Privacy Policy

Revision of: 25th November 2022

Welcome to operator privacy policy (the “Policy”).

Operator (hereinafter “we”; “us”; “our”) respect your privacy and value its importance, and are wholly committed to keeping your information safe and secure.

As a high-level summary, we are a company, which created a platform attracting certain coupon issuers, sellers of goods and services and their customers, which use coupon issued by issuers for their clearing-off (the “Services”). We provide all this by means of our website (the “Platform”).

Accordingly, the purpose of this Policy is to set out the basis on which we will process your Personal data when you:

  1. visit and use a Platform, regardless of where you visit or use them;
  2. apply for and register a customer account with us (your “Account”);
  3. apply for, receive, pay and/or use any of our Services.

This also includes any data which you may provide to us for our events, newsletters and other marketing items.

This Policy informs you about the items of Personal data that we may collect about you and how we will handle it, and in turn, also tells you about:

  1. our obligations to process your Personal data responsibly,
  2. your data protection rights as a data subject and
  3. how the law protects you.

This Policy is provided in a layered format so you can click through to the specific areas set out below. It should be read in conjunction with our Cookie Policy.

Please read the following information carefully to understand our practices regarding your Personal data.

Important information and who we are

We process your data in an appropriate and lawful manner, in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) (the “Regulation” or the “GDPR”) and relevant laws applicable to the protection of personal data in other jurisdictions (the “Legislation”).

This Policy aims to ensure that you are fully informed on how we will collect and process your Personal data in the circumstances and scenarios outlined in the ‘Introduction’ (namely, for your subscription and use of the Platform, purchase of coupon by you and any of the related activities necessary for Services rendering).

It is important that you read this Policy together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

The opening and registration of a customer account will give rise to the existence of a contractual relationship with us, as regulated by our Terms of Use, and all matters between you and us relating to Services will be deemed to fall within the subject-matter of that same contractual relationship. Furthermore, the existence of this contract between you and us will also serve as the legal basis for a number of our processing activities involving your Personal data, as detailed below.


Operator (as defined) above is the controller and responsible for your Personal data.

We process and store your Personal data.

There may be other controllers of your Personal data, such as, for example, electronic identification verification service providers, or other service providers engaged by us or our licensees for purposes of processing and storing your Personal data. They will be so-called “joint controllers” of your Personal data and as such, will share responsibility for such control with us.

Changes to the Policy and your duty to inform us of changes

It is imperative that the Personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to process your coupon purchases and/or our ability to provide you with the Services that you may requests from us (amongst other salient issues). Please keep us informed if any of your Personal data changes during your relationship with us.

Our Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notice or policies. We strongly encourage you to read the privacy notice of every website you visit, particularly when leaving our Platform.

Some key definitions

Set out below are key definitions of certain data protection terms which appear in this Policy.

Consent Form refers to separate documents which we might from time to time provide you where we ask for your explicit consent for any processing which is not for purposes set out in this Policy.

Data subjects

Data subjects means living individuals (i.e. natural persons) about whom we collect and process Personal data

Data controller

Data controller or controller means any entity or individual who determines the purposes for which, and the manner in which, any Personal data is processed.

Data processor

Data processor or processor means any entity or individual that processes data on our behalf and on our instructions (we being the data controller).

Personal data

Personal data means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess. This may include, but is not limited to, your name and surname (including maiden name where applicable), address (city or other locality, country) contact details (including phone number and personal email address), bank account details, as well as online identifiers. The term “personal information”, where and when used in this Policy, shall be taken have the same meaning as Personal data.


Processing means any activity that involves use of Personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal data to third parties.

Sensitive Personal data

Sensitive Personal data, sensitive data or special categories of Personal data includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. This type of sensitive data can only be processed under strict conditions.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, share and disclose different kinds of Personal data about you which (for purely indicative purposes) we have grouped together as follows.

  • Identity Data includes your first name, maiden name (where applicable), last name, username or similar identifier, city or other locality and country.

  • Contact Data includes email address and contact number (telephone or mobile).

  • Financial Data includes your banking information, wallet details.

  • Transaction Data includes details about:

    • your subscriptions, purchases and transactional activity;
    • your transactional history on the Platform;
    • your use of coupons and the Services (including your service requests);
    • the payments made to and from you.
  • Portfolio Data includes details about the coupons credited to your account.

  • Usage Data includes details about how you use our Platform.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices which you (whether a client or otherwise) use to access and browse the Platform.

  • Platform Visit Data includes the full Uniform Resource Locators (URL), clickstream to, through and from the Platform (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.

  • Marketing and Communications Data includes your preferences in receiving marketing from us or our third parties and your communication preferences. This may include information whether you have subscribed or unsubscribed from any of our mailing lists, attended any of our events, or accepted any of our invitations.

We will also collect, use and process any other information that you voluntarily choose to provide or disclose to us where relevant for processing your coupon requests and/or providing you with your requested Services. Any such information that we receive from you would fall under the Transaction Data category.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal data but is not considered Personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Platform Visit Data to calculate the percentage of users accessing a specific feature of the Platform. However, if we combine or connect Aggregated Data with your Personal data so that it can directly or indirectly identify you, we treat the combined data as Personal data which will be used in accordance with this Policy.

If you fail to provide Personal data

Where we need to collect Personal data about you:

  • by law, or
  • under the terms of, or in connection with, the agreement that we have with you; or
  • as part of our legitimate (business) interests to verify the identity of our applicants and customers, mitigate against risks (such as potential or suspected fraud) and, in particular, to assess and take a decision on whether we want to enter into a customer relationship with you (as subject to our customer acceptance criteria and policies),

and you either fail to provide that data when requested, or else provide incomplete or insufficient data, we may not be able to perform or conclude the agreement which we have or are otherwise trying to enter into with you (namely, regarding your account opening, coupon purchase, and provision of the Services).

We will however notify you if this is the case at the time.

Нow is your Personal data collected?

We generally use different methods to collect data from and about you including through:

Account Registration

We will ask you to provide us with your Identity and Contact Data when you apply to open a customer account with us. You provide this information, which will then be collected and processed, when you fill in and submit your account application form (together with other related forms) and complete the required application steps.

Direct Interactions

You may give us your Identity, Contact Data and Marketing and Communications Data by filling on our forms. This includes Personal data you provide when you:

  • contact us in the context of opening and registering a customer account;
  • apply to open a customer account;
  • purchase coupons at the Platform;
  • use the Platform and/or our Services;
  • discuss the particular Services that you require;
  • contact us with complaints or queries;
  • complete an enquiry form;
  • contact us for further information about the coupons and Services;
  • request marketing to be sent to you;
  • express interest and/or attend any of our seminars or other hosted events;
  • participate in a survey or our webinars;
  • subscribe to our newsletters;
  • give us some feedback.

Through our provision of the Services

This may encompass all of the data categories, namely, Identity, Contact and Transaction Data.

Automated technologies or interactions

When you interact with our Platform, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We may collect this Personal data by using cookies, server logs and other similar technologies.

Please see our Cookie Policy for further details.

Third parties or publicly available sources

We may receive Personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    • analytics providers;
    • advertising networks; and
    • search information providers.
  • Identity, Contact Data from publicly available sources such as public court documents, the company houses and registers of other jurisdictions, and from electronic data searches, anti-fraud databases and other third party databases and from general searches carried out via online search engines (e.g. Google).

If you attend an event or meeting at our offices, we may hold images of you captured by our CCTV cameras.

How we use your Personal data

We will only use your Personal data when the law allows us to. Most commonly, we will use your Personal data in the following circumstances:

  • Where you wish to enter into a customer relationship at the Platform.
  • Where you need to perform the agreement you have or which are about to enter into with you as customer (including in respect of coupons purchases and use of Services).
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

You have the Right to withdraw consent to such marketing at any time by contacting us.

Change of purpose

We strive to provide you with choices regarding certain Personal data uses, particularly around advertising and marketing. Through your Identity, Contact, Usage, Technical and Platform Visit Data, we are able to form a view on what we think you may want or need. This is how we then decide which of our Services may be relevant or of interest to you (our marketing communications).

We will only use your Personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or we are obliged to process your data by applicable laws or court / enforceable orders.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at

If we need to use your Personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal data without the need to obtain your consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your Personal data

We may have to grant access to, disclose or share your Personal data with the parties set out below (which may be in or outside your jurisdiction):

  • Third party service providers, including platform integration and infrastructure hosting providers (in order to store data) and coupon accounting services (in order to verify, monitor and secure coupon purchase activity).

  • Our affiliated entity, such as partner firms involved in the provision of certain Services.

  • Affiliated group entities. We share information with these entities in order to:

    • help, detect and prevent potentially illegal acts and violations of our policies;
    • allow you to use the products and services they provide that are supplied in connection with, or using, the products and services at the Platform; and
    • guide decisions about our products, services and communications.
  • Suppliers and external agencies that we engage to process information on our or your behalf, including to provide you with the information and/or materials which you may have requested.

  • Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.

  • Law enforcement agencies, public authorities and judicial bodies (local and overseas).

  • Other organizations where exchange of information is for the purpose of fraud protection.

  • Debt recovery agencies who assist us with the recovery of debts owed to us.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal data in the same way as set out in this Policy.

We require all affiliated entities and third-party service providers to respect the security of your Personal data and to treat it in accordance with the law. We do not allow them to use your Personal data for their own purposes and only permit them to process your Personal data for specified purposes and in accordance with our documented instructions. Our service providers currently store your Personal data in the European Union territory. We will update this Privacy Policy if their data storage location changes.

International transfer

We do not generally transfer your Personal data to outside the European Economic Area (“EEA”) except as may be necessary to:

  • process your transactions, subscriptions, purchases and/or trading activity,
  • provide the requested services,
  • fulfil our contractual obligations to you,
  • exercise and enforce our contractual rights and terms of services,
  • comply with our legal and/or regulatory obligations or
  • assert, file or exercise a legal claim.

Where we do need to transfer your Personal data to outside the EEA, we will ensure a similar degree of protection is afforded to that Personal data by ensuring at least one of the following safeguards applies or is otherwise implemented:

  • We will only transfer your Personal data to countries that have been deemed to provide an adequate level of protection for Personal data by the European Commission.
  • In the absence of an adequacy decision, we will use specific contracts approved by the European Commission which give Personal data the same protection it has in Europe.
  • Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal data shared between the Europe and the US.

Data security

We have put in place appropriate security measures to prevent your Personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed (i.e. to safeguard its integrity and confidentiality). We also regularly review and, where practicable, improve upon these security measures.

We also limit access to your Personal data to strictly those employees, agents, contractors and third parties that have a professional ‘need-to-know’. They will only process your Personal data on our instructions and they are subject to a duty of confidentiality. All our employees and agents have received appropriate training on data protection.

We have put in place procedures to deal with any suspected Personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your Personal data for as long as necessary to fulfil the purposes for which we collected it and, thereafter:

  • for the purpose of satisfying any legal, accounting, tax, anti-money laundering and regulatory obligations or reporting requirements to which we may be subject; and/or
  • to the extent that we may also need to retain your Personal data to be able to assert, exercise or defend possible future legal claims against you or that otherwise involve you.

By and large, our retention of your Personal data shall not exceed the period of six (6) years from the termination of your customer relationship with us (which would typically arise from the closure or termination of your customer account). This retention period enables us to make use your Personal data for any applicable reporting obligations, and for the filing, exercise or defense of possible future legal claims (taking into account applicable prescriptive periods and statutes of limitation). In certain cases, we may need to retain your Personal data for a period of up to ten (10) years in order to comply with applicable accounting and tax laws (this will primarily consist of your Transaction Data). There may also be instances where the need to retain Personal data for longer periods, as dictated by the nature of the products and services provided by merchants.

In some circumstances you can ask us to delete your data. See Request erasure below for further information.

Kindly contact us at for further details about the retention periods that we apply.

Data Minimization

To the extent possible, we may anonymize the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you. In some circumstances, we may even pseudonymize your Personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your Personal data. Please, click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us at

No fee is usually charged

You will not have to pay a fee to access your Personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may simply refuse to comply with your request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within a period of one month from the date of receiving your request. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to:

1. Request access

Request access to your Personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal data we hold about you and to check that we are lawfully processing it.

You may send an email to requesting information as the Personal data which we process. Any copies of the Personal data which is undergoing processing shall be sent via email and incur a charge of €10.00.

2. Right to information

Right to information when collecting and processing Personal data about you from publicly accessible or third party sources. When this take places, we will inform you, within a reasonable and practicable timeframe, about the third party or publicly accessible source from whom we have collected your Personal data.

3. Request correction or rectification

Request correction or rectification of the Personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us. As mentioned, it is in your interest to keep us informed of any changes or updates to your Personal data which may occur during the course of your relationship with us.

4. Request erasure

Request erasure of your Personal data. This enables you to ask us to delete or remove Personal data where:

  • there is no good reason for us continuing to process it; - you have successfully exercised your right to object to processing (see below);
  • we may have processed your information unlawfully; or
  • we are required to erase your Personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

These may include instances where the retention of your Personal data is necessary to:

  • comply with a legal or regulatory obligation to which we are subject; or
  • establish, exercise or defend a legal claim.

5. Object to processing

Object to processing of your Personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal data for direct marketing purposes.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal information that override your rights and freedoms.

6. Request restriction

Request restriction of processing of your Personal data. This enables you to ask us to suspend the processing of your Personal data in the following scenarios:

  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold onto the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or
  • where you have objected to our use of your Personal data, but we need to verify whether we have overriding legitimate grounds to use it.

7. Request the transfer (data portability)

Request the transfer (data portability) of your Personal data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw your consent at any time where we are relying on consent to process your Personal data (which will generally not be the case). This will not however affect the lawfulness of any processing which we carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected.

Kindly note that none of these data subject rights are absolute, and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override your data subject request, you will be informed of this by our data protection team along with the reasons for our decision.


You have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as (in particular) the supervisory authority in the place of your habitual residence or your place of work. We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance at


We reserve the right to make changes to this Policy in the future, which will be duly notified to you. If you have any questions regarding this Policy, or if you would like to send us your comments, please contact us today or alternatively write to our data protection team using the details indicated in this Policy.

This is the Cookie Policy for operator, accessible from

What Are Cookies

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.

For more general information on cookies see the Wikipedia article on HTTP Cookies.

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore it is recommended that you do not disable cookies.

The Cookies We Set

Site preferences cookies

In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site. This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.

Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.

More Information

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However if you are still looking for more information then you can contact with our support team via

You are entitled to request us to erase any personal data we hold about you under the EU General Data Protection Regulation (GDPR) and the relevant laws that apply to the protection of personal data in other jurisdictions.

We will do our best to respond promptly and in any event within 1 (one) month of the following:

  • Our receipt of your written request; or
  • Our receipt of any further information we may ask you to provide to enable us to comply with your request, whichever happens to be later.

The information you supply to us will only be used for the purposes of identifying the personal data you are requesting that we erase and responding to your request. You are not obliged to complete this form to make a request, but doing so will make it easier for us to process your request quickly.

Please provide following information to our support team via email

Section 1. Details of the person requesting information

  • Full name
  • Address
  • Contact telephone number
  • Email address

Section 2. Are you the data subject?

YES: I am the data subject. I enclose proof of my identity (see below). (Please go to Section 4)

NO: I am acting on behalf of the data subject. I have enclosed the data subject’s written authority and proof of the data subject’s identity and my own identity (see below). (Please go to Section 3)

To ensure we are erasing data of the right person we require you to provide us with proof of your identity and of your address. Please supply us with a photocopy or scanned image (do not send the originals) of one or both of the following:

  1. Proof of Identity (Passport, photo driver’s license, national identity card, birth certificate.)

  2. Proof of Address (Utility bill, bank statement, credit card statement (no more than 3 months old); current driver’s license.)

If we are not satisfied you are who you claim to be, we reserve the right to refuse to grant your request.

Section 3. Details of the data subject (if different from Section 1)

  • Full name
  • Address
  • Contact telephone number
  • Email address

Section 4. Reason for erasure request

Given the sensitive nature of erasing personal data, GDPR Article 17(1) requires certain conditions to be met before a request may be considered. Please supply us with the reason you wish your data to be erased and please attach any justifying documents to this one.

Please provide one or more following reasons:

  • You feel your personal data is no longer necessary for the purposes for which we originally collected it.
  • You no longer consent to our processing of your personal data.
  • You object to our processing of your personal data as is your right under Article 21 of the GDPR.
  • You feel your personal data has been unlawfully processed.
  • You feel we are subject to a legal obligation of the EU or Member State that requires the erasure of your personal data.
  • You are a child, you represent a child, or you were a child at the time of the data processing and you feel your personal data was used to offer you information society services.

Section 5: What information do you wish to erase?

Please describe the information you wish to erase. Please provide any relevant details you think will help us to identify the information. Providing the URL for each link you wish to be removed would be helpful.

Also, please explain, if it is not abundantly clear, why the linked page is about you or the person you are representing on this form.

Please note that. In certain circumstances, where erasure would adversely affect the freedom of expression, contradict a legal obligation, act against the public interest in the area of public health, act against the public interest in the area of scientific or historical research, or prohibit the establishment of a legal defense or exercise of other legal claims, we may not be able to erase the information you requested in accordance with article 17(3) of the GDPR. In such cases you will be informed promptly and given full reasons for that decision.

While in most cases we will be happy to erase the personal data you request, we nevertheless reserve the right, in accordance with Article 12(5) of the GDPR, to charge a fee or refuse the request if it is considered to be “manifestly unfounded or excessive.” However we will make every effort to provide you with the erasure of your personal data if suitable.

Section 6: Declaration

Please note that any attempt to mislead may result in prosecution.

I confirm that I have read and understood the terms of this subject access form and certify that the information given in this application to ______________ is true.

I understand that it is necessary for ________________ to confirm my/the data subject’s identity and it may be necessary to obtain more detailed information in order to locate the correct personal data.

Signed: ………………………………………… Date: ……………..

Documents which must accompany this application:

  • Evidence of your identity (see section 2)
  • Evidence of the data subject’s identity (if different from above)
  • Authorization from the data subject to act on their behalf (if applicable)
  • Justification for erasure of data (see section 4)