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GDPR, privacy policy

A. Introduction

  1. The privacy of our website visitors is very important to us and we are committed to protecting it. This policy explains what we do with your personal data.

  2. Your consent to the use of cookies in accordance with our terms on your first visit to our website allows us to use cookies on each of your visits to our website.

B. Acknowledgments

This document was created using a template from SEQ Legal ( and edited by Website Planet ( ).

C. Collection of Personal Information

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

  1. information about your computer, including IP address, geographic location, browser type and version, and operating system;

  2. information about your visits to and use of this website including referral source, length of visit, pages viewed and website traversal;

  3. information such as the email address you enter when registering on our website;

  4. information you enter when you create a profile on our website – for example, your name, profile pictures, gender, date of birth, status, interests and hobbies, education and occupation;

  5. information such as your name and email address that you enter when you sign up for our email services and/or newsletters;

  6. information you enter when using the services on our website;

  7. information generated when you use our website, including when, how often and under what conditions you use it;

  8. information related to your purchase, services used or transactions you make through our website, which includes your name, address, telephone number, email address and credit card details;

  9. information that you submit to our website with the intention of publishing it on the Internet, including your username, profile pictures and the content of your post;

  10. information contained in any communication you send to us by email or through the Website, including the content itself and metadata;

  11. any other personal data you send us.

Before you share another person's personal data with us, you must obtain that person's consent to the disclosure and processing of that personal data in accordance with this policy.

D. Use of Your Personal Information

Personal data provided to us through our website will be used for the purposes set out in this policy or on the relevant pages of the website. We may use your personal data for the following purposes:

  1. administering our website and business;

  2. tailoring our website to you;

  3. enabling the use of services available on our website;

  4. sending goods purchased through our website;

  5. providing services purchased through our website;

  6. sending statements, invoices, payment reminders and collecting payments;

  7. sending non-commercial commercial messages;

  8. sending you specifically requested email notifications;

  9. sending you our email newsletter if you have requested it (you can inform us at any time if you no longer require it);

  10. sending you marketing communications about our business or the business of carefully selected third parties that we think may be of interest to you by post or, if you have expressly agreed to it, by email or similar technology (you can tell us at any time if you no longer require marketing communications);

  11. providing statistical information about our users to third parties (however, such third parties will not be able to identify any individual user from this information);

  12. dealing with inquiries and complaints raised by you or otherwise relating to you in relation to our website;

  13. maintaining the security of our website and preventing fraud;

  14. verifying compliance with our website terms of use (including monitoring private messages sent through our private messaging service); and

  15. further use.

If you submit personal information for publication on our website, we will publish and use it in accordance with the license you grant us.

Your privacy settings can be used to limit the disclosure of your information on our website and can be adjusted using the privacy controls on this website.

Without your express consent, we will not provide your personal information to any third party for the purpose of direct marketing to them or any other third party.

E. Disclosure of Personal Information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, contractors 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 (ie our subsidiaries, our main holding company and any of its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

  1. to the extent we are required to do so by law;

  2. in connection with any pending or future legal proceedings;

  3. to establish, exercise or defend our legal rights (including providing information to others to prevent fraud and reduce credit risk);

  4. to a buyer (or prospective buyer) of any business or assets that we sell (or are considering selling); and

  5. to any person whom we reasonably believe may be required by a court or other competent authority to provide such personal data and if, in our opinion, such court or authority could order the disclosure of such personal data.

Except as provided in this policy, we will not provide your personal information to third parties.

F. International Data Transfers

  1. The data we collect may be stored, processed and transferred between any of the countries in which we operate in order to use it in accordance with this policy.

  2. The data we collect may be transferred to the following countries that do not have data protection laws equivalent to those in the European Economic Area: United States of America, Russia, Japan, China and India.

  3. Personal information that you post on our site or submit for publication on our site may be available worldwide via the Internet. We cannot prevent the use or misuse of this information by others.

  4. You expressly consent to the transfers of personal information described in this Section F.

G. Retention of Personal Information

  1. This Part G sets out data retention policies and procedures designed to ensure that we comply with our legal obligations regarding the retention and deletion of personal data.

  2. Personal data that we process for any purpose or purposes may not be retained for longer than is necessary for that purpose or purposes.

  3. Without prejudice to Article G 2, we delete personal data that falls into the categories below on the date and time set out below:

    1. personal data will be deleted on {ENTER DATE / TIME}; and


  4. Notwithstanding the other provisions of this Section G, we will retain documents (including electronic ones) containing personal information

      1. to the extent we are required to do so by law;

      2. if we believe the documents may be relevant to any ongoing or future legal proceedings; and

      3. to establish, exercise or defend our legal rights (including providing information to others to prevent fraud and reduce credit risk).

H. Security of Your Personal Information

  1. We will take reasonable technical and organizational measures to prevent the loss, misuse or alteration of your personal data.

  2. We store all personal data you provide on our secure servers (password and firewall protected).

  3. All electronic financial transactions entered through our website will be encrypted.

  4. 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.

  5. You are responsible for maintaining the confidentiality of the password you use to access our website; we will not ask you for your password (except when you log in to our website).

I. Changes

We may update this policy from time to time by posting a new version on our website. You should check this page occasionally to make sure you understand any changes to this policy. We may notify you of changes to this policy by email or through private messages on our website.

J. Your Rights

You can direct us to provide you with any personal information we hold about you. The provision of such information shall be subject to the following:

  1. payment of a fee {ENTER FEE IF RELEVANT}; and

  2. presenting relevant proof of your identity ({ADJUST TEXT TO REFLECT YOUR POLICY for this purpose we usually accept a notarized photocopy of your passport and an original copy of your utility bill showing your current address}).

To the extent permitted by law, we may refuse to provide the personal data you request.

You can at any time instruct us not to process your personal data for marketing purposes.

In practice, you will usually either expressly consent in advance to how we use your personal data for marketing purposes, or we will offer you the option to opt-out of the use of your personal data for marketing purposes.

K. Third Party Websites

Our website contains 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. Data Update

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

M. Cookie files

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 stored by the web browser. This identifier is then sent back to the server whenever the browser requests a page from the server. Cookies can be either "persistent" or "session". Persistent cookies will be stored by the web browser and remain valid until their expiration date, unless deleted by the user before the expiration date. Session cookies, on the other hand, expire at the end of the user's session after closing the web browser. Cookies normally do not contain any information that would uniquely identify the user, but the personal data we store about you may be linked to the information stored and obtained from the cookies.

  1. The names of the cookies we use on our website and the reasons for their use are listed below:

    1. On our website we use Google Analytics and Adwords to recognize the computer and {INCLUDE ALL USES THAT COOKIES ARE USED FOR ON YOUR SITE when the user visits the website / tracking the user's movement on our website / enabling the use of the shopping cart on the website / improving the usability of the website pages / website usage analysis / website management / fraud prevention and website security improvement / website customization for each user / targeted advertising, according to the individual interests of specific users / describe the reason(s)};

  2. Most browsers allow you to refuse to accept cookies - for example:

    1. in Internet Explorer (version 10) you can block cookies by changing the cookie settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";

    2. in Firefox (Version 24), you can block all cookies by clicking "Tools", "Options", "Privacy", then in the drop-down menu, select "Use custom history settings" and uncheck "Accept cookies from websites"; and

    3. in Chrome (version 29) you can block all cookies in the "Customization and control" menu, where you click on "Settings", "Show advanced settings" and "Content settings" and then under the heading "Cookies" select "Block websites from setting any data".

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

  1. You can delete cookies already stored on your computer - for example:

    1. in Internet Explorer (version 10), you must delete cookies manually (instructions on how to do this can be found here: );

    2. in Firefox (Version 24) you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom history settings", clicking "Show cookies" and then clicking "Delete all cookies" ; and

    3. in Chrome (version 29) you can delete all cookies in the "Customization and control" menu, where you click on "Settings", "Show advanced settings" and "Clear browser data" and before clicking on "Clear browser data", select "Delete cookies and other site data and extensions".

  2. Deleting cookies will have a negative impact on the usability of many websites.

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