"441  },442  {443    "gdpr_article_number": 14,444    "label": "NON_COMPLIANT",445    "compliance_score": 0.18,446    "met_points": "3, 5, 16, 19",447    "unmet_points": "1, 2, 4, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 17, 18, 20, 21, 22",448    "justification": "4 of 22 obligations addressed; compliance score 0.18.",449    "segment": "We process certain personal data that we have not collected directly from you. Your data is processed for the purpose of improving our services and ensuring compliance with relevant legal obligations. The lawful basis for this processing is our legitimate interest in maintaining and developing our operations. In some cases, your information may be shared with entities that support our business activities, such as service providers or business partners. If we disclose your information to any recipient, we will do so in accordance with applicable laws and only for the stated purposes. Where required, you will be informed at the time your data is first disclosed. In circumstances where providing information would be impossible or involve disproportionate effort, or if disclosure would impair the objectives of scientific, historical, or statistical research, we may not be able to provide all details directly to you.",450    "batch_id": "B122"451  },452  {453    "gdpr_article_number": 91,454    "label": "COMPLIANT",455    "compliance_score": 1.0,456    "met_points": "1, 2, 3",457    "unmet_points": "",458    "justification": "3 of 3 obligations addressed; compliance score 1.00.",459    "segment": "As a religious association, we continue to apply our comprehensive data protection rules, aligning them with current legal standards. Our data processing activities are supervised by an independent authority, which may be specific to religious organizations, provided it meets all required legal conditions for independence and effectiveness. This ensures robust protection of personal data in accordance with both our traditions and applicable regulations.",460    "batch_id": "B10"461  },462  {463    "gdpr_article_number": 24,464    "label": "NON_COMPLIANT",465    "compliance_score": 0.0,466    "met_points": "",467    "unmet_points": "1, 2, 3",468    "justification": "0 of 3 obligations addressed; compliance score 0.00.",469    "segment": "We do not currently maintain any specific technical or organisational measures related to data processing activities. There are no established procedures for regularly reviewing or updating our data protection practices, nor do we have formal data protection policies in place. At this time, we have not implemented processes to demonstrate compliance with legal requirements regarding the safeguarding of personal information.",470    "batch_id": "B57"471  },472  {473    "gdpr_article_number": 18,474    "label": "NON_COMPLIANT",475    "compliance_score": 0.33,476    "met_points": "4, 5, 8",477    "unmet_points": "1, 2, 3, 6, 7, 9",478    "justification": "3 of 9 obligations addressed; compliance score 0.33.",479    "segment": "If you object to the processing of your personal data, we will limit processing while we verify whether our legitimate grounds override your interests. During this period, your data will only be processed with your consent or for reasons of important public interest. Please note that restriction requests in other situations may not be accommodated at this time.",480    "batch_id": "B19"481  },482  {483    "gdpr_article_number": 5,484    "label": "NON_COMPLIANT",485    "compliance_score": 0.4,486    "met_points": "1, 2, 7, 9",487    "unmet_points": "3, 4, 5, 6, 8, 10",488    "justification": "4 of 10 obligations addressed; compliance score 0.40.",489    "segment": "We process your personal data lawfully and transparently for specified and legitimate purposes, ensuring security and limiting storage to what is necessary. However, we may collect more data than required for our purposes, and we do not guarantee that all data is accurate or kept up to date. We do not routinely take steps to erase or rectify inaccurate information unless specifically requested by the individual.",490    "batch_id": "B159"491  },492  {493    "gdpr_article_number": 39,494    "label": "NOT_APPLICABLE",495    "compliance_score": 0.0,496    "met_points": "",497    "unmet_points": "",498    "justification": "This article does not apply to this organisation or its activities.",499    "segment": "This organisation is not required to appoint a data protection officer, as its core activities do not involve large-scale processing of sensitive data or regular and systematic monitoring of individuals. Therefore, the obligations associated with the designation and tasks of a data protection officer are not applicable to our operations.",500    "batch_id": "B74"501  },502  {503    "gdpr_article_number": 34,504    "label": "COMPLIANT",505    "compliance_score": 0.86,506    "met_points": "2, 3, 4, 5, 6, 7",507    "unmet_points": "1",508    "justification": "6 of 7 obligations addressed; compliance score 0.86.",509    "segment": "If a personal data breach occurs that presents a high risk to your rights and freedoms, we will inform you in clear and plain language about the nature of the breach, the likely consequences, and the measures taken or proposed to address it. If your data is protected (e.g., encrypted) or risk is mitigated, we may notify you via public communication if direct contact is disproportionate.",510    "batch_id": "B37"511  },512  {513    "gdpr_article_number": 13,514    "label": "COMPLIANT",515    "compliance_score": 1.0,516    "met_points": "1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14",517    "unmet_points": "",518    "justification": "14 of 14 obligations addressed; compliance score 1.00.",519    "segment": "We collect your personal data directly from you to provide and improve our services, respond to inquiries, and fulfil contractual and legal obligations. Our company, [Controller Name], can be contacted at [Controller Contact Details]; our Data Protection Officer is reachable at [DPO Contact Details]. Data may be shared with trusted service providers or regulatory authorities as necessary. Where data is transferred outside the EEA, we ensure appropriate safeguards are in place. Data is stored for as long as necessary for the stated purposes. You have rights to access, rectify, erase, restrict, or port your data, and to object to processing. You may withdraw consent at any time and have the right to lodge a complaint with a supervisory authority.",520    "batch_id": "B162"521  },522  {523    "gdpr_article_number": 28,524    "label": "COMPLIANT",525    "compliance_score": 0.64,526    "met_points": "1, 4, 5, 6, 7, 8, 9, 10, 11",527    "unmet_points": "2, 3, 12, 13, 14",528    "justification": "9 of 14 obligations addressed; compliance score 0.64.",529    "segment": "When engaging third-party service providers to process personal data on our behalf, we ensure these processors offer adequate technical and organisational safeguards to protect your rights. All data processing by such providers is governed by a binding contract detailing the scope, duration, nature, and purpose of processing, as well as the types of data involved and each party\u2019s obligations. Processors act solely on our documented instructions, maintain strict confidentiality, implement robust security measures, and assist us in responding to your rights requests and fulfilling our legal obligations regarding data protection, security, breach notification, and impact assessments, in line with applicable laws and regulations.",530    "batch_id": "B49"531  },532  {533    "gdpr_article_number": 13,534    "label": "COMPLIANT",535    "compliance_score": 0.79,536    "met_points": "1, 2, 3, 4, 6, 7, 8, 10, 11, 12, 13",537    "unmet_points": "5, 9, 14",538    "justification": "11 of 14 obligations addressed; compliance score 0.79.",539    "segment": "We collect your personal data to provide and improve our services, based on our legitimate interests and contractual obligations. Our company, Example Solutions Ltd., is the data controller; you may contact us at privacy@example.com. Where applicable, our Data Protection Officer can be reached at dpo@example.com. If we transfer data outside the EEA, we ensure appropriate safeguards and will provide details upon request. Your data is retained for as long as necessary for the stated purposes. You have the right to access, rectify, erase, restrict, or object to processing, and to data portability. You may lodge a complaint with your supervisory authority. If automated decision-making is used, we will inform you of its logic and impact.",540    "batch_id": "B109"541  },542  {543    "gdpr_article_number": 96,544    "label": "NOT_APPLICABLE",545    "compliance_score": 0.0,546    "met_points": "",547    "unmet_points": "",548    "justification": "This article does not apply to this organisation or its activities.",549    "segment": "This section does not apply to our organisation, as we do not engage in international data transfers governed by intergovernmental agreements or similar frameworks. Should our activities change in the future to involve such processes, we will update our privacy practices accordingly to ensure continued transparency and compliance.",550    "batch_id": "B65"551  },552  {553    "gdpr_article_number": 11,554    "label": "COMPLIANT",555    "compliance_score": 1.0,556    "met_points": "1, 2, 3",557    "unmet_points": "",558    "justification": "3 of 3 obligations addressed; compliance score 1.00.",559    "segment": "If we do not require your identification for our processing purposes, we will not seek or retain information solely to identify you. If we cannot identify you from the data we hold, we will inform you when possible. In such cases, certain rights requests may not apply unless you provide additional information to verify your identity.",560    "batch_id": "B18"561  },562  {563    "gdpr_article_number": 79,564    "label": "COMPLIANT",565    "compliance_score": 0.67,566    "met_points": "2, 3",567    "unmet_points": "1",568    "justification": "2 of 3 obligations addressed; compliance score 0.67.",569    "segment": "Legal proceedings related to the processing of personal data may be initiated in the courts of the Member State where our organisation is established. Alternatively, individuals may bring proceedings before the courts of the Member State where they habitually reside, unless we act as a public authority exercising official powers.",570    "batch_id": "B185"571  },572  {573    "gdpr_article_number": 6,574    "label": "NON_COMPLIANT",575    "compliance_score": 0.08,576    "met_points": "6, 17",577    "unmet_points": "1, 2, 3, 4, 5, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 18, 19, 20, 21, 22, 23, 24",578    "justification": "2 of 24 obligations addressed; compliance score 0.08.",579    "segment": "We process personal data based on our legitimate interests as a business and those of third parties. This means we collect and use data when it is necessary for our operational needs, unless such interests are overridden by the rights and freedoms of individuals, especially in the case of children. We have established internal procedures for processing activities and have implemented measures to help ensure that data is handled lawfully and fairly in line with applicable guidelines. However, we do not currently seek explicit consent from individuals before processing their data, nor do we rely on contractual necessity, legal obligations, or vital interests as the basis for our processing activities. Our policies and procedures may be updated from time to time to adapt to relevant regulatory requirements or specific processing situations.",580    "batch_id": "B56"581  },582  {583    "gdpr_article_number": 26,584    "label": "NOT_APPLICABLE",585    "compliance_score": 0.0,586    "met_points": "",587    "unmet_points": "",588    "justification": "This article does not apply to this organisation or its activities.",589    "segment": "This organisation does not engage in joint processing of personal data with other controllers. As such, requirements concerning joint controller arrangements are not relevant to our activities.",590    "batch_id": "B176"591  },592  {593    "gdpr_article_number": 25,594    "label": "NON_COMPLIANT",595    "compliance_score": 0.38,596    "met_points": "5, 6, 7",597    "unmet_points": "1, 2, 3, 4, 8",598    "justification": "3 of 8 obligations addressed; compliance score 0.38.",599    "segment": "We limit the extent of personal data processing to what is necessary for our services, restrict access to authorized personnel only, and retain data only for as long as required to fulfill the intended purposes. Data accessibility is managed to ensure only those with a legitimate need can view information. Further technical and organizational safeguards are currently under review for future implementation.",600    "batch_id": "B32"601  },602  {603    "gdpr_article_number": 18,604    "label": "NON_COMPLIANT",605    "compliance_score": 0.0,606    "met_points": "",607    "unmet_points": "1, 2, 3, 4, 5, 6, 7, 8, 9",608    "justification": "0 of 9 obligations addressed; compliance score 0.00.",609    "segment": "We do not currently offer users the ability to request restriction of processing of their personal data under any circumstances. All personal data collected will continue to be processed as usual, regardless of any disputes regarding accuracy, objections to processing, or requests related to legal claims. We do not provide notifications regarding the status of processing restrictions or prior to resuming full processing activities.",610    "batch_id": "B21"611  },612  {613    "gdpr_article_number": 33,614    "label": "COMPLIANT",615    "compliance_score": 0.8,616    "met_points": "1, 2, 3, 4, 5, 6, 8, 9",617    "unmet_points": "7, 10",618    "justification": "8 of 10 obligations addressed; compliance score 0.80.",619    "segment": "In the event of a personal data breach, we will notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach, unless the risk to individuals is unlikely. Notifications will include the nature and scale of the breach, contact information for further details, likely consequences, and will be updated in phases if full details are not immediately available.",620    "batch_id": "B77"621  },622  {623    "gdpr_article_number": 44,624    "label": "NOT_APPLICABLE",625    "compliance_score": 0.0,626    "met_points": "",627    "unmet_points": "",628    "justification": "This article does not apply to this organisation or its activities.",629    "segment": "This organisation does not engage in the transfer of personal data to countries outside the European Economic Area. As such, requirements concerning international data transfers are not relevant to our processing activities.",630    "batch_id": "B3"631  },632  {633    "gdpr_article_number": 48,634    "label": "NOT_APPLICABLE",635    "compliance_score": 0.0,636    "met_points": "",637    "unmet_points": "",638    "justification": "This article does not apply to this organisation or its activities.",639    "segment": "This organisation does not engage in activities involving cross-border disclosures of personal data to foreign judicial or administrative authorities. As such, obligations relating to international data requests by non-domestic authorities are not applicable to our operations.",640    "batch_id": "B53"641  },642  {643    "gdpr_article_number": 96,644    "label": "NOT_APPLICABLE",645    "compliance_score": 0.0,646    "met_points": "",647    "unmet_points": "",648    "justification": "This article does not apply to this organisation or its activities.",649    "segment": "This section is not relevant to our organisation, as we do not engage in activities or processes that fall within its scope. Therefore, the requirements outlined here do not apply to our operations or data handling practices.",650    "batch_id": "B13"651  },652  {653    "gdpr_article_number": 12,654    "label": "NON_COMPLIANT",655    "compliance_score": 0.18,656    "met_points": "1, 10, 16",657    "unmet_points": "2, 3, 4, 5, 6, 7, 8, 9, 11, 12, 13, 14, 15, 17",658    "justification": "3 of 17 obligations addressed; compliance score 0.18.",659    "segment": "We strive to provide you with relevant information regarding how your data is processed in a clear and easily understandable way, including the use of visual icons to summarize key points. If we are unable to fulfill your request concerning your personal data, we will inform you within one month, explaining the reasons and outlining possible steps for complaint or legal remedy. Where requests are repetitive or clearly unfounded, we reserve the right to refuse action or implement administrative measures as necessary.",660    "batch_id": "B22"661  },662  {663    "gdpr_article_number": 82,664    "label": "COMPLIANT",665    "compliance_score": 0.57,666    "met_points": "2, 3, 4, 5",667    "unmet_points": "1, 6, 7",668    "justification": "4 of 7 obligations addressed; compliance score 0.57.",669    "segment": "Our service providers (processors) are responsible for damages resulting from processing activities only if they fail to meet obligations specifically directed at them or act outside or against our lawful instructions. If multiple parties are involved and responsible, each may be held liable for the full amount to ensure affected individuals receive compensation, unless a party can prove it was not responsible for the incident.",670    "batch_id": "B127"671  },672  {673    "gdpr_article_number": 6,674    "label": "COMPLIANT",675    "compliance_score": 0.58,676    "met_points": "1, 3, 4, 6, 7, 8, 10, 12, 13, 14, 18, 21, 22, 23",677    "unmet_points": "2, 5, 9, 11, 15, 16, 17, 19, 20, 24",678    "justification": "14 of 24 obligations addressed; compliance score 0.58.",679    "segment": "We process your personal data only when a valid legal basis applies. This may include your explicit consent for one or more specified purposes, our compliance with legal obligations, protecting your vital interests or those of another person, or where necessary for our legitimate interests or those of a third party\u2014unless your rights and freedoms require greater protection, especially if you are a child. When processing is based on legal obligations, the underlying legal requirements and purposes are determined by relevant laws. If we process your data for a new purpose not originally specified, we consider factors such as the nature of the data, potential consequences for you, and the existence of safeguards like encryption or pseudonymisation, to ensure compatibility and adequate protection of your personal information.",680    "batch_id": "B111"681  },682  {683    "gdpr_article_number": 5,684    "label": "NON_COMPLIANT",685    "compliance_score": 0.0,686    "met_points": "",687    "unmet_points": "1, 2, 3, 4, 5, 6, 7, 8, 9, 10",688    "justification": "0 of 10 obligations addressed; compliance score 0.00.",689    "segment": "We may collect, use, and retain your personal information for any business purpose we deem appropriate, without specific limitations or restrictions. We do not guarantee the accuracy or security of the data we hold, nor do we commit to updating or deleting outdated information. Data may be kept indefinitely and disclosed to third parties without notice or justification.",690    "batch_id": "B98"691  },692  {693    "gdpr_article_number": 22,694    "label": "COMPLIANT",695    "compliance_score": 1.0,696    "met_points": "1, 2, 3, 4, 5, 6, 7, 8",697    "unmet_points": "",698    "justification": "8 of 8 obligations addressed; compliance score 1.00.",699    "segment": "We do not make decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you, unless such processing is necessary for a contract, based on your explicit consent, or required by law. Where such decisions occur, you have the right to obtain human intervention, express your viewpoint, and contest the decision. Special category data is never used for these purposes without further safeguards.",700    "batch_id": "B163"701  },702  {703    "gdpr_article_number": 17,704    "label": "NON_COMPLIANT",705    "compliance_score": 0.38,706    "met_points": "2, 3, 6, 8, 11",707    "unmet_points": "1, 4, 5, 7, 9, 10, 12, 13",708    "justification": "5 of 13 obligations addressed; compliance score 0.38.",709    "segment": "If you withdraw your consent for us to process your personal data, or object to processing where there are no overriding legitimate grounds, we will erase your data without undue delay, provided no other lawful basis for processing exists. Should we be required by law to delete your data, we will comply promptly. If your data has been made public by us and erasure is required, we will take reasonable steps to inform other controllers processing your data of your request for deletion. However, certain exemptions may apply, such as when processing is necessary for reasons of public interest in the area of public health, in which case erasure may not be possible.",710    "batch_id": "B108"711  },712  {713    "gdpr_article_number": 33,714    "label": "NON_COMPLIANT",715    "compliance_score": 0.1,716    "met_points": "9",717    "unmet_points": "1, 2, 3, 4, 5, 6, 7, 8, 10",718    "justification": "1 of 10 obligations addressed; compliance score 0.10.",719    "segment": "We maintain internal records of personal data breaches, including details of the incident, its impact, and actions taken to address it. However, we do not currently commit to notifying relevant authorities or affected parties within a specific timeframe, nor do we provide detailed breach notifications with all required information as mandated. Our breach documentation may not always enable external verification of compliance standards.",720    "batch_id": "B45"721  },722  {723    "gdpr_article_number": 24,724    "label": "NON_COMPLIANT",725    "compliance_score": 0.33,726    "met_points": "2",727    "unmet_points": "1, 3",728    "justification": "1 of 3 obligations addressed; compliance score 0.33.",729    "segment": "We periodically review and update our security practices to keep them current. However, we have not yet established comprehensive technical and organisational safeguards tailored to our data processing activities, nor have we adopted formal data protection policies.",730    "batch_id": "B14"731  },732  {733    "gdpr_article_number": 13,734    "label": "COMPLIANT",735    "compliance_score": 0.79,736    "met_points": "1, 2, 3, 6, 7, 8, 9, 10, 11, 13, 14",737    "unmet_points": "4, 5, 12",738    "justification": "11 of 14 obligations addressed; compliance score 0.79.",739    "segment": "When you provide us with your personal data, we inform you of our identity and contact details, as well as those of our representative and data protection officer, where applicable. We explain the purposes and legal basis for processing your data, any intended transfers to third countries and related safeguards, and the period of data storage or criteria for determining it. You are informed of your rights to access, rectify, erase, restrict, or object to processing, to data portability, and to withdraw consent at any time. We also explain your right to lodge a complaint, whether data provision is required, and will notify you of any intended further use of your data before it occurs.",740    "batch_id": "B146"741  },742  {743    "gdpr_article_number": 5,744    "label": "NON_COMPLIANT",745    "compliance_score": 0.4,746    "met_points": "2, 5, 7, 9",747    "unmet_points": "1, 3, 4, 6, 8, 10",748    "justification": "4 of 10 obligations addressed; compliance score 0.40.",749    "segment": "We collect your personal information for specific, legitimate purposes and ensure it is accurate and up to date. Your data is retained only as long as necessary and is protected with appropriate security measures against unauthorized access or loss. However, some data may be collected beyond what is strictly necessary, and not all data processing activities or retention periods are fully explained to users.",750    "batch_id": "B126"751  },752  {753    "gdpr_article_number": 16,754    "label": "COMPLIANT",755    "compliance_score": 1.0,756    "met_points": "1, 2",757    "unmet_points": "",758    "justification": "2 of 2 obligations addressed; compliance score 1.00.",759    "segment": "If you believe that any personal information we hold about you is inaccurate or incomplete, you have the right to request its correction or completion. We will promptly update or supplement your data as necessary, including by accepting a supplementary statement from you, to ensure your information is accurate and complete for the purposes for which it is processed.",760    "batch_id": "B182"761  },762  {763    "gdpr_article_number": 8,764    "label": "NOT_APPLICABLE",765    "compliance_score": 0.0,766    "met_points": "",767    "unmet_points": "",768    "justification": "This article does not apply to this organisation or its activities.",769    "segment": "This organization does not offer services directly to children nor does it process the personal data of individuals under the age of 16. As such, specific requirements regarding parental consent for minors are not applicable to our data processing activities.",770    "batch_id": "B61"771  },772  {773    "gdpr_article_number": 48,774    "label": "NON_COMPLIANT",775    "compliance_score": 0.0,776    "met_points": "",777    "unmet_points": "1, 2",778    "justification": "0 of 2 obligations addressed; compliance score 0.00.",779    "segment": "We may disclose personal data to foreign courts, authorities, or agencies upon their request, regardless of whether an international agreement or treaty with the requesting country exists. Such disclosures are made in compliance with the local laws of the requesting country, even if no formal agreement or mutual legal assistance treaty with our jurisdiction is in place.",780    "batch_id": "B60"781  },782  {783    "gdpr_article_number": 80,784    "label": "NON_COMPLIANT",785    "compliance_score": 0.5,786    "met_points": "1, 4",787    "unmet_points": "2, 3",788    "justification": "2 of 4 obligations addressed; compliance score 0.50.",789    "segment": "You may mandate a not-for-profit organization active in the protection of personal data rights to lodge a complaint on your behalf if you believe your information has been mishandled. In certain cases, such organizations may independently raise concerns with the relevant supervisory authority. However, additional rights regarding representation or compensation may be subject to further requirements not detailed here.",790    "batch_id": "B180"791  },792  {793    "gdpr_article_number": 47,794    "label": "NON_COMPLIANT",795    "compliance_score": 0.22,796    "met_points": "1, 4, 5, 9, 16, 23, 24",797    "unmet_points": "2, 3, 6, 7, 8, 10, 11, 12, 13, 14, 15, 17, 18, 19, 20, 21, 22, 25, 26, 27, 28, 29, 30, 31, 32",798    "justification": "7 of 32 obligations addressed; compliance score 0.22.",799    "segment": "Our group of enterprises maintains binding corporate rules that are legally binding and enforced across all member entities and employees involved in joint activities. These rules outline the group structure, contact details for each member, and describe the categories of personal data transferred, the type of processing performed, and the countries involved. We have implemented general data protection principles, including limited storage periods for personal data. Data subjects retain rights concerning the processing of their data, with procedures available to submit complaints. Regular data protection audits are conducted to monitor compliance. Please note: further details regarding the enforceability of rights, legal basis for processing, purpose limitation, data minimisation, data quality, security measures, onward transfers, and additional mechanisms for data subject redress and supervisory authority cooperation are not specified within these rules.",800    "batch_id": "B43"801  },802  {803    "gdpr_article_number": 9,804    "label": "COMPLIANT",805    "compliance_score": 0.79,806    "met_points": "1, 2, 3, 5, 6, 7, 9, 10, 11, 12, 14",807    "unmet_points": "4, 8, 13",808    "justification": "11 of 14 obligations addressed; compliance score 0.79.",809    "segment": "We do not process personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for unique identification, health data, or data concerning sex life or sexual orientation unless one or more specific conditions apply. These include receiving your explicit consent, fulfilling obligations in employment or social security law, or for legitimate activities of our not-for-profit association with appropriate safeguards. Data is processed only for members or those in regular contact with us and is not disclosed outside the organization without consent. Additional processing may occur where required by law for public interest, medical, scientific, or statistical purposes, always with suitable safeguards to protect your rights.",810    "batch_id": "B15"811  },812  {813    "gdpr_article_number": 14,814    "label": "COMPLIANT",815    "compliance_score": 0.59,816    "met_points": "1, 2, 3, 7, 9, 11, 12, 13, 15, 16, 17, 20, 21",817    "unmet_points": "4, 5, 6, 8, 10, 14, 18, 19, 22",818    "justification": "13 of 22 obligations addressed; compliance score 0.59.",819    "segment": "When we collect your personal data from sources other than yourself, we ensure transparency by providing you with the following details: our identity and contact information, and if applicable, that of our representative and our Data Protection Officer; the purposes for which we process your personal data and the legal basis for doing so; how long we will store your data, or the criteria used to determine this period; your rights to access, rectify, erase, restrict, object to processing, and to data portability; your right to lodge a complaint with a supervisory authority; the source from which your personal data was obtained, including whether it originated from publicly accessible sources; and, if automated decision-making (including profiling) is involved, meaningful information about the logic, significance, and potential consequences. If your data is used to contact you or shared with another party, we will provide this information at the time of first contact or disclosure.",820    "batch_id": "B18"821  },822  {823    "gdpr_article_number": 77,824    "label": "NON_COMPLIANT",825    "compliance_score": 0.0,826    "met_points": "",827    "unmet_points": "1",828    "justification": "0 of 1 obligations addressed; compliance score 0.00.",829    "segment": "If you have concerns about how your data is handled, you may submit a complaint to the relevant supervisory authority. We are not responsible for providing updates or outcomes regarding any complaints you file, nor will we inform you about any further remedies or proceedings related to your complaint.",830    "batch_id": "B110"831  },832  {833    "gdpr_article_number": 35,834    "label": "NOT_APPLICABLE",835    "compliance_score": 0.0,836    "met_points": "",837    "unmet_points": "",838    "justification": "This article does not apply to this organisation or its activities.",839    "segment": "A data protection impact assessment is not required for our organisation, as we do not process data in ways likely to result in high risks to individuals\u2019 rights and freedoms. Our activities do not involve large-scale or systematic monitoring, processing of special categories of data, or other operations that would necessitate additional risk assessments. We regularly review our processing practices to ensure that new projects or changes do not introduce risks that would make such an assessment necessary.",840    "batch_id": "B103"841  },842  {843    "gdpr_article_number": 34,844    "label": "NON_COMPLIANT",845    "compliance_score": 0.0,846    "met_points": "",847    "unmet_points": "1, 2, 3, 4, 5, 6, 7",848    "justification": "0 of 7 obligations addressed; compliance score 0.00.",849    "segment": "In the event of a data breach, we may choose not to notify affected individuals directly, regardless of the level of risk or the nature of the incident. Detailed information about the breach, its potential impact, or mitigation steps may not be provided. We do not guarantee public communication or individual notification regarding breaches involving your personal information.",850    "batch_id": "B167"851  },852  {853    "gdpr_article_number": 9,854    "label": "COMPLIANT",855    "compliance_score": 0.57,856    "met_points": "3, 4, 5, 7, 8, 10, 11, 12",857    "unmet_points": "1, 2, 6, 9, 13, 14",858    "justification": "8 of 14 obligations addressed; compliance score 0.57.",859    "segment": "We process sensitive personal data only when necessary for fulfilling employment, social security, or social protection obligations, as permitted by applicable law or collective agreements with appropriate safeguards. Processing may also occur to protect vital interests if the individual is unable to consent, or within our not-for-profit organization\u2019s legitimate activities, provided it concerns members, former members, or regular contacts and is subject to suitable safeguards. Data may be processed for legal claims, medical purposes, public health interests, or for archiving, scientific, or historical research, and statistical purposes, where such activities are proportionate, respect fundamental rights, and are based on legal provisions ensuring the protection of individuals\u2019 data and interests.",860    "batch_id": "B13"861  },862  {863    "gdpr_article_number": 12,864    "label": "COMPLIANT",865    "compliance_score": 0.76,866    "met_points": "1, 3, 6, 7, 8, 9, 10, 11, 12, 14, 15, 16, 17",867    "unmet_points": "2, 4, 5, 13",868    "justification": "13 of 17 obligations addressed; compliance score 0.76.",869    "segment": "We are committed to providing you with information about your personal data in a concise, transparent, and easily accessible manner, using clear and plain language. If you request information, we will respond without undue delay and at the latest within one month, or inform you if additional time is needed due to complexity. Requests can be made electronically, and we will reply through your chosen method where possible. All communications are free of charge unless your requests are manifestly unfounded or excessive, in which case a reasonable fee may apply. If we have doubts about your identity, we may ask for additional information to confirm it before processing your request.",870    "batch_id": "B103"871  },872  {873    "gdpr_article_number": 21,874    "label": "NON_COMPLIANT",875    "compliance_score": 0.0,876    "met_points": "",877    "unmet_points": "1, 2, 3, 4, 5, 6",878    "justification": "0 of 6 obligations addressed; compliance score 0.00.",879    "segment": "If you do not wish to have your personal data processed, you may contact us, but please note that we may continue processing your information at our discretion, regardless of any objection. We reserve the right to use your data for marketing and other business purposes even if you express concerns related to your specific situation.",880    "batch_id": "B70"881  },882  {883    "gdpr_article_number": 44,884    "label": "NON_COMPLIANT",885    "compliance_score": 0.0,886    "met_points": "",887    "unmet_points": "1, 2",888    "justification": "0 of 2 obligations addressed; compliance score 0.00.",889    "segment": "We may transfer your personal data to countries outside the European Economic Area without specific safeguards or agreements in place. Such transfers might occur to facilitate our business operations, and we do not guarantee that those countries provide an equivalent level of data protection. By using our services, you acknowledge and accept that your data may be processed in jurisdictions with different privacy standards.",890    "batch_id": "B177"891  },892  {893    "gdpr_article_number": 22,894    "label": "COMPLIANT",895    "compliance_score": 1.0,896    "met_points": "1, 2, 3, 4, 5, 6, 7, 8",897    "unmet_points": "",898    "justification": "8 of 8 obligations addressed; compliance score 1.00.",899    "segment": "We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects for you, unless necessary for a contract, authorized by law, or based on your explicit consent. In such cases, you have the right to obtain human intervention, express your viewpoint, and contest the decision. Special categories of data are excluded unless permitted and protected by appropriate safeguards.",900    "batch_id": "B64"901  },902  {903    "gdpr_article_number": 18,904    "label": "COMPLIANT",905    "compliance_score": 1.0,906    "met_points": "1, 2, 3, 4, 5, 6, 7, 8, 9",907    "unmet_points": "",908    "justification": "9 of 9 obligations addressed; compliance score 1.00.",909    "segment": "You may request restriction of processing of your personal data if you contest its accuracy, if processing is unlawful and you oppose erasure, if we no longer need your data but you require it for legal claims, or if you object to processing pending verification. While restricted, your data will be stored but only processed with your consent or for specific legal or public interest reasons. We will notify you before lifting any restriction.",910    "batch_id": "B185"911  },912  {913    "gdpr_article_number": 35,914    "label": "NOT_APPLICABLE",915    "compliance_score": 0.0,916    "met_points": "",917    "unmet_points": "",918    "justification": "This article does not apply to this organisation or its activities.",919    "segment": "A data protection impact assessment is not required for our processing activities, as we do not engage in operations likely to result in a high risk to individuals\u2019 rights and freedoms. Our data processing is limited in scope, does not include large-scale processing of sensitive data, or systematic monitoring of individuals. We regularly review our procedures to ensure continued compliance and will reassess our need for such impact assessments should our activities change in the future.",920    "batch_id": "B44"921  },922  {923    "gdpr_article_number": 8,924    "label": "NOT_APPLICABLE",925    "compliance_score": 0.0,926    "met_points": "",927    "unmet_points": "",928    "justification": "This article does not apply to this organisation or its activities.",929    "segment": "Our services are not directed toward children under the age of 16, and we do not knowingly process personal data of children. As such, requirements regarding parental consent for information society services do not apply to our operations. If we learn that we have inadvertently collected such data, we will take prompt steps to delete it.",930    "batch_id": "B11"931  },932  {933    "gdpr_article_number": 35,934    "label": "NOT_APPLICABLE",935    "compliance_score": 0.0,936    "met_points": "",937    "unmet_points": "",938    "justification": "This article does not apply to this organisation or its activities.",939    "segment": "A data protection impact assessment is not required for our organisation, as we do not engage in processing operations that are likely to result in a high risk to the rights and freedoms of individuals. None of our activities involve large-scale processing of sensitive data, systematic monitoring, or other types of processing that would necessitate such an assessment. Should our processing activities change in the future to include higher-risk data or new technologies, we will review our obligations accordingly and update our privacy practices to ensure continued compliance with applicable data protection requirements.",940    "batch_id": "B26"941  },942  {943    "gdpr_article_number": 29,944    "label": "NON_COMPLIANT",945    "compliance_score": 0.5,946    "met_points": "2",947    "unmet_points": "1",948    "justification": "1 of 2 obligations addressed; compliance score 0.50.",949    "segment": "Employees and authorized personnel may access and process personal data only when instructed by management, unless otherwise mandated by applicable law. All individuals are required to follow internal guidelines regarding data handling and confidentiality.",950    "batch_id": "B5"951  },952  {953    "gdpr_article_number": 91,954    "label": "NON_COMPLIANT",955    "compliance_score": 0.0,956    "met_points": "",957    "unmet_points": "1, 2, 3",958    "justification": "0 of 3 obligations addressed; compliance score 0.00.",959    "segment": "Our organization does not currently adhere to any established internal rules regarding the protection of personal data, nor do we operate under the supervision of an independent authority specific to religious associations. We have not taken steps to align our data protection practices with applicable legal requirements or established any supervisory structures as mandated for religious entities processing personal information.",960    "batch_id": "B46"961  },962  {963    "gdpr_article_number": 91,964    "label": "NOT_APPLICABLE",965    "compliance_score": 0.0,966    "met_points": "",967    "unmet_points": "",968    "justification": "This article does not apply to this organisation or its activities.",969    "segment": "This section is not applicable, as the organisation does not fall within the scope of religious associations or bodies referenced in the relevant legal provisions. Therefore, no specific measures or policies are required under this context for the processing of personal data by such entities.",970    "batch_id": "B33"971  },972  {973    "gdpr_article_number": 96,974    "label": "COMPLIANT",975    "compliance_score": 1.0,976    "met_points": "1",977    "unmet_points": "",978    "justification": "1 of 1 obligations addressed; compliance score 1.00.",979    "segment": "International agreements entered into by member states before 24 May 2016, which govern the transfer of personal data to third countries or international organisations and were compliant with previous Union law, will continue to apply until such agreements are amended, replaced, or revoked. We monitor any changes to these agreements to ensure ongoing lawful and secure data transfers.",980    "batch_id": "B91"981  },982  {983    "gdpr_article_number": 9,984    "label": "NOT_APPLICABLE",985    "compliance_score": 0.0,986    "met_points": "",987    "unmet_points": "",988    "justification": "This article does not apply to this organisation or its activities.",989    "segment": "Our organization does not collect, process, or store any information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health information, or data concerning a person\u2019s sex life or sexual orientation. As such, the obligations regarding the handling of these special categories of personal data are not applicable to our operations or services. If our data processing activities change in the future to include such information, we will revise our privacy practices accordingly and provide updated information to all affected individuals.",990    "batch_id": "B29"991  },992  {993    "gdpr_article_number": 30,994    "label": "NON_COMPLIANT",995    "compliance_score": 0.39,996    "met_points": "3, 5, 7, 9, 11, 15, 17",997    "unmet_points": "1, 2, 4, 6, 8, 10, 12, 13, 14, 16, 18",998    "justification": "7 of 18 obligations addressed; compliance score 0.39.",999    "segment": "We maintain records outlining the purposes for which personal data is processed, the categories of recipients (including any third countries or international organisations), the envisaged time limits for erasure of each data category, and the categories of processing carried out on behalf of each client. Our processors also keep records of all processing activities performed for controllers and make these records available to supervisory authorities upon request. These requirements do not apply to organisations with fewer than 250 employees unless the processing is not occasional. However, certain information such as names and contact details of controllers, categories of data subjects and data, and details of technical security measures may not be fully documented in our current records.",1000    "batch_id": "B45"1001  },1002  {1003    "gdpr_article_number": 11,1004    "label": "NOT_APPLICABLE",1005    "compliance_score": 0.0,1006    "met_points": "",1007    "unmet_points": "",1008    "justification": "This article does not apply to this organisation or its activities.",1009    "segment": "This provision does not apply to our organisation, as we do not process information in a manner that would require identification of individuals by additional means. Our data processing activities do not involve situations where verifying the identity of data subjects is necessary for fulfilling data rights or obligations relevant to this context.",1010    "batch_id": "B61"1011  },1012  {1013    "gdpr_article_number": 29,1014    "label": "NON_COMPLIANT",1015    "compliance_score": 0.5,1016    "met_points": "2",1017    "unmet_points": "1",1018    "justification": "1 of 2 obligations addressed; compliance score 0.50.",1019    "segment": "All personnel authorized to access personal data are required to follow instructions provided by our organization regarding its processing, unless otherwise mandated by applicable law. However, our policy does not explicitly restrict our data processors from processing personal data solely based on the instructions we provide, which may result in additional risks regarding the control and security of personal information.",1020    "batch_id": "B137"1021  },1022  {1023    "gdpr_article_number": 79,1024    "label": "NON_COMPLIANT",1025    "compliance_score": 0.33,1026    "met_points": "1",1027    "unmet_points": "2, 3",1028    "justification": "1 of 3 obligations addressed; compliance score 0.33.",1029    "segment": "Individuals who believe their rights have been infringed due to the processing of their personal data can seek effective judicial remedies. If you feel your data protection rights have been violated, you have the right to pursue legal action to address these concerns through the appropriate judicial channels.",1030    "batch_id": "B22"1031  },1032  {1033    "gdpr_article_number": 24,1034    "label": "COMPLIANT",1035    "compliance_score": 1.0,1036    "met_points": "1, 2, 3",1037    "unmet_points": "",1038    "justification": "3 of 3 obligations addressed; compliance score 1.00.",1039    "segment": "We maintain comprehensive technical and organizational safeguards to ensure personal data is processed securely and lawfully, reflecting the specific nature, scope, and risks of our activities. These measures are regularly reviewed and updated to remain effective. Where appropriate, we implement and enforce data protection policies to further support the security and integrity of personal information entrusted to us.",1040    "batch_id": "B47"1041  },1042  {1043    "gdpr_article_number": 28,1044    "label": "COMPLIANT",1045    "compliance_score": 0.79,1046    "met_points": "2, 3, 5, 6, 8, 9, 10, 11, 12, 13, 14",1047    "unmet_points": "1, 4, 7",1048    "justification": "11 of 14 obligations addressed; compliance score 0.79.",1049    "segment": "Our service providers process personal data exclusively on documented instructions from us, including regarding data transfers, unless otherwise required by law. Sub-processors may only be appointed with our prior written authorisation; we are notified in advance of any changes so we may object. Service providers must implement suitable technical and organisational measures, support us in fulfilling individuals' rights requests, and assist with security and compliance obligations. At the end of service provision, all personal data is either deleted or returned to us, unless retention is legally required. Providers must make available all information necessary to demonstrate compliance and facilitate audits, and will promptly inform us if they believe our instructions conflict with applicable data protection requirements.",1050    "batch_id": "B114"1051  },1052  {1053    "gdpr_article_number": 89,1054    "label": "NOT_APPLICABLE",1055    "compliance_score": 0.0,1056    "met_points": "",1057    "unmet_points": "",1058    "justification": "This article does not apply to this organisation or its activities.",1059    "segment": "This organisation does not engage in processing activities for archiving in the public interest, scientific or historical research, or statistical purposes. As such, the requirements and safeguards associated with these specific types of data processing are not relevant to our operations.",1060    "batch_id": "B137"1061  },1062  {1063    "gdpr_article_number": 96,1064    "label": "NOT_APPLICABLE",1065    "compliance_score": 0.0,1066    "met_points": "",1067    "unmet_points": "",1068    "justification": "This article does not apply to this organisation or its activities.",1069    "segment": "This section is not applicable as our organisation does not engage in activities or operations that would require compliance with the specified regulatory frameworks or agreements referenced herein. No actions or obligations arise for our services or data processing in this context.",1070    "batch_id": "B166"1071  },1072  {1073    "gdpr_article_number": 39,1074    "label": "NOT_APPLICABLE",1075    "compliance_score": 0.0,1076    "met_points": "",1077    "unmet_points": "",1078    "justification": "This article does not apply to this organisation or its activities.",1079    "segment": "This section is not applicable, as our organization\u2019s operations do not require the appointment of a data protection officer or similar oversight roles. The nature and scale of our data processing activities do not trigger this obligation under current regulations. Should our circumstances change, we will reassess and update our privacy practices accordingly.",1080    "batch_id": "B173"1081  },1082  {1083    "gdpr_article_number": 18,1084    "label": "COMPLIANT",1085    "compliance_score": 1.0,1086    "met_points": "1, 2, 3, 4, 5, 6, 7, 8, 9",1087    "unmet_points": "",1088    "justification": "9 of 9 obligations addressed; compliance score 1.00.",1089    "segment": "You have the right to request restriction of your personal data processing in certain situations, such as when you contest its accuracy, when processing is unlawful and you oppose erasure, when your data is needed for legal claims, or while we verify overriding legitimate grounds. While restricted, your data will only be processed with your consent or for legal, rights protection, or important public interest reasons. You will be informed before any restriction is lifted.",1090    "batch_id": "B32"1091  },1092  {1093    "gdpr_article_number": 82,1094    "label": "NON_COMPLIANT",1095    "compliance_score": 0.29,1096    "met_points": "2, 3",1097    "unmet_points": "1, 4, 5, 6, 7",1098    "justification": "2 of 7 obligations addressed; compliance score 0.29.",1099    "segment": "Our data processors are responsible for damages only if they fail to meet obligations specifically directed at them or if they act outside or against the lawful instructions provided by us as the data controller. In such cases, the processor may be held liable for any resulting damage. We require our processors to adhere strictly to our instructions and applicable legal requirements.",1100    "batch_id": "B59"1101  },1102  {1103    "gdpr_article_number": 8,1104    "label": "COMPLIANT",1105    "compliance_score": 0.8,1106    "met_points": "1, 3, 4, 5",1107    "unmet_points": "2",1108    "justification": "4 of 5 obligations addressed; compliance score 0.80.",1109    "segment": "We offer our online services directly to children who are at least 16 years old, unless local law allows for a lower minimum age (but not below 13). We make reasonable efforts, using available technology, to verify that any required consent or authorisation from a parent or guardian is obtained, and we respect applicable national laws regarding contracts with minors.",1110    "batch_id": "B168"1111  },1112  {1113    "gdpr_article_number": 79,1114    "label": "COMPLIANT",1115    "compliance_score": 1.0,1116    "met_points": "1, 2, 3",1117    "unmet_points": "",1118    "justification": "3 of 3 obligations addressed; compliance score 1.00.",1119    "segment": "If you believe your personal data rights have been violated due to our data processing, you have the right to seek an effective judicial remedy. You may initiate proceedings before the courts where we are established or, alternatively, in the Member State of your habitual residence, unless we are acting as a public authority exercising official powers.",1120    "batch_id": "B17"1121  },1122  {1123    "gdpr_article_number": 5,1124    "label": "NON_COMPLIANT",1125    "compliance_score": 0.0,1126    "met_points": "",1127    "unmet_points": "1, 2, 3, 4, 5, 6, 7, 8, 9, 10",1128    "justification": "0 of 10 obligations addressed; compliance score 0.00.",1129    "segment": "We may collect and use personal information for a wide variety of reasons, both stated and unstated, and retain data indefinitely without regular review or correction. We do not guarantee that your personal data will be accurate, securely stored, or handled in a manner that protects your privacy. We reserve the right to process information in any way we see fit without prior notice.",1130    "batch_id": "B9"1131  },1132  {1133    "gdpr_article_number": 44,1134    "label": "NOT_APPLICABLE",1135    "compliance_score": 0.0,1136    "met_points": "",1137    "unmet_points": "",1138    "justification": "This article does not apply to this organisation or its activities.",1139    "segment": "This organisation does not engage in the transfer of personal data outside the European Economic Area. As a result, the requirements related to international data transfers are not relevant to our operations. Should this situation change in the future, we will update our privacy practices and inform individuals accordingly.",1140    "batch_id": "B83"1141  },1142  {1143    "gdpr_article_number": 95,1144    "label": "NOT_APPLICABLE",1145    "compliance_score": 0.0,1146    "met_points": "",1147    "unmet_points": "",1148    "justification": "This article does not apply to this organisation or its activities.",1149    "segment": "This section is not applicable, as our organisation does not engage in activities or provide services that fall under this requirement. Therefore, no specific measures or processes are implemented in relation to this provision. Should our operations change in the future to encompass such activities, we will review and update our privacy practices accordingly.",1150    "batch_id": "B139"1151  },1152  {1153    "gdpr_article_number": 47,1154    "label": "COMPLIANT",1155    "compliance_score": 0.72,1156    "met_points": "2, 3, 4, 5, 6, 7, 10, 11, 13, 14, 15, 17, 18, 20, 22, 23, 24, 25, 27, 28, 29, 30, 31",1157    "unmet_points": "1, 8, 9, 12, 16, 19, 21, 26, 32",1158    "justification": "23 of 32 obligations addressed; compliance score 0.72.",1159    "segment": "Our group of undertakings has adopted binding corporate rules that have been approved by the competent supervisory authority through the established consistency mechanism. These rules are legally binding and specify the structure and contact details of each group member. They clearly define the categories of personal data covered, transfer types and purposes, affected data subjects, and relevant third countries. The rules ensure data processing aligns with principles such as purpose limitation, data quality, protection by design and by default, security, and lawful handling of special categories of data. Data subjects are granted enforceable rights, including the ability to lodge complaints with supervisory authorities and courts, and to seek redress or compensation for rule breaches. Compliance is verified via audits, corrective actions, and ongoing training. Changes to the rules are recorded and notified to the supervisory authority, ensuring transparency and cooperation in maintaining data protection standards.",1160    "batch_id": "B3"1161  },1162  {1163    "gdpr_article_number": 17,1164    "label": "NON_COMPLIANT",1165    "compliance_score": 0.0,1166    "met_points": "",1167    "unmet_points": "1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13",1168    "justification": "0 of 13 obligations addressed; compliance score 0.00.",1169    "segment": "We do not offer a process for individuals to request deletion of their personal data, nor do we commit to erasing such data under any circumstances. All personal data provided to us, regardless of its relevance or the withdrawal of consent, will be retained indefinitely and may continue to be processed for our purposes. We do not review the necessity of holding personal data, nor do we provide notification to other parties who may have received such data from us. There are no exceptions or procedures in place for individuals to exercise any rights regarding the erasure of their personal information from our systems.",1170    "batch_id": "B49"1171  },1172  {1173    "gdpr_article_number": 25,1174    "label": "NON_COMPLIANT",1175    "compliance_score": 0.0,1176    "met_points": "",1177    "unmet_points": "1, 2, 3, 4, 5, 6, 7, 8",1178    "justification": "0 of 8 obligations addressed; compliance score 0.00.",1179    "segment": "We process personal information as required for our services and retain it as long as needed. All collected data is stored and used according to our business needs. We do not apply specific technical or organisational measures to limit the amount of data collected, how long it is stored, or who can access it, and do not use pseudonymisation or similar safeguards.",1180    "batch_id": "B50"1181  },1182  {1183    "gdpr_article_number": 33,1184    "label": "NON_COMPLIANT",1185    "compliance_score": 0.4,1186    "met_points": "4, 6, 7, 10",1187    "unmet_points": "1, 2, 3, 5, 8, 9",1188    "justification": "4 of 10 obligations addressed; compliance score 0.40.",1189    "segment": "In the event of a personal data breach, we will provide notification describing the nature of the breach, including the categories and approximate number of individuals and data records affected. We will outline the likely consequences and measures taken or proposed to address the breach. Documentation will be maintained to allow authorities to verify our response and compliance with these requirements.",1190    "batch_id": "B118"1191  },1192  {1193    "gdpr_article_number": 46,1194    "label": "NOT_APPLICABLE",1195    "compliance_score": 0.0,1196    "met_points": "",1197    "unmet_points": "",1198    "justification": "This article does not apply to this organisation or its activities.",1199    "segment": "This organisation does not engage in the transfer of personal data to countries outside the European Economic Area or to any international organisations. As such, requirements and safeguards relating to international data transfers are not applicable to our operations. Should our practices change in the future, we will update our privacy policy accordingly to reflect any new activities involving cross-border data transfers.",1200    "batch_id": "B141"

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