Privacy policyA. Introduction1. The privacy of our website visitors is very important to us, and we arecommitted to safeguarding it. This policy explains what we do with yourpersonal information.2. Consenting to our use of cookies in accordance with the terms of this policywhen you first visit our website permits us to use cookies every time you visitour website.B. Credit1. This document was created using a template from SEQ Legal(seqlegal.com) and modified by vpnMentor (www.vpnmentor.com)C. How we collect your personal dataThe following types of personal information may be collected, stored, and used:1. Information about your computer including your IP address, geographicallocation, browser type and version, and operating system2. Information about your visits to and use of this website including thereferral source, length of visit, page views, and website navigation paths.3. Information that you enter when you register with our website, such asyour email website.4. Information that you enter when you create a profile on our website. Forexample, your name, profile pictures, gender, birthday, relationshipstatus, interests and hobbies, educational details, and employmentdetails.5. Information that you enter in order to set up subscription to our emailsand/or newsletters.6. Information that is generated while using our website, including when,how often, and under what circumstances you use it.7. Information relating to anything you purchase, services you use, ortransaction you make through our website, which includes your name,address, telephone number, email address, and credit card details.8. Information that you post to our website with the intention of publishingit on the internet.9. Any other personal information you send to us.D. Using Personal InformationPersonal information submitted to us through our website will be used for thepurposes specified in this policy or on the relevant pages of the website. We mayuse your personal information for the following:1. Administering our website and business2. Personalizing our website for you3. Enabling your use of the services available on our website4. Sending you goods purchased through our website5. Supplying services purchased through our website6. Sending statements, invoices, and payment reminders to you, andcollecting payments from you.7. Sending you on-marketing commercial communications8. Sending you email notifications you have specifically requested.9. Sending you our email newsletter if you signed up for it (you canunsubscribe at any time).10.Sending you marketing communications relating to our business or thebusinesses of third parties which we think may be of interest to you.11. Providing third parties with statistical information about our users.12. Dealing with inquiries and complaints made by or about you relating toour website13.Keeping our website secure and prevent fraud.14.Verifying compliance with the terms and conditions governing the use ofour website.15. Other uses.If you submit personal information for publication on our website, we will publishand otherwise use that information in accordance with the license you grant us.Your privacy settings can be used to limit the publication of your information on ourwebsite and can be adjusted using privacy controls on the website.We will not, without your expressed consent, supply your personal information toany third party for their or any other third party’s direct marketing.E. Disclosing personal informationWe may disclose your personal information to any of our employees, officers,insurers, professional advisers, agents, suppliers, or subcontractors as reasonablynecessary for the purposes set out in this policy.We may disclose your personal information to any member of our group ofcompanies (this means our subsidiaries, our ultimate holding company and all itssubsidiaries) as reasonably necessary for the purposes set out in this policy.We may disclose your personal information:1. to the extent that we are required to do so by law;2. in connection with any ongoing or prospective legal proceedings;3. in order to establish, exercise, or defend our legal rights (including providinginformation to others for the purposes of fraud prevention and reducingcredit risk);4. to the purchaser (or prospective purchaser) of any business or asset that weare (or are contemplating) selling; and5. to any person who we reasonably believe may apply to a court or othercompetent authority for disclosure of that personal information where, in ourreasonable opinion, such court or authority would be reasonably likely toorder disclosure of that personal information.Except as provided in this policy, we will not provide your personal information tothird parties.F. International data transfers1. Information that we collect may be stored, processed in, and transferredbetween any of the countries in which we operate in order to enable us touse the information in accordance with this policy.2. Information that we collect may be transferred to the following countrieswhich do not have data protection laws equivalent to those in force in theEuropean Economic Area: the United States of America, Russia, Japan,China, and India.3. Personal information that you publish on our website or submit forpublication on our website may be available, via the internet, around theworld. We cannot prevent the use or misuse of such information by others.4. You expressly agree to the transfers of personal information described inthis Section F.G. Retaining personal information1. This Section G sets out our data retention policies and procedure, which aredesigned to help ensure that we comply with our legal obligations regardingthe retention and deletion of personal information.2. Personal information that we process for any purpose or purposes shall notbe kept for longer than is necessary for that purpose or those purposes.3. Without prejudice to article G-2, we will usually delete personal data fallingwithin the categories set out below at the date/time set out below:a. personal data type will be deleted {ENTER DATE/TIME}; andb. {ENTER ADDITIONAL DATES/TIMES}.4. Notwithstanding the other provisions of this Section G, we will retaindocuments (including electronic documents) containing personal data:a. to the extent that we are required to do so by law;b. if we believe that the documents may be relevant to any ongoing orprospective legal proceedings; andc. in order to establish, exercise, or defend our legal rights (includingproviding information to others for the purposes of fraud preventionand reducing credit risk).H. Security of your personal information1. We will take reasonable technical and organizational precautions to preventthe loss, misuse, or alteration of your personal information.2. We will store all the personal information you provide on our secure(password- and firewall-protected) servers.3. All electronic financial transactions entered into through our website will beprotected by encryption technology.4. You acknowledge that the transmission of information over the internet isinherently insecure, and we cannot guarantee the security of data sent overthe internet.5. You are responsible for keeping the password you use for accessing ourwebsite confidential; we will not ask you for your password (except whenyou log in to our website).I. AmendmentsWe may update this policy from time to time by publishing a new version on ourwebsite. You should check this page occasionally to ensure you understand anychanges to this policy. We may notify you of changes to this policy by email orthrough the private messaging system on our website.J. Your rightsYou may instruct us to provide you with any personal information we hold aboutyou; provision of such information will be subject to the following:1. the payment of a fee {ENTER FEE IF RELEVANT}; and2. the supply of appropriate evidence of your identity ({ADJUST TEXT TOREFLECT YOUR POLICY for this purpose, we will usually accept a photocopyof your passport certified by a notary plus an original copy of a utility billshowing your current address}).We may withhold personal information that you request to the extent permitted bylaw.You may instruct us at any time not to process your personal information formarketing purposes.In practice, you will usually either expressly agree in advance to our use of yourpersonal information for marketing purposes, or we will provide you with anopportunity to opt out of the use of your personal information for marketingpurposes.K. Third party websitesOur website includes hyperlinks to, and details of, third party websites. We have nocontrol over, and are not responsible for, the privacy policies and practices of thirdparties.L. Updating informationPlease let us know if the personal information that we hold about you needs to becorrected or updated.M. CookiesOur website uses cookies. A cookie is a file containing an identifier (a string ofletters and numbers) that is sent by a web server to a web browser and is storedby the browser. The identifier is then sent back to the server each time the browserrequests a page from the server. Cookies may be either “persistent” cookies or“session” cookies: a persistent cookie will be stored by a web browser and willremain valid until its set expiry date, unless deleted by the user before the expirydate; a session cookie, on the other hand, will expire at the end of the user session,when the web browser is closed. Cookies do not typically contain any informationthat personally identifies a user, but personal information that we store about youmay be linked to the information stored in and obtained from cookies. {SELECTACCURATE PHRASING We use only session cookies / only persistent cookies / bothsession and persistent cookies on our website.}1. The names of the cookies that we use on our website, and the purposes forwhich they are used, are set out below:a. we use Google Analytics and Adwords on our website to recognize acomputer when a user {INCLUDE ALL USES THAT COOKIES ARE USEDFOR ON YOUR SITE visits the website / track users as they navigate thewebsite / enable the use of a shopping cart on the website / improve thewebsite’s usability / analyze the use of the website / administer thewebsite / prevent fraud and improve the security of the website /personalize the website for each user / target advertisements which maybe of particular interest to specific users / describe purpose(s)};2. Most browsers allow you to refuse to accept cookies—for example:a. in Internet Explorer (version 10) you can block cookies using thecookie handling override settings available by clicking “Tools,”“Internet Options,” “Privacy,” and then “Advanced”;b. in Firefox (version 24) you can block all cookies by clicking “Tools,”“Options,” “Privacy,” selecting “Use custom settings for history” fromthe drop-down menu, and unticking “Accept cookies from sites”; andc. in Chrome (version 29), you can block all cookies by accessing the“Customize and control” menu, and clicking “Settings,” “Showadvanced settings,” and “Content settings,” and then selecting “Blocksites from setting any data” under the “Cookies” heading.Blocking all cookies will have a negative impact upon the usability of manywebsites. If you block cookies, you will not be able to use all the features on ourwebsite.3. You can delete cookies already stored on your computer—for example:a. in Internet Explorer (version 10), you must manually delete cookiefiles (you can find instructions for doing soat http://support.microsoft.com/kb/278835 );b. in Firefox (version 24), you can delete cookies by clicking “Tools,”“Options,” and “Privacy”, then selecting “Use custom settings forhistory”, clicking “Show Cookies,” and then clicking “Remove AllCookies”; andc. in Chrome (version 29), you can delete all cookies by accessing the“Customize and control” menu, and clicking “Settings,” “Showadvanced settings,” and “Clear browsing data,” and then selecting“Delete cookies and other site and plug-in data” before clicking “Clearbrowsing data.”4. Deleting cookies will have a negative impact on the usability of manywebsites.
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