Last modified: JANUARY 29, 2020
- The owning Company is the publisher and operator (referred to as the “Company”, “we”, “our” or “us”) of the website.
- The Company is committed to protecting your privacy and handling your personal data in an open and transparent manner. The personal data that we collect and process will vary depending on how you use the Website.
- Users must be aged eighteen (18) years and over or must have attained the age of majority in their respective jurisdiction in order to be able to use the Website. All persons who do not meet these criteria are strictly forbidden from accessing, viewing the contents of, or otherwise joining the Website.
- We do not knowingly seek or collect any personal information from persons who have not attained the age of eighteen (18).
- When we refer to “personal data” or “personal information” we mean data which identifies or may identify you and which may include, for instance, your email or IP address.
- When we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your personal data.
4. How we collect your personal data?
- We obtain your personal data mainly through any information you provide directly to us through our Website.
- When we need to collect and process your personal data in order to provide you with our services and you fail to provide that data when requested, we may not be able to provide you with access to our Website and/or the services we offer.
- We will collect different categories of personal data from you depending on your level of interaction with our Website.
- Personal data we collect and process from Browsers Technical Data, including your Internet Protocol (IP) address and associated country, your browser type and version, time zone setting and location, browser plug-in types and versions, smart device information, mobile phone network information, operating system and platform and other technology on the devices you use to access this Website.
- For more information on the cookies we collect, please visit our Cookies Policy.
- Usage Data, including your communication preferences and information about how you use our Website including the services you viewed or searched for, page response times, download errors, length and number of visits and page interaction information (such as scrolling, clicks and mouse-overs) as well as the links you clicked on or used.
- As you navigate through and interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect these data by using cookies and other similar technologies. We may also use these technologies to collect information about your online activities across third-party websites. Please see our Cookies Policy for further details.
5. Why we need your personal data and how we use it:
- We would like to ensure that you fully understand why your information may be used.
- Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide you with the services we provide to our Members.
- Analytics We may collect and process your personal data where it is necessary in order to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed and demographic patterns.
- We may collect and process your personal data where it is necessary to administer our relationship with you, manage your account and provide you with support about your account, including expiration and renewal notices, and inform you about any changes to the Website that may affect the services that you provide to us.
6. Other legitimate interests - in addition to the above, we may process your data, to the extent required for our business needs in order to:
- Develop new services on our Website as well as analyze and target new markets.
- Protect our legal rights and interests (including legal claims and preparing our defense in litigation).
- Monitor, maintain and improve internal business processes, information and data, technology and communication solutions and services.
- Ensure network information security, including monitoring Members’ access to our information technology for the purpose of preventing cyber-attacks, unauthorized use of Website and prevention or detection of crime.
- Send you relevant marketing information (including details of other services provided by us which we believe may be of interest to you), but only where you are Members of the Website.
- Monitor the performance and effectiveness of our services and the Website and assess the quality of our customer services.
7. Who we share your personal data with?
- When we disclose your personal data to service providers, we will ensure that they are bound by a contract requiring them to comply with their GDPR obligations.
- We specifically reserve the right to disclose any and all information to law enforcement in the event that a crime is committed or suspected or if we are compelled to do so by lawful criminal, civil or administrative process, discovery requests, subpoenas, court orders or writs.
- We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- We also may share aggregated information with third-parties for conducting general business analysis. This information does not contain any personal data and may be used to develop content and services that we hope you and other users will find of interest.
- Please note that we have never sold and will never sell your personal data to third parties.
8. Security of your personal data:
- We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your personal data from unauthorized access and disclosure. For instance, only authorized employees are permitted to access personal data, and they may do so only for permitted business functions.
- In addition, we use encryption in the transmission of your personal data between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal data. However, please be advised that we cannot fully eliminate security risks associated with the storage and transmission of personal data as we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining this information.
- You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
9. Information we transfer:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield.
- We may additionally, in rare occasions, transfer your personal data to a party outside the EEA where we have your prior explicit consent to do so or where such transfer is necessary for the provision of our services to you.
10. Marketing information:
- We may process your personal data so as to inform you about existing and/or future services that may be of interest to you by sending you periodic announcements with details on existing and/or new services and/or programs.
- You have the right to object at any time to the processing of your personal data for marketing purposes, by sending us an email.
- We can only use your personal data to promote our services to you if we have your explicit consent to do so, or in certain cases such as for example when you are a Member of our Website, if we consider that it is in our legitimate interest to do so.
- You may also occasionally receive marketing communications from our affiliates, but only provided you have given your explicit consent in receiving such communications.
- Even if you inform us that you no longer wish to receive marketing material, you will still receive from us system notices and other information specifically related to your account from time to time.
11. How long we keep your personal data:
- We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
- We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
- To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
12. Your data protection rights:
- We want to make sure you are aware of your rights in relation to the personal data we process about you.
- Access: This enables you to get access or receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
- Correction: If you believe that any of the information that we hold about you is inaccurate or incomplete, you have a right to request that we correct the inaccurate personal information.
- Erasure: You may request that we delete your personal information.
- Right to object: You have the right to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you exercise your right to object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedom or for the establishment, exercise and defense of legal claims. You also have the right to object where we are processing your personal data for direct marketing purposes. This also includes profiling in as much as it is related to direct marketing. If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes. Depending on the circumstances, we may need to restrict or cease processing your personal data altogether or, where requested, delete your personal data. Please note that if you object us processing your personal data, we may have to suspend the services we provide to you.
- Restriction: You have the right to request the restriction of processing of your personal data. Please note that if you request us to restrict processing of your personal data, we may have to suspend the services we provide to you.
- Right to portability: Where we have requested your permission to process your personal data or you have provided us with information for the purposes of entering into a contract with us, you have the right to receive the personal data you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provided to you.
13. Our policy towards minors:
- Our Website is not directed to individuals under the age of eighteen (18) or the applicable age of majority in the jurisdiction from which the Website is accessed and we do not knowingly collect personal data from minors.
- If you become aware that your child has provided us with personal data, please contact us.
- If we become aware that a minor has provided us with personal data, we will take steps to remove such information and terminate that person’s account immediately.