Responsible authority within the meaning of data protection laws, in particular the General Data Protection Regulation (GDPR): Stewart Hutton
You may request to:
- Receive confirmation as to whether or not personal information concerning you is being processed and access your stored personal information, together with supplementary information.
- Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your personal information that is in our control.
- Request erasure of your personal information.
- Object to the processing of personal information by us.
- Request to restrict processing of your personal information by us.
- Lodge a complaint with a supervisory authority.
However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the above rights or receive more information, please contact our Data Protection Officer (“DPO”) Stewart Hutton via our contact form.
We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Grounds for data collection
Processing of your personal information (i.e. any information which may potentially allow your identification through reasonable means; hereinafter “Personal Information”) is necessary for the performance of our contractual obligations towards you as a customer, and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.
What information do we collect?
We collect two types of data and information from Users.
The first type of information is unidentified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).
The second type of information is Personal Information , which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:
- Device Information: We may collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
- Contact information: When you register an account, make a purchase, or complete a form on our Site you will be asked to provide us certain details such as: full name; email or physical address, and other information.
For the avoidance of doubt, we do not process or store any financial information supplied during the online purchase of our products.
All such transactions are processed directly and securely with dedicated payment processors.
How do we receive information about you?
We receive your Personal Information from various sources:
- When you voluntarily provide us with your personal details on our Site;
- When you use or access our Site in connection with your use of our services;
- From third-party providers, services and public registers (for example, traffic analytics vendors).
How is the information used? With whom do we share the information?
We may use the information for the following:
- Supplying products you have ordered.
- Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
- To communicate with you and to keep you informed about our latest updates and services;
- To serve you advertisements when you use our Site (see more under “Advertisements”);
- To market our websites and products (see more under “Marketing”);
- For statistical and analytical purposes, intended to improve the Site.
In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.
- Hosting and operating our Site;
- Providing you with our services, including providing a personalised display of our Site;
- Storing and processing such information on our behalf;
- Serving you with advertisements and to assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
- Providing you with marketing offers and promotional materials related to our Site and services;
- Performing research, technical diagnostics or analytics;
A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help make sure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
a. ‘session cookies’ , which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
b. ‘persistent cookies’, which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
c. ‘third-party cookies’ , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
Use of script libraries (Google Web Fonts)
In order to present our contents correctly and make them graphically appealing across all browsers, we use script libraries and font libraries such as Google Web Fonts (https://www.google.com/webfonts) on this website. Google Web Fonts are transferred to your browser’s cache to avoid multiple loading. If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font.
- Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible – but currently also unclear whether and, if so, for what purposes – that operators of corresponding libraries collect data.
Third-party collection of information
How do we safeguard your information?
Transfer of data outside the EEA
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).
You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
We may use your Personal Information such as your name, email address, telephone number, etc., ourselves or by using our third-party subcontractors, for the purpose of providing you with promotional materials concerning our services which we believe may interest you.
To respect your right to privacy, within such marketing materials we provide you with the means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists.
Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow the use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at email@example.com.
How to contact us
If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us via our contact form.
Last Modified January 2019