Oct 15 2019
1. Information We Collect:
When you interact with us through the Site and use Company Services, we may collect Personal Data and other information from you, as further described below:
- Interaction with our Site: When you interact with Company through the Site, we receive and store certain Personal Data. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Company may store such information itself or such information may be included in databases owned and maintained by Company affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process. For further details please see the section on “Cookies” below.
- Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Company Services, Company often conducts research on its customer and user demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Company may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Company may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
2. Our Use of Your Personal Data and Other Information:
We process the Personal Data you provide to us to enable us to perform the contract we are about to enter into or have entered into with you, to ensure compliance with local legal and regulatory requirements and for the purposes of our legitimate business interests, including:
- to enable us to carry out our obligations arising from any contracts and to provide you with the information, products and services that you request from us;
- to enable us to respond to an enquiry or other request you make when you contact us via our Site or mobile application, including for customer services support;
- to notify you about any changes to Company Services;
- to enable us to issue a notice or corrective action to you in relation to any of the Company Services, if required;
- to help us improve the content and functionality of the Site and Company Services, and to better understand how you use our Services;
- to provide you with information about other services which we believe will be of interest to you similar to those that you have already purchased or enquired about, as described in the “Marketing” section below.
In operating this Site, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. [We use various types of cookies, including session cookies, persistent cookies, local shared objects, pixels, gifs and other tracking technologies, session and persistent technologies, first and third-party cookies. Cookies can be persistent by remaining on your computer until you delete them or be based on your browsing session where they delete once you close your browser. First party cookies are used and controlled by us to provide services on our Site.]
- Strictly necessary cookies: these are essential in order to enable you to move around our Site and use its features. Without these cookies, the services you have asked for cannot be provided.
- Performance cookies: also known as “analytical” cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our site. For example, they allow us to understand which pages are visited most often, and if they get error messages from web pages. All information collected by these cookies is aggregated and therefore anonymous.
Strictly necessary cookies are necessary to provide the Site to you. We use such cookies without your prior consent. All other cookies are dropped after you have consented via a cookie banner.
(b) Opting out of Cookies
You have the ability to accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Detailed instructions are provided by your browser. If you do not accept all cookies or withdraw your consent, you may still browse the Site; however, in this case you may not be able to use the full functionalities of the Site.
Company and its subsidiaries and affiliates (the “Company Related Companies”) may also use your Personal Data to contact you in the future to tell you about services we believe will be of interest to you.
If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
5. Our Disclosure of Your Personal Data and Other Information
Company is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
- Agents, Consultants and Related Third Parties: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include hosting our Company Services, mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
- Legal Requirements: Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
6. Storing your Personal Data
Your Personal Data collected via our Site and through our Company Services will be stored on servers located in the United States. This includes by individuals or service providers engaged in, among other things, administration of an enquiry or request you make via our Site, or the provision of support services.
For individuals based in the European Economic Area (“EEA”): we rely on our EU-U.S. and Swiss-U.S. Privacy Shield certification to transfer Personal Data that we receive from the EU and Switzerland to Company in the U.S. (for more information, please read the “Privacy Shield” section below).
7. Privacy Shield
- General. We rely on our Privacy Shield certification to transfer Personal Data that we receive from the EU and Switzerland to HqO in the U.S. and Switzerland to Company in the U.S. and we process such Personal Data in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (“Privacy Shield Principles”), as described below. We commit to treat personal data transfers from the United Kingdom to Hq0 in the U.S. subject to our Privacy Shield certification.
- Accountability for Onward Transfers. We may be accountable for the Personal Data we receive under the Privacy Shield that we may transfer to third-party service providers (described in the section “How We Share and Disclose Personal Data” above). If such service providers process Personal Data in a manner inconsistent with the Privacy Shield Principles, we are responsible for the harm caused.
- Access. EU users have certain rights to access, correct, amend, or delete Personal Data where it is inaccurate, or has been processed in violation of the Privacy Shield Principles. Please see the “Your Rights” section above for more information on the rights of users in the EU (and, to the extent applicable, users in Switzerland).
- Recourse, Enforcement, Liability. In compliance with the Privacy Shield Principles, Company commits to resolve complaints about our processing of your Personal Data. EU and Swiss users with inquiries or complaints regarding this Privacy Shield Policy should first contact Company at: [email protected].
We have further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution (free of charge) at https://feedback-form.truste.com/watchdog/request.
If your complaint is not resolved through these channels, under certain conditions a binding arbitration option may be available before a Privacy Shield Panel. For additional information, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to Personal Data received or transferred pursuant to the Frameworks.
To learn more about our processing activities, please see our records.
8. Data Retention
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorised 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.
11. Links to Other Web Sites
12. Our policy on Do Not Track Signals
Company takes reasonable steps to protect the Personal Data provided via the Site and Company Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from this Site may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to Company.
14. Other Terms and Conditions
16. Your Rights
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via this Site.
For individuals based in the EEA: You may have the right to: request (a) access the to your Personal Data we hold about you; (b) request we correct any inaccurate Personal Data we hold about you; (c) request we delete any Personal Data we hold about you; (d) restrict the processing of Personal Data we hold about you; (e) object to the processing of Personal Data we hold about you; and/or (f) receive any Personal Data we hold about you in a structured and commonly used machine-readable format or have such Personal Data transmitted to another company.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you. We will process any request in line with any local laws and our policies and procedures. If you are located in the EEA, you have the right to lodge a complaint about how we process your personal information with the supervisory authority in your country.
If you wish to exercise any of your rights, please contact us using the information provide in the “Contact Us” section below.
17. Your California Privacy Rights
Applicable California privacy legislation permits visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request to access such information, please contact us as follows: email to [email protected]. Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
18. Contact Us