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 first visit our website, you allow us to use cookies every time you visit our website.

B. Acknowledgement

This document was created using a template from SEQ Legal (seqlegal.com)

C. Collection of personal information

The following types of personal information may be collected, stored, and used:

• information about your computer, including your IP address, geographic location, browser type and version, and operating system;
• information about your visits to and use of this website, including the referral source, length of visit, page views, and website navigation paths;
• information that you provide when you register with our website, such as your email address;
• information that you provide when you create a profile on our website, such as your name;
• information that you provide when you subscribe to our email newsletters and/or marketing communications, such as your name and email address;
• information that you provide when you use our website's services;
• information generated when you use our website, including when, how often, and under what circumstances you use it;
• information relating to anything you purchase, the services you use, or transactions you make through our website, including your name, phone number, address, email address;
• information contained in any communication that you send to us by email or through our website, including its content and metadata;
• any other personal information that you send to us.

Before you disclose another person's personal information to us, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

D. Use of your personal information

Personal information submitted to us through our website will be used for the purposes stated 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 business; to personalize our website for you; to enable you to use the services available on our website; to send goods purchased via our website to you; to deliver services purchased via our website; to send statements, invoices, and payment reminders to you and collect payments from you; to send non-marketing commercial communications; to send email notifications that you have specifically requested; to send our newsletter by email to you if you have requested it (you can inform us at any time if you no longer require the newsletter); to send marketing communications relating to our business or the businesses of carefully-selected third parties which 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 those third parties will not be able to identify any individual user from that information); to deal with inquiries and complaints made by or about you relating to our website; to keep our website secure and prevent fraud; to confirm your consent to our website's terms of use; 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 license you grant to 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, without your express consent, provide your personal information to any third parties for the purpose of direct marketing by them or any other third parties.

E. Disclosure of personal information

We may disclose your personal information to any of our employees, officers, 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 ultimate holding company, and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to the buyer (or prospective buyer) of any business or asset that we are (or are contemplating) selling; and to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information. We will not disclose your personal information to third parties except as provided for in this policy.

F. International data transfer

Information that we collect may be stored, processed, and transferred between any of the countries in which we operate to enable us to use the information in accordance with this policy. Information that we collect may be transferred to the following countries that do not have data protection laws equivalent to those in the European Economic Area: USA, Russia, Japan, China, and India. Personal information that you publish on our website or submit for publication on our website may be available via the internet around the world. We cannot prevent the use or misuse of such information by others. You expressly consent to the transfer of personal information described in this section F. 

G. Retention of personal information

This section G describes our policies and procedures for data retention, which are designed to ensure that we comply with our legal obligations regarding the storage and deletion of personal information. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Without prejudice to article G-2, we will usually delete personal data falling within the categories below at the date and time specified:

type of personal data will be deleted every 5 years;

Notwithstanding the other provisions of this section G, we will retain documents (including electronic documents) containing personal data:

to the extent that we are required to do so by law; if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

H. Your Personal Information Security

We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. We will store all 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 transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over 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). I. Changes

We may update this policy from time to time by posting a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through our website's private messaging system.

J. Your Rights

You may ask us to provide you with any personal information we hold about you; provision of such information will be subject to the following:

payment of a fee; and provision of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a notary plus an original copy of a utility bill showing your current address). We may withhold personal information that you request to the extent permitted by law.

You may at any time ask us not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.

K. Third-Party Websites

Our website contains hyperlinks to and details of third-party websites. We have no control over, and are not responsible for, third-party privacy policies and practices.

L. Updating Information

Please let us know if the personal information we hold about you needs to be corrected or updated.

M. Cookies

Our website uses cookies. A cookie is a file that contains an identifier (a string of letters and numbers) sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can either be "persistent cookies" or "session cookies": a persistent cookie is stored by a browser and remains valid until its 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 typically 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 both persistent and session cookies on our website.

Below are the names of the cookies we use on our website and the purposes they are used for: we use Google Analytics and Adwords on our website to recognize a computer when a user visits the website / track users as they navigate the website / enable the use of a shopping cart on the website / improve the website's usability / analyze the use of the website / administer the website / prevent fraud and improve website security / customize the website for each user / target ads to specific users; Most web browsers allow you to refuse cookies – for example: in Internet Explorer (version 10) you can block cookies using the cookie handling override settings by clicking "Tools", "Internet Options", "Privacy" and then "Advanced"; in Firefox (version 24) you can block all cookies by clicking "Tools", "Options", "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 "Site settings" under "Privacy and security" and then unchecking "Allow sites to save and read cookie data". If you block all cookies, it will have a negative impact on many websites' usability. If you block cookies, you will not be able to use all the features on our website.

You can delete cookies that are already 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", "Options", "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 "Clear browsing data" under "Privacy and security". Deleting cookies will have a negative impact on many websites' usability.