“Because we do not collect or determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, We are not acting in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter “GDPR”) and does not have the associated responsibilities under the GDPR.”
Protecting privacy and personal data
The Site, Our products or services may contain links to other companies’ websites and services that have their own privacy policies and/or the services of third parties installed on your device may allow access to information on your device. We advises you to read carefully the privacy policies of such third parties. We is not responsible for such third party service providers’ privacy practices or contents.
1. Controller of Personal Data
The controller for your personal data is Our websites.
2. Purpose of the processing of personal data and legal basis for processing
When using the Site, certain personal data that can be connected to you may be collected and processed.
Such personal data may be used for the following purposes, as necessary for Our legitimate interests in connection to (one or more of which may apply simultaneously):
- maintenance and development of the Site and Our products and services;
- marketing and communication purposes such as for conducting marketing research, direct marketing, automated marketing, informing you of new features, new products or launches, and special promotions;
- provision of products and services such as for performing the contract between you and Us, ensuring the functionality and security of Our products and services, identifying you and preventing and investigating possible misuses; and for
- statistical and analytical purposes.
If you communicate with us using the Site, and/or register as a user of the Site (where applicable), We may in some instances also process your personal data on the basis that such processing is necessary for the performance of a contract between you and Us, preparatory measures in connection to the contract, or, in some instances, based on your consent.
To the extent We processes your personal data based on your consent, you have the right, at any time and free of charge, to withdraw the consent that you give for Us to process your personal data. Please, note however, that such withdrawal may mean that you will no longer be able to use all the functionalities on the Site, or other products or services offered by Us to you, since certain data processing activities relying on your consent may be an integral part of such functionalities, products or services.
3. Collected Personal Data
Personal data is typically collected when you use the Site, register into Our products and services or otherwise interact with Us. The personal data may include, among others, access times, the website you linked from, the links you use, the pages you visit, the content you view and such other behavioural information We receives through your browser.
We may further ask you to provide Us with other kind of information, such as your name, e-mail address, street address, user names and passwords, consent, feedback, age, gender and other non-sensitive data. We wishes to emphasize that certain non-identifiable personal data may become identifiable when you provide Us with your personal data.
4. Regular sources of data
The personal data is collected from the following sources:
- information provided by you or through your actions within the Site or otherwise contacting Us;
- Our subcontractors in relation to the provision of services with respect to the Site
- Publicly available sources
5. Regular disclosure of data and the transfer of data outside the EU or the EEA
The personal data may be disclosed by Us to its group companies also outside the European Union (“EU”) or outside the European Economic Area (“EEA”) in accordance with a contract entered into between the relevant Our entities, incorporating the European Commission’s Standard Contractual Clauses, which ensure that adequate data protection arrangements are in place. The personal data stored on the server will not be transferred outside the EU or the EEA.
We may further conduct marketing and other communication jointly with Our partners and in connection with this, We may combine information We has collected about you with information Our partners have collected about you to e.g. avoid unnecessary communication and tailor Our message to you.
In the event We sells, buys, merges or reorganizes in some other way, this may involve Our disclosing personal data e.g. to potential and actual purchasers and their advisers.
In addition to the above We may be obliged to disclose your personal data to the authorities. We may also disclose and otherwise process your personal data, in accordance with applicable legislation, to defend its legitimate interests.
6. Principles of data security and data storage
The personal data will be mainly stored electronically. The personal data is stored in locked premises with restricted access and protected by a participant ID and a password. All physical copies of the personal data, if any, will be stored in locked premises. Only persons who need to process the personal data as part of their duties have access to and the right to process the information stored in the register.
We retains your personal data as long as it is necessary for the aforementioned purposes or as required by applicable laws. When such requirements no longer exist, your personal data will be deleted or anonymised in such a manner that it no longer can be connected to you.
7. Automated decision making
Personal data is not used for automated decision making having legal or similar consequences to you.
8. User’s rights
Right of access: You are entitled to inspect your personal data and to receive a written copy of the personal data. The inspection is free of charge.
Right to data portability: To the extent We processes your personal data based on your consent, or for the purposes of a contract between you and Us, you are entitled to receive your personal data, which you have provided to Us, in a structured, commonly used and machine-readable format and, when technically feasible, have the right to transmit those data to another controller without hindrance from Us.
Right to object: You are entitled to object at any time to processing of your personal data for direct marketing purposes.
Right to request rectification, erasure or restriction: You are entitled to ask Us to rectify or erase your personal data in case it is obsolete, irrelevant, incorrect, incomplete, otherwise inaccurate or due to other legally acceptable ground. You are also entitled to request restriction of processing of your personal data.
Official complaint: while We hopes to resolve any issue you may have with how We processes your personal data, you do also have the right to lodge an official complaint with your local national data protection supervisory authority.
If you wish to exercise your rights, please present a written request to the address stated in Section 11.
A cookie is typically a small piece of data sent to your computer device from a website and stored in your web browser while you are browsing a website. When you browse the same website again, the data stored in the cookie may be retrieved by the website to notify the website of your previous activity. To read more about these technologies and how they work, please see for example http://www.allaboutcookies.org.
From time to time, a ‘cookie’ file may be placed on your computer to improve the effectiveness of this Site and/or Our services to you. Most browsers are set to accept cookies. You can change your settings to refuse all cookies or to tell you when a cookie is being sent.
The use of certain cookies is necessary to run basic functions on the Site. These cookies are essential for running the Site and are needed to provide you a pleasant experience when visiting the Site.
The length of storage of information depends on the type of cookie used. Session cookies expire when the browser is closed, while persistent cookies have typical expiration dates between two months and a couple of years.
10. Website Analytics and Visitor Information
The Site uses a web analytics service provided, for example, by Google, Inc (“Google”). By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out in the above statement.
Third parties, such as advertisers, advertising networks and providers of tracking services, may set cookies on your device when you are visiting the Site, for example to provide you with targeted advertising or to compile statistics on the number of visitors on the Site. Since your web browser must request these advertisements from third parties’ servers, these third parties may view, modify or set their own cookies as if you had requested a webpage from the third parties’ website directly.
The Site uses social media plugins, such as the “Like” button provided by the social network facebook.com. The content of the social media plugins on the Site is from such social network(s) directly. When you visit the Site while logged into a social network, your browser establishes a direct connection with the social network’s servers. If you are logged out from the social network(s) while visiting Site, your browser sends the social network(s) a more limited information. The social media plugins on the Site are subject to the privacy terms and other terms and conditions of the relevant social media sites. The information collected by the social network(s) is not disclosed to Us without your explicit consent.
Should you have any additional questions, please don’t hesitate to contact us through our customer service.