Privacy Policy
A. Introduction
- The privacy of our website visitors is very important to us and we are committed to protecting it. This policy explains what we do with your personal data.
- By consenting to our use of cookies in accordance with the terms of this policy when you visit our website for the first time, you allow us to use cookies each time you visit our website.
B. Collection of personal information
The following types of personal information may be collected, stored and used:
- information about your computer, including IP address, geographical location, browser type and version, and operating system;
- information about your visits to and use of this website, including the reference source, length of visit, page views and website navigation paths;
- information that you provide when you register on our website, such as your email address;
- information you provide when creating a profile on our website, such as your name, gender, relationship status, birthday, profile pictures, interests, hobbies, education and employment details;
- information you provide to subscribe to our emails and/or newsletters, such as your name and email address;
- information that you provide when using the services of our website;
- information generated when you use our website, including when, how often and under what circumstances you use it;
- information relating to anything you buy, the services you use or transactions you make through our website, including your name, telephone number, address, email address and credit card details;
- information that you post on our website with the intention of publishing it on the internet, including your username, your profile pictures and the content of your posts;
- information in any communication you send to us via email or our website, including its content and metadata;
- any other personal information you send us.
Before disclosing another person’s personal information to us, you will need that person’s consent for the personal information to be both disclosed and processed in accordance with this policy.
C. Use of your personal information
Personal information submitted to us via our website will be used for the purposes set out in this policy or on the relevant pages of the website. We may use your personal information for the following:
- to administer our website and activities;
- to customize our website for you;
- to enable you to use the services available on our website;
- to send you goods that you have purchased through our website;
- to deliver services purchased through our website;
- sending statements, invoices and payment reminders to you and collecting payments from you;
- sending commercial communications that are not for marketing purposes;
- to send emails that you have specifically requested;
- to send you our newsletter by email if you have requested it (you can inform us at any time if you no longer need the newsletter);
- to send you marketing communications relating to our business or the business of carefully selected third parties that we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
- to provide third parties with statistical information about our users (but these third parties will not be able to identify an individual user from the information);
- to handle inquiries and complaints from or about you regarding our website;
- to keep our website secure and prevent fraud;
- to confirm your acceptance of our website’s terms of use (including monitoring private messages sent via our website’s private messaging service); and
- other uses.
If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the permission you give us.
Your privacy settings can be used to limit the publication of your information on our website and can be adjusted using the website’s privacy controls.
We will not disclose your personal information to third parties for their or any other third party’s direct marketing without your explicit consent.
D. Disclosure of personal information
We may disclose your personal information to any of our employees, directors, insurers, professional advisers, agents, suppliers or subcontractors as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our holding company and all its affiliates) as reasonably necessary for the purposes set out in this policy.
We may disclose your personal information:
- insofar as we are required to do so by law;
- in the context of ongoing or future court proceedings;
- to establish, exercise or defend our legal rights (including disclosing information to others to prevent fraud and reduce credit risk);
- to the buyer (or prospective buyer) of any business or asset that we are in the process (or considering) of selling; and
- to any person whom we reasonably believe may request from a court or other competent authority that we disclose the personal information if, in our reasonable opinion, such court or authority could reasonably order us to disclose the personal information.
We will not disclose your personal information to third parties except in the cases specified in this policy.
E. International data transfer
- Information we collect may be stored, processed in and transferred between any of the countries we operate in to enable us to use the information in accordance with this policy.
- Information we collect may be transferred to the following countries that do not have data protection laws equivalent to those of the European Economic Area: the United States, Russia, Japan, China and India.
- Personal information that you publish on our website or submit for publication on our website may be accessible via the internet worldwide. We cannot prevent its use or misuse by others.
- You expressly consent to the transfer of personal information as described in this Section F.
F. Preservation of personal information
- This section G describes our data retention policies and procedures, which are designed to ensure that we comply with our legal obligations regarding the retention and deletion of personal information.
- Personal information that we process for any purpose or purposes will not be kept longer than necessary for that purpose or those purposes.
- Without prejudice to Article G-2, we will usually delete personal data that falls within the categories below at the date and time specified below:
- personal data type will be deleted {ENTER DATE/TIME}; and
- {SET ADDITIONAL DATES/TIMES}.
- Notwithstanding the other provisions of this Section G, we will retain documents (including electronic documents) containing personal data:
- insofar as we are required to do so by law;
- if we believe the documents may be relevant to ongoing or future court proceedings; and
- to establish, exercise or defend our legal rights (including disclosing information to others to prevent fraud and reduce credit risk).
G. Security of your personal information
- We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.
- We will store any personal information you provide on our secure (password and firewall protected) servers.
- All electronic financial transactions made through our website are protected by encryption technology.
- You acknowledge that information transmission via the internet is inherently insecure, and we cannot guarantee the security of data sent via the internet.
- You are responsible for keeping the password you use to access our website confidential; we will not ask you for your password (except when you log in to our website).
H. Amendments
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to make sure you understand any changes to this policy. We may notify you of changes to this policy by email or via our website’s private messaging system.
I. Your rights
You can ask us to provide you with any personal information we hold about you; the provision of such information will be subject to the following:
- payment of a fee {ENTER FEE IF APPLICABLE}; and
- providing appropriate proof of your identity ({CHANGE TEXT TO REFLECT YOUR POLICY for this purpose, we usually accept a photo of your passport that has been certified by a notary, plus a copy of a utility bill showing your current address}).
We may withhold the personal information you request as permitted by law.
You can ask us at any time not to process your personal information for marketing purposes.
In practice, you will usually either explicitly accept our use of your personal information for marketing purposes, or we will give you the opportunity to opt out of the use of your personal information for marketing purposes.
J. Third party websites
Our website contains hyperlinks to and details of third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
K. Updating of information
Let us know if the personal information we hold about you needs to be corrected or updated.
L. Kakor
Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) sent by a web server to a browser and stored by the browser. The identifier is then sent back to the server every time the browser requests a page from the server. Cookies can be either “persistent cookies” or “session cookies”: a persistent cookie is stored by a browser and remains valid until the specified expiration date, unless deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user session, when the browser is closed. Cookies generally do not contain information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. {We use only session cookies / only persistent cookies / both persistent and session cookies on our website.}
- Below are the names of the cookies we use on our website and the purposes for which they are used:
- we use Google Analytics and Adwords on our website to recognize a computer when a user {INCLUDE ALL AREAS OF USE FOR COOKIES ON YOUR WEBSITE visits the website / track users as they browse the website / enable the use of a shopping cart on the website / improve the usability of the website / analyze the use of the website / administer the website / prevent fraud and improve the security of the website / customize the website for each user / target ads that may be of particular interest to specific users / describe the purpose(s)};
- Most browsers allow you to refuse to accept cookies – for example:
- in Internet Explorer (version 10), you can block cookies using the settings to override cookie management by clicking on “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
- in Firefox (version 24), you can block all cookies by clicking “Tools”, “Preferences”, “Privacy & Security”, selecting “Custom Content Blocking” and clicking “All Cookies”; and
- In Chrome (version 29), you can block all cookies by opening the ‘Settings’ menu and clicking on ‘Website settings’ under ‘Privacy and security’ and then unchecking ‘Allow websites to save and read cookie data’.
Blocking all cookies will have a negative impact on the usability of many websites. If you block cookies, you will not be able to use all the features of our website.
- You can delete cookies that have already been stored on your computer – for example:
- in Internet Explorer (version 10), you must manually delete cookies (you can find instructions for doing so at http://support.microsoft.com/kb/278835 );
- in Firefox (version 24), you can delete cookies by clicking “Tools”, “Preferences”, “Privacy & Security” and then selecting “Clear data” under “Cookies and site data”; and
- In Chrome (version 29), you can delete all cookies by opening the ‘Settings’ menu and clicking on ‘Clear web information’ under ‘Privacy and security’.
- Removing cookies will have a negative impact on the usability of many websites.