Privacy Policy

 

A. Introduction

  1. The privacy of visitors to our website is extremely important to us and we are committed to protecting it. This policy explains what we do with your personal data.
  2. When you consent to our use of cookies in accordance with the terms of this policy on your first visit to our website, you grant us permission to use cookies each time you visit our website.

 

B. Collection of personal data

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

  1. information about your computer, including IP address, geographical location, browser type and version, as well as operating system;
  2. information about your visits to and use of this website, including referring page, length of visit, page views and website navigation;
  3. information that you provide when you register on our website, such as your email address;
  4. information that you provide when you create a profile on our website, such as your name, gender, marital status, your date of birth, your profile pictures, interests, hobbies and information about your education and employment;
  5. information that you provide in order to subscribe to our emails and/or newsletter, such as your name and your email address;
  6. information that you provide when you use services on our website;
  7. information that is generated when you use our website, including when, how often and in what ways you use it;
  8. information relating to everything you purchase, the services you use or transactions you carry out via our website, including your name, telephone number, your address, email address and your credit card details;
  9. information that you publish on our website with the intention of publishing it on the internet, including your username, your profile pictures and the content of your posts;
  10. information in all forms of communication that you send to us by email or via our website, including its content and metadata;
  11. all other personal information that you submit to us.

Before you provide us with someone else’s personal data, you must have that person’s consent to their personal data being disclosed and processed in accordance with this policy.

 

C. Use of your personal data

Personal data that is submitted to us via 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 data for the following purposes:

  1. to administer our website and business;
  2. to tailor our website to your needs;
  3. to enable you to use the services that are available on our website;
  4. to send products to you that you have purchased via our website;
  5. to provide services purchased via our website;
  6. to send statements of account, invoices and payment reminders to you and to collect payments from you;
  7. to send commercial communication other than for marketing purposes;
  8. to send emails that you have specifically requested;
  9. to send our newsletter to you by email if you have requested this (you can notify us at any time if you no longer wish to receive the newsletter);
  10. to send marketing communications to you relating to our business, or to that of carefully selected third parties, which we believe may be of interest to you, by post or, where you have specifically consented to this, by email or similar technology (you can notify us at any time if you no longer wish to receive marketing communications);
  11. to provide third parties with statistical information about our users (such third parties will not, however, be able to identify an individual user from this information);
  12. to handle enquiries and complaints from or about you in relation to our website;
  13. to keep our website secure and to prevent fraud;
  14. to confirm your consent to the terms of use of our website (including monitoring private messages sent via our website’s private messaging service); and
  15. other use.

If you submit personal data for publication on our website, we will publish and otherwise use such data in accordance with the consent you have given to us.

Your privacy settings can be used to restrict the publication of your data on our website and can be adjusted using the website’s privacy controls.

We will not disclose your personal data to any third party for their direct marketing or for the direct marketing of any other third party without your express consent.

 

D. Disclosure of personal data

We may disclose your personal data to any of our employees, board members, insurers, professional advisers, agents, suppliers or subcontractors as may be reasonably necessary for the purposes stated in this policy.

We may disclose your personal data to all members of our corporate group (this includes our subsidiaries, our holding company and all its subsidiaries) as may be reasonably necessary for the purposes stated in this policy.

We may disclose your personal data:

  1. to the extent we have a legal obligation to do so;
  2. in connection with ongoing or future court proceedings;
  3. in order to establish, assert or defend our legal rights (including disclosing information to others for the purpose of preventing fraud and reducing credit risk);
  4. to the purchaser (or the prospective purchaser) of all companies or assets that we are in the process of (or are considering) selling; and
  5. to all persons that we reasonably consider able to request that a court or other competent authority instructs us to disclose the personal data if, in our reasonable opinion, such a court or competent authority would instruct us to disclose such personal data.

We will not disclose your personal data to a third party except in those cases stated in this policy.

 

E. International data transfer

  1. Data that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the data in accordance with this policy.
  2. The data that we collect may be transferred to the following countries, which do not have data protection legislation equivalent to that which applies in the European Economic Area: USA, Russia, Japan, China and India.
  3. Personal data that you publish on our website or submit for publication on our website may be accessible worldwide via the internet. We cannot prevent such data being used or misused by others.
  4. You give your express consent to the transfer of personal data as described in this section E.

 

F. Retention of personal data

  1. This section F describes our policies and procedures for data storage, which are designed to ensure that we fulfil our legal obligations in relation to the storage and erasure of personal data.
  2. Personal data that we process for any purpose or purposes will not be stored for longer than is necessary for such purpose or purposes.
  3. Notwithstanding section F-2, we will usually erase personal data that falls within the following categories on the date and at the time indicated below:
    1. category of personal data will not be erased unless requested by the customer.
  4. Notwithstanding other provisions of this section F, we will retain documents (including electronic documents) that contain personal data:
    1. to the extent we have a legal obligation to do so;
    2. if we believe that the documents may be relevant to ongoing or future court proceedings; and
    3. in order to establish, assert or defend our legal rights (including disclosing information to others for the purpose of preventing fraud and reducing credit risk).

 

G. Security of your personal data

  1. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal data.
  2. We will store all personal data that you provide on our secure (password- and firewall-protected) servers.
  3. All electronic financial transactions made via our website are protected using encryption technology.
  4. You acknowledge that the transfer of data via the internet is inherently insecure and we are unable to guarantee the security of data that is sent via the internet.
  5. You are responsible for keeping confidential the password that you use to access our website; we will not ask you for your password (except when you are logging in to our website).

 

H. Changes

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

 

I. Your rights

You can ask us to provide you with all the personal data that we hold about you; the provision of such data will be subject to the following:

  1. The production of acceptable proof of your identity (for this purpose, we normally accept a photocopy of your passport that has been certified by a notary, plus a copy of a utility bill showing your current address).

 

We may withhold the personal data you request as permitted by law.

You can request at any time that we do not process your personal data for marketing purposes.

In practice, you will normally either explicitly accept our use of your personal data for marketing purposes or we will give you the opportunity to reject the use of your personal data for marketing purposes.

 

J. Third-party websites

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

 

K. Updating your data

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

 

L. Cookies

Our website uses cookies. A cookie is a file that contains an identifier (a string of letters and numbers) that is sent by a web server to a browser and is stored by the browser. The identifier is then sent back to the server every time the browser requests a page from the server. Cookies can be either “persistent cookies” or “session cookies”: a persistent cookie is stored by a browser and remains valid until the specified expiry date, unless it is deleted by the user before the expiry date; a session cookie, on the other hand, expires at the end of the user session, when the browser is closed. Cookies do not usually contain data that personally identifies a user, but personal data that we store about you can be linked to the data that is stored in and received from cookies. We use both persistent and session cookies on our website.

  1. Below are the names of the cookies we use on our website and the purposes for which they are used:
    1. We use Google Analytics and Adwords on our website in order to recognise a computer when a user visits the website / track users as they browse the website / enable the use of a shopping basket on the website / improve the functionality of the website / analyse the use of the website / administrate the website / prevent fraud and improve the security of the website / adapt the website for each user / display targeted advertising that may be of particular interest to specific users.
  2. Most browsers allow you to refuse to accept cookies – for example:
    1. in Internet Explorer (version 10) you can block cookies using the settings to cancel cookie management by clicking “Tools”, “Internet options”, “Privacy” and then “Advanced”;
    2. in Firefox (version 24) you can block all cookies by clicking “Tools”, “Settings”, “Privacy & security”, selecting “Customised content blocking” and clicking “All cookies”; and
    3. in Chrome (version 29), you can block all cookies by opening the “Settings” menu and clicking “Website settings” under “Privacy and security” and then deselecting “Allow websites to store and read cookie data”.

 

If you block all cookies, this will have a negative impact on the functionality of many websites. If you block cookies, you will not be able to use all the functions on our website.

  1. You can remove cookies that have already been stored on your computer – for example:
    1. in Internet Explorer (version 10) you have to remove cookies manually (you can find instructions on how to do this at http://support.microsoft.com/kb/278835);
    2. in Firefox (version 24) you can remove cookies by clicking “Tools”, “Settings”, “Privacy & security” and then selecting “Delete data” under “Cookies and website data”; and
    3. in Chrome (version 29) you can remove all cookies by opening the “Settings” menu and clicking “Delete web data” under “Privacy and security”.
    4. If you remove cookies, this will have a negative impact on the functionality of many websites.