Privacy Policy

 

1. General

1.1  Safeguarding the privacy of our Website visitors is carried out in accordance with this Privacy Policy (the “Policy”).

1.2  Our Website uses cookies and when you first access our Website you will be asked to consent to the use of cookies according to this policy. Access or use of our Website or Services shall be deemed conclusive and sufficient evidence of your consent to this policy.

 

2. Personal data

2.1  By accessing or using our Website you agree and represent that the following types of personal data (information) may be collected, processed and otherwise used by us:

(a) your location, browser type, browser version, operating system, referral source, length of visit, your IP address, page views and navigation paths, as well as other information about your computer and about your use of and visits to our Website;

(b) your email address and other data supplied by you while using our Website, such as the comment forms;

(c) any communication and details contained therein that you send, post or otherwise disclose via our Website, including metadata associated with the communication.

2.2  By accessing or using our Website you represent and warrant that you have obtained proper consent by any other person whose personal data you disclose to us, including for the purposes of storing, processing and otherwise using of such data according to this policy.

 

3. Use of personal data

3.1  Personal data provided to us via our Website will be used for:

(a) administering our Website and for personalizing our Website for you;

(b) the purposes of using of the Services and other resources of our Website, including for the provision of respective deliverables, newsletters, notifications, etc.;

(c) documentary exchange;

(d) monitoring compliance with rules that govern the use of our Website;

(e) marketing and non-marketing communications which we deem might be of your interest;

(f) processing and provision of information of statistical nature about our visitors to third parties (with no particular identification of individual users);

(g) administration of inquiries relating to our Website;

(h) our Website security reasons, prevention of fraud and unauthorized access or actions;

(i) provision of assistance to official authorities to the extent required by the applicable laws.

3.2  If you would like us to discontinue sending you standard correspondence such as newsletters or other notifications, please make sure you explicitly let us know via email communication;

3.3  Your personal data will not be disclosed to any third party for the purpose of any third part’s direct marketing. Personal data may be used for the purposes specified in this policy or as indicated on relevant pages of our Website.

 

4. Personal data disclosure

4.1  Your personal data will not be subject to disclosing to third parties, except as provided in this policy or unless otherwise agreed by both parties and with your consent;

4.2  By accessing or using our Website you agree that your personal data may be disclosed by us:

(a) to the extent required by the applicable law; or

(b) with respect to ongoing or prospective legal proceedings, including in order to ascertain, exercise or defend our legal rights, or for the purposes of fraud prevention and/or reducing credit risk; or,

(c) to our employees, officers, insurers, professional advisers, related companies, affiliates, subsidiaries, suppliers or subcontractors as reasonably necessary for the purposes set out in this policy and on a need-to-know basis.

 

5. Safety of personal data

5.1  The personal data provided by you will be stored on our or on our service providers’ secure servers (operating under password and firewall protections). In case data is stored on our service provider infrastructure, we may not ensure or enforce protective measures other than these already undertaken by them. We take reasonable technical measures designated to prevent the loss, misuse or alteration of personal data. We ensure your data is secure at all times and processed over a secure connection. Always look for the padlock in the browser address bar to check if an SSL certificate is installed.

5.2  You acknowledge that:

(a) you are aware of the fact and accept that our Website utilizes hyperlinks to, and details of, other Websites, including Websites of third parties. We cannot guarantee the accuracy of the information found at any external sites. Any information on external Websites we link to cannot be considered an endorsement by us.

(b) we are not responsible for the privacy policy and practices of any third party;

(c) you will keep your personal data at our Website updated to ensure the Services are rendered and supplied to you appropriately;

(d) we are not responsible for whatsoever having arisen out from inappropriate rendering of information to us, neither for having any information not updated;

 

6. Personal data retention and your rights over your data

6.1  We will not keep personal data longer than necessitated by the purposes set out herein. If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue. If you email us, we store the contents for 5 years.

6.2  Notwithstanding any provision hereof, you expressly agree that electronic and other documents containing personal data may be retained by us:

(a) to the extent required by the applicable law; or

(b) with respect to ongoing or prospective legal proceedings, including in order to ascertain, exercise or defend our legal rights, or for the purposes of fraud prevention and/or reducing credit risk.

6.3  If you have an account or have provided information through this Website, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes. Visitor comments may be checked through an automated spam detection service.

We handle subject access requests in accordance with the GDPR.

Under the GDPR your rights are as follows:

(a) the right to be informed;
(b) the right of access;
(c) the right to rectification;
(d) the right to erasure;
(e) the right to restrict processing;
(f) the right to data portability;
(g) the right to object; and
(h) the right not to be subject to automated decision-making including profiling.

You also have the right to complain to the ICO (www.ico.org.uk) if you feel there is a problem with the way we are handling your data.

 

7. What data breach procedures we have in place

If there is a data breach, we commit to abiding by the GDPR regulations for informing those affected within 72 hours.

 

8. Cookies

8.1  A cookie is a file containing a string of letters and numbers that are sent by a web server to a web browser and are stored by the web browser. Such string of letters and numbers is sent back to the server each time the browser requests a page from the server. More information of cookies (types, manner of operation, etc.) is available at: https://en.wikipedia.org/wiki/HTTP_cookie.

8.2  Although, as a rule, cookies do not contain data that identifies a visitor, certain personal data that is kept about you with us may be linked to the data pertaining to the cookies.

8.3  You can delete cookies stored by your browser or you can block cookies (by the controls/settings of your web browser). Deleting cookies, blocking cookies or refusing the use of cookies may have a negative impact upon the use of many Websites. If you block or delete cookies, the functionalities of our Website will be affected, highly restricted or could even be unusable.

8.4  This Website uses Google Analytics to provide our analytics and reporting services so we can estimate our traffic and Website performance. You can opt-out of Google Analytics data collection with the Google Analytics Opt-out Browser Add-on.

 

9. Modifications

9.1  This Policy and our Terms and Conditions of Service are subject to changes with or without notice. However, be assured that if the Privacy Policy changes in the future, we will not use the personal information you have submitted to us under this policy in a way that is materially inconsistent with the existing version, without your prior consent.

9.2  You should periodically review the provisions hereof to ensure you are acquainted in detail with the Policy and Terms and Conditions of Service, including any changes thereto.

 

Last updated: 01st September 2019