“Personal Information” or “Personal Data” is an information that identifies or can be used to identify, contact, or locate the person to whom such information pertains.
The definition "processing" refers herein to the handling of your Personal Data by us, including collecting, protecting and storing your Personal Data.
We are fully committed to respecting privacy and to protecting any information that our users provide. Your privacy and security are both our highest priorities and we make every effort to ensure that all the information provided by you is protected.
- PERSONAL INFORMATION WHICH WE MAY COLLECT
- Personal Information, that we collect and process from Visitors:
- Technical information, which we may collect through automated means. Through your use of the Website and Services, we monitor and collect tracking information related to usage such as IP (Internet Protocol) address, language preference, country, information about hiding of banners, the “remember me” function during the authorization, information that helps us not to provide you repeated data, information about viewing of posters on our Website, analytics information, access date, time and location, browser plug-in types and versions, mobile phone network information, device identification, information that helps us to receive payment from you, operating system, browser type and version. This information may be directly obtained by the Company or through third party services;
- Consents, including any permissions, consents or preferences that you give to the Website.
- In case you decide to share with us some other Personal Information and we may collect it as well.
- Personal Information, that we collect and process from Members:
- All Personal Information that we collect from Visitors in accordance with cl. 2.2. of the Policy;
- Identity and contact Personal Information, including your email address, username and password;
- Information, that you can add to your Account such as your favorite content, subscription status;
- Marketing Data, including preferences in receiving marketing from us and third-parties;
- Technical information such as the information about the current session of the Member; and
- Communications, including communication provided by you in comment section and information on how and what methods we use in order to communicate with you through electronic and verbal correspondence.
- We may also collect, use and share aggregated data such as statistical or demographic data for the purpose of customizing our marketing efforts or the use of our Website. Aggregated data may be derived from your Personal Data but is not considered Personal Data as this data does not directly or indirectly reveal your identity.
- WHO WE ARE
- The Personal Information on the Website is collected, controlled and processed by the
- WAYS OF COLLECTING YOUR PERSONAL data, failure to provide PERSONAL data
- As a general rule we obtain your Personal Data through any information you provide directly to us via our Website. However, we also use other indirect methods to collect Your Personal Information while you use our Website and/or Services. Below is a list of ways we collect your Personal Data:
- when you visit and/or use our Website;
- when you complete the registration steps in order to create an account;
- you also provide Personal Information indirectly when you navigate the Website, as Personal Information about you is automatically observed and collected;
- when you contact us via the Website, email, comments or otherwise.
- Where we need to collect and process your Personal Data in order to provide you with our services and you fail to provide that data when requested, we may not be able to provide you with access to our Website and/or the services we offer. In this case, we may have to suspend your access to the Website or, if you are a Member, prohibit any access to non-public areas of the Website or restrict the operation of your account and the services we provide to you.
- Policy towards minors
- We do not intend to solicit or collect Personal Information from anyone under the age of 18 or under the legal age of your country, if it is higher. If you are under 18 or are not of a legal age of your country, do not enter any Personal Information on our Website and leave our Website. If we become aware that a minor has provided us with Personal Data, we will take steps to remove such data and terminate that person's account immediately (if such account was created). We encourage you to contact us via email@example.com if you become aware that minor provided us with Personal Information.
- Purposes for Which We Use Your Personal Information
- We will collect, process store and use Personal Information for providing you with our lawful services and make available all functionality of the Website in accordance with this Policy. In brief, we have the following legal basis under the GDPR and other applicable EU laws for processing your Personal Data:
- We process Personal Data for the purposes of providing the services, functionality and security because the processing is necessary to provide the services you have requested via the Website, or to provide our Website and services in a manner consistent with our terms and conditions of use and any other contract that you have with us;
- We process Personal Data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- We process Personal Data where such processing is necessary for us to comply with a legal or regulatory obligation;
- We process Personal Data in specific circumstances where you have provided your consent to such processing.
- Please find below this legal basis and circumstances in further detail.
- Performance of our services to you
- Provision of services
We may collect and process your Personal Data where it is necessary in order to present our Website and its contents to you, including any interactive features on our Website and to provide you with information or services that you request from us.
Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide you with the services we provide to our Members.
- Customer management (Members Only)
We may use identifiers, contact information and any other types of Personal Information to manage your account, to provide customer support and notices to you about your account, including expiration and renewal notices, and notices about changes to our Website or any products or services we offer or provide through it
- Legitimate interests
- Customization of content (Members Only)
We may collect and process your Personal Data where it is necessary in order to perform research and analysis about your use or, or interest in, our Website content and/or services, so as to develop and display content and advertising tailored to your interests on our Website.
We may collect and process your Personal Data where it is necessary in order to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed and demographic patterns.
- Functionality and security
We may collect and process your Personal Data where it is necessary in order to diagnose or fix technology problems, and to detect, prevent and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
- Other legitimate interests
In addition to the above, we may process your Personal Data, to the extent required for our business needs in order to:
- develop new services on our Website as well as analyze and target new markets;
- protect our legal rights and interests (including legal claims and preparing our defense in litigation);
- monitor, maintain and improve internal business processes, information and data, technology and communication solutions and services;
- ensure network information security, including monitoring Visitors' and Members’ access to our information technology for the purpose of preventing cyber-attacks, unauthorized use of Website and prevention or detection of crime;
- send you relevant marketing information (including details of other services provided by us which we believe may be of interest to you), but only where you are a Member of the Website;
- monitor the performance and effectiveness of our services and the Website; and
- assess the quality of our customer services.
- For compliance with legal obligations
When you visit and/or use and/or register in our Website (and throughout your relationship with us), we are required to comply with certain legal and regulatory obligations which may involve the processing of your Personal Data. This may include processing to:
- perform checks and comply with laws relating to fraud;
- manage contentious regulatory matters, investigations and litigation.
- You have provided your consent
We will only ask for your consent when we wish to provide marketing information to you in relation to our services which we believe may be of interest and of benefit to you.
You have the right to revoke your consent at any time. However, any processing of Personal Data prior to the receipt of your revocation will not be affected.
- Disclosure and share of your personal data
- In certain situations, We may be required to disclose Personal Information in response to lawful requests by competent authorities, including to meet national security, public interests or law enforcement requirements.
- We may disclose your Personal Information where required by law (e.g., to comply with a subpoena, warrant, court order, or legal process served on the Company), and when we believe that disclosure is necessary to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms and conditions of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of our Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
- We may disclose all of the categories of Personal Information we collect to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.
- We may share Personal Information with certain companies that perform services on our behalf on a need-to-know basis. We require any company with which we may share Personal Information to protect that data in a manner consistent with this policy and to limit the use of such Personal Information to the performance of services for the Company.
- You agree that We may share and transfer Your information which no longer identifies You to the third party (pseudonymisation) who is a contracting party with Us, usually Our service providers or advertising partners. This information does not contain any Personal Data and may be used to develop content and services that we hope you and other users will find of interest.
- Please note that we have never sold and will never sell your Personal Data to third parties.
- SECURITY MEASURES
- The Company aims to protect your Personal Information as much as we aim to protect our own confidential information and network. We do not sell, trade, or rent your personal identification information to others. You should never disclose your account password to unauthorized parties.
- We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your Personal Data from unauthorized access and disclosure. For instance, only authorized employees are permitted to access Personal Data, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Data between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Data. However we cannot guarantee that these measures will stop any users try to get around the privacy or security settings on the Website through unforeseen and/or illegal activity. That is why we make no warranty, express, implied or otherwise, that we will prevent such access.
- You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
- data retention
- We will retain your information only for as long as is necessary for the purposes set out in this policy. We will retain your information just to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
- To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- If you have questions about our data retention practices, please contact us electronically by sending as an email at firstname.lastname@example.org.
- Transfers of Your Personal Information to Other Countries
- We may additionally, in rare occasions, transfer your Personal Data to a party outside the EEA where we have your prior explicit consent to do so or where such transfer is necessary for the provision of our services to you.
- Marketing information
- We may process your Personal Data so as to inform you about existing and/or future services that may be of interest to you by sending you periodic announcements with details on existing and/or new services and/or programs.
- You have the right to object at any time to the processing of your Personal Data for marketing purposes.
- We can only use your Personal Data to promote our services to you if we have your explicit consent to do so, or in certain cases such as for example when you are a Member of our Website, if we consider that it is in our legitimate interest to do so. You may also occasionally receive marketing communications from our affiliates, but only provided you have given your explicit consent in receiving such communications.
- Even if you inform us that you no longer wish to receive marketing material, you will still receive from us system notices and other information specifically related to your account from time to time.
- Your rights related to your personal data
- In accordance with effective regulations You have a significant number of rights related to your Personal Information, such as e.g.:
- The right to access and amend the Personal Information we hold about you. You have a right to request a copy of the Personal Information we hold about you.
- You have the right to correct or update your Personal Information at any time.
- The right to delete your Personal Information. In accordance with the "Right to be forgotten", we leave the opportunity to erase Personal Information about you. If you do not want to use Website or want your data to be erased, you can request us to erase your Personal Information permanently. In this case, the Company will cancel your account (if you are a Member) and delete your Personal Data subject to erasure.
- The right to restrict processing. You have the right to ask us to restrict the processing of your Personal Information. When processing is restricted, we can still store your information, but will not use it further. This enables you to ask us to restrict the processing of your Personal Data if:
- it is not accurate; or
- it has been used unlawfully but you do not want us to delete it; or
- it is not relevant any more, but you want us to keep it for use in possible legal claims; or
- you have already asked us to stop using your Personal Data but you are waiting for us to confirm if we have legitimate grounds to use your Personal Data.
- The right to object to the processing of your data. You have a right to object to our use of your Personal Information for our own purpose at any time. In other words you can withdraw your consent to processing your Personal Information by us. In case you want to exercise this right, you may contact us. This right also includes the right to object to processing your Personal Information for marketing and advertising purposes. You can do it by clicking on the special button (an unsubscribe button) or by contact us and opting out from receiving all e-mails. If you exercise your right to object, we will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedom or for the establishment, exercise and defense of legal claims.
- The right to data portability. You have the right to receive Personal Information you provide to us, in a "commonly used machine-readable format". This allows you to obtain and reuse your information for your own purposes across different services.
- In case you want to exercise your rights, please contact us.
- Please note that some requests to delete certain Personal Data will require the deletion of your account as a Member as the provision of Member accounts is inextricably linked to the use of certain Personal Data (e.g. your email address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.
- There are exceptions to these rights, however. For example, access to Personal Information may be denied in some circumstances if making the information available would reveal Personal Information about another person or if we are legally prevented from disclosing such information. In addition, where some of the data is necessary to maintain the Company or where that is a legal requirement, we may retain such data for the period it is needed or required even if you withdraw your consent or cancel your account. Such information will not be considered as subject to erasure.
- Contact us
- California Consumer Privacy Act Notice
- As of January 1, 2020, the California Consumer Privacy Act of 2018 ("CCPA") provides California residents ("Consumer(s)") certain rights with respect to their Personal Information, as this term is defined under the CCPA. In addition to the rights we state under this policy and subject to the exceptions found under the CCPA, Consumers have the right to:
- opt-out of the sale of their Personal Information, should we sell their Personal Information;
- be informed of certain information concerning our collection and use of their Personal Information;
- request that we delete certain Personal Information we collected from them;
- appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
- not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.
- The Company does not sell nor has it sold in the past 12 months Personal Information to third parties for monetary or other valuable considerations. We may however disclose certain Personal Information with third parties, service providers and entities within our corporate group in order to enable them to perform certain services on our behalf and namely to make the Website work properly. Regardless, we respect the California residents' right to exclude Personal Information from such sharing arrangements and to thereby opt-out of any future sale of their Personal Information. If the CCPA is applicable to you and you would like to record such preference, please send us an email at email@example.com.
- LAW AND HARM
- Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our users’ rights or property. However, nothing in this Policy is intended to limit any legal defences or objections that you may have to a government’s request for disclosure of your information.
- Third-party links
- CHANGES TO POLICY
- This Policy may be amended at our full discretion without prior notice. We encourage you to review it periodically in order to be aware of the changes we may have made. Reading it carefully and checking for any modifications is your responsibility. By using the Website, you accept and agree to the Policy and the Terms and Conditions of Use.
- Cookies POLICY
- As we have briefly mentioned in this Policy, our Website uses small files known as cookies to make it work better in order to improve your experience.