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A. Introduction

  1. The privacy of visitors to our website is very important to us, and we are committed to protecting it. This policy details what we do with your personal information.
  2. Consenting to our use of cookies in accordance with this policy during your first visit to our website allows us to use cookies each time you visit our site.

B. Source

This document was created using a SEQ Legal template (seqlegal.com).

C. Collection of Personal Information

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

  1. Information about your computer, including your IP address, geographical location, the type and version of your browser, and your operating system;
  2. Information about your visits to and use of this website including the referral source, length of visit, page views, and web navigation paths;
  3. Information like your email address, which you provide to us when you register on the site;
  4. Information you enter when you create a profile on our website such as your name, profile picture, gender, date of birth, relationship status, interests and hobbies, educational background, and work history;
  5. Information such as your name and email address, which you enter to subscribe to our emails and/or newsletters;
  6. Information you enter when you use the services of our website;
  7. Information generated when using our site, including when, how often, and under what circumstances you use it;
  8. Information relating to purchases you make, services you use, or transactions you engage in on our site, which includes your name, address, phone number, email address, and bank details;
  9. Information you post on our website with the intention of publishing it on the internet, which includes your identifier, profile pictures, and the content of your posts;
  10. Information contained in any communications you send to us by email or through our website, including their content and metadata;
  11. Any other personal information you provide to us.

Before disclosing personal information about another person, you must obtain that person’s consent regarding the disclosure and processing of that personal information in accordance with the terms of this policy.

D. Use of Your Personal Information

The personal information provided to us through our website will be used for the purposes described in this policy or in the relevant pages of the site. We may use your personal information to:

  1. Administer our website and our business;
  2. Personalize our website for you;
  3. Enable your use of the services available on our website;
  4. Send you the goods purchased on our site;
  5. Provide you with the services purchased on our site;
  6. Send you statements, invoices and payment reminders, and collect your payments;
  7. Send you non-marketing commercial communications;
  8. Send you email notifications that you have specifically requested;
  9. Send you our newsletter by email, if you have requested it (you can inform us at any time if you no longer wish to receive our newsletter);
  10. Send you marketing communications relating to our business or carefully selected third-party businesses that we think may be of interest to you, in the form of publication, or if you have expressly consented, by email or similar technology (you can inform us at any time if you no longer wish to receive marketing communications);
  11. Provide statistical information about our users to third parties (without those third parties being able to identify any individual user with that information);
  12. Handle inquiries and complaints relating to our website made by you or about you;
  13. Maintain the security of our website and prevent fraud;
  14. Verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through the private messaging service of our website); and
  15. Other uses.

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

Your privacy settings can be used to limit the publication of your information on our website and can be adjusted in your privacy settings on the website.

Without your explicit consent, we will not provide your personal information to third parties for their direct marketing, or that of other third parties.

E. Disclosure of Your Personal Information

We may disclose your personal information to any of our employees, officers, insurers, professional advisors, agents, suppliers, or subcontractors to the extent that it is 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) to the extent that it is 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. To establish, exercise, or defend our legal rights (including providing information to others for the purposes of preventing fraud and reducing credit risk);
  4. To the buyer (or potential buyer) of any business or asset we are selling (or considering selling); and
  5. To any person we reasonably believe may require disclosure of such personal information to a court or other competent authority if, in our opinion, such court or authority is likely to request disclosure of that personal information.

Unless otherwise provided in this policy, we will not disclose your personal information to any third party.

F. International Data Transfers

  1. The information we collect may be stored, processed, and transferred in any country where we operate, to enable us to use the information in accordance with this policy.
  2. The information 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.
  3. The personal information that you post on our website or submit for publication may be available, via the internet, around the world. We cannot prevent the good or bad use of that information by third parties.
  4. You expressly consent to the transfer of personal information described in this Section F.

G. Retention of Your Personal Information

  1. This Section G details our data retention policies and procedures, designed to help us comply with our legal obligations regarding the retention and deletion of personal information.
  2. Personal information that we process for any purpose shall not be kept longer than is necessary for that purpose or those purposes.
  3. Subject to Article G-2, we will generally delete personal data in these categories at the date and time specified below:
    1. This type of personal data will be deleted after 1 year.
  4. Notwithstanding the other provisions of this Section G, we will retain documents (including electronic documents) containing personal data:
    1. To the extent that we are required to do so by law;
    2. If we believe that the documents may be relevant to any ongoing or potential legal proceedings; and
    3. To establish, exercise or defend our legal rights (including providing information to others for the purposes of preventing fraud and reducing credit risk).

H. Security of Your Personal Information

  1. We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
  2. We will store all the personal information you provide on secure servers (protected by password and firewall).
  3. All electronic financial transactions made through our website will be protected by encryption technologies.
  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 keeping the password you use to access our website confidential; we will never 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 are happy with any changes to this policy. We may notify you of changes to this policy by email or through the private messaging service of our website.

J. Your Rights

You may request us to provide you with any personal information we hold about you; the provision of such information will be subject to the following conditions:

  1. Payment of a fee and
  2. Provision of sufficient evidence of your identity (for this purpose, we generally accept a notarized photocopy of your passport plus an original copy of a utility bill indicating your current address).

We may withhold personal information that you request to the extent permitted by law.

You may request us at any time not to process your personal information for marketing purposes.

In practice, you will explicitly and in advance consent to our using your personal information for marketing purposes or we will provide you with an opportunity to refuse the use of your personal information for marketing purposes.

K. Third-Party Websites

Our website contains hyperlinks to third-party websites and information about them. We have no control over these sites and are not responsible for their privacy policies or practices.

L. Updating Information

Please let us know if the personal information 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) sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can be “persistent” or “session”: a persistent cookie is stored by the browser and remains valid until its expiry date, unless deleted by the user before that expiry date; while a session cookie expires at the end of the user session, when the browser is closed. Cookies generally do not contain any information that personally identifies a user, but the personal information that we store about you may be linked to the information stored in and obtained by cookies. We only use session cookies on our website.

  1. The names of the cookies we use on our website and the purposes for which we use them are as follows:
    1. We use Google Analytics and Adwords on our website to: recognize a computer when a user visits the website / track users as they navigate the website / enable the use of a shopping cart on the website / improve website usability / analyze website usage / administer the website / prevent fraud and improve the security of the website / customize the website for each user / send targeted advertisements that may be of interest to certain users (describe your other objectives);
  2. Most browsers allow you to reject or accept cookies. For example:
    1. with Internet Explorer (version 10), you can block cookies by using the cookie management settings available by clicking on “Tools”, “Internet Options”, “Privacy”, and then “Advanced”;
    2. with Firefox (version 24), you can block all cookies by clicking on “Tools”, “Options”, “Privacy”, and then selecting “Use custom settings for history” from the dropdown menu and unchecking “Accept cookies from sites”; and
    3. with Chrome (version 29), you can block all cookies by accessing the “Customize and control” menu, then clicking on “Settings”, “Show advanced settings”, and “Content settings”, then selecting “Prevent sites from setting data” under the “Cookies” heading.

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

  1. You can delete cookies that are already stored on your computer. For example:
    1. with Internet Explorer (version 10), you need to manually delete the cookie file (you can find instructions on how to do that here http://support.microsoft.com/kb/278835);
    2. with Firefox (version 24), you can delete cookies by clicking on “Tools”, “Options”, and “Privacy”, then selecting “Use custom settings for history” and clicking on “Show cookies”, then “Remove all cookies”; and
    3. with Chrome (version 29), you can delete all cookies by accessing the “Customize and control” menu, then clicking on “Settings”, “Show advanced settings”, and “Clear browsing data”, then “Delete cookies and site data” before clicking on “Clear browsing data”.
  2. Deleting cookies will have a negative impact on the usability of many websites.
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