A. Introduction
- The privacy of our website
visitors is very important to us, and we are committed to safeguarding it.
This policy explains what we will do with your personal information.
- Consenting to our use of
cookies in accordance with the terms of this policy when you first visit
our website permits us to use cookies every time you visit our website.
B.
Credit
This document was created using a template from SEQ Legal (seqlegal.com)
and modified by Website Planet (www.websiteplanet.com)
C.
Collecting personal information
The
following types of personal information may be collected, stored, and used:
- information about your computer
including your IP address, geographical 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, such as your email
address, that you enter when you register with our website;
- information that you enter when
you create a profile on our website—for example, your name, profile
pictures, gender, birthday, relationship status, interests and hobbies,
educational details, and employment details;
- information, such as your name
and email address, that you enter in order to set up subscriptions to our
emails and/or newsletters;
- information that you enter
while using the services on our website;
- information that is generated
while using our website, including when, how often, and under what
circumstances you use it;
- information relating to
anything you purchase, services you use, or transactions you make through
our website, which includes your name, address, telephone number, email
address, and credit card details;
- information that you post to
our website with the intention of publishing it on the internet, which
includes your username, profile pictures, and the content of your posts;
- information contained in any
communications that you send to us by email or through our website, including
its communication content and metadata;
- any other personal information
that you send to us.
Before you
disclose to us the personal information of another person, you must obtain that
person’s consent to both the disclosure and the processing of that personal
information in accordance with this policy
D. Using
your personal information
Personal
information submitted to us through our website will be used for the purposes
specified in this policy or on the relevant pages of the website. Wemayuseyourpersonalinformationforthefollowing:
- administering our website and
business;
- personalizing our website for you;
- enabling your use of the services available on our website;
- sending you goods purchased through our website;
- supplying services purchased
through our website;
- sending statements, invoices,
and payment reminders to you, and collecting payments from you;
- sending you non-marketing
commercial communications;
- sending you email notifications
that you have specifically requested;
- sending you our email newsletter,
if you have requested it (you can inform us at any time if you no longer
require the newsletter);
- sending you 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);
- providing third parties with
statistical information about our users (but those third parties will not
be able to identify any individual user from that information);
- dealing with inquiries and
complaints made by or about you relating to our website;
- keeping our website secure and
prevent fraud;
- verifying compliance with the terms
and conditions governing the use of our website (including monitoring
private messages sent through our website private messaging service); and
- otheruses.
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 privacy controls on the website.
We will not, without your express consent, supply your personal information to any
third party for their or any other third party’s direct marketing.
E. Disclosing 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 purchaser (or
prospective purchaser) 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.
Except as provided in this policy, we will not provide your personal information to third parties.
F. Internationaldatatransfers
- Information that we collect may be stored, processed in, and transferred between any of the countries in
which we operate in order to enable us to use the information in
accordance with this policy.
- Information that we collect may be transferred to the following countries which do not have data
protection laws equivalent to those in force in the European Economic
Area: the United States of America, 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 agree to the transfers of personal information described in this Section F.
G. Retainingpersonalinformation
- This Section G sets out our
data retention policies and procedure, which are designed to help ensure
that we comply with our legal obligations regarding the retention 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
set out below at the date/time set out below:
- personal data type will be
deleted {ENTER DATE/TIME}; and
- {ENTER ADDITIONAL DATES/TIMES}.
- 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.
Security of your personal information
- We will take reasonable technical
and organizational precautions to prevent the loss, misuse, or alteration
of your personal information.
- We will store all the personal
information you provide on our secure (password- and firewall-protected)
servers.
- All electronic financial transactions
entered into through our website will be protected by encryption
technology.
- You acknowledge that the
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 for accessing our website confidential; we will not
ask you for your password (except when you log in to our website).
I.
Amendments
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 you understand any
changes to this policy. We may notify you of changes to this policy by email or
through the private messaging system on our website.
J. Your
rights
You may
instruct us to provide you with any personal information we hold about you;
provision of such information will be subject to the following:
- the payment of a fee of CHF 100
(one hundred); and
- the supply 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
instruct us at any time 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
includes hyperlinks to, and details of, third party websites. We have no
control over, and are not responsible for, the privacy policies and practices
of third parties.
L.
Updating information
Please let
us know if the personal information that we hold about you needs to be
corrected or updated.
M.
Cookies
Our website
uses cookies. A cookie is a file containing an identifier (a string of letters
and numbers) that is sent by a web server to a web browser and is stored by the
browser. The identifier is then sent back to the server each time the browser
requests 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 will
remain valid until its set expiry date, unless deleted by the user before the
expiry date; 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 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. {SELECT ACCURATE PHRASING We use only session cookies / only persistent
cookies / both session and persistent cookies on our website.}
- The names of the cookies that
we use on our website, and the purposes for which they are used, are set
out below:
we use:
on our website to recognize a computer when a user {INCLUDE ALL USES THAT
COOKIES ARE USED FOR ON YOUR SITE 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 the security
of the website / personalize the website for each user / target
advertisements which may be of particular interest to specific users /
describe purpose(s)};
- Most browsers allow you to
refuse to accept cookies—for example:
- in Internet Explorer (version
10) you can block cookies using the cookie handling override settings
available by clicking “Tools,” “Internet Options,” “Privacy,” and then
“Advanced”;
- in Firefox (version 24) you
can block all cookies by clicking “Tools,” “Options,” “Privacy,”
selecting “Use custom settings for history” from the drop-down menu, and
unticking “Accept cookies from sites”; and
- in Chrome (version 29), you
can block all cookies by accessing the “Customize and control” menu, and
clicking “Settings,” “Show advanced settings,” and “Content settings,”
and then selecting “Block sites from setting any data” under the
“Cookies” heading.
Blocking
all cookies will have a negative impact upon the usability of many websites. If
you block cookies, you will not be able to use all the features on our website.
- You can delete cookies already
stored on your computer—for example:
- in Internet Explorer (version
10), you must manually delete cookie files (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,” and “Privacy”, then
selecting “Use custom settings for history”, clicking “Show Cookies,” and
then clicking “Remove All Cookies”; and
- in Chrome (version 29), you
can delete all cookies by accessing the “Customize and control” menu, and
clicking “Settings,” “Show advanced settings,” and “Clear browsing data,”
and then selecting “Delete cookies and other site and plug-in data”
before clicking “Clear browsing data.”
- Deleting cookies will have a
negative impact on the usability of many websites.
What is GDPR?
The General
Data Protection Regulation (GDPR) is a set of laws that was created to protect
the personal data of European Union (EU) citizens. The Council of the European
Union, European Parliament, and European Commission joined forces to help
people have better control over their personal data.
Officially
approved by European Parliament in 2016, the EU allowed a two-year grace period
for companies and organizations to comply with the new regulations. Therefore,
as of May 25, 2018, any business not complying with the new GDPR laws will be breaking
the law.
Who Is
Affected by the GDPR?
Any
business operating within the EU and any company that does business, or hopes
to do business, with citizens of the European Union must comply with the new
laws. Even companies outside the EU are affected if they offer goods or
services to citizens of the EU, and anyone who holds personal data of EU
citizens can be penalized as of May 25, 2018.
What
Sort of Data Falls under the GDPR?
Any
information classified as personal details that can be used to identify a
citizen of the EU is protected by the GDPR and includes, but is not exclusive
to, the following data:
- Name
- Photo
- Emailaddress
- Socialmediaposts
- Personalmedicalinformation
- IP addresses
- Bankdetails
Minors
cannot legally grant consent to use their personal data; therefore, parents or
guardians of children ages 16 and under must be asked for permission before a
company can use the minor’s data.