1. INFORMATION WE COLLECT
1.1. While using our Website, you may decide to provide us with certain information about you by completing online forms, registering on our Website, making orders, contacting us etc. The types of personal information you may provide to us include, but not limited to: name, contact information (address, e-mail address, telephone number, fax number), username and, personal preferences, interests in and use of various products and services, content of communication with us. You do not have to provide listed above and below personal data to access the Website but certain functionality will not otherwise be available to you.
1.2. Once you visit our Website we may automatically collect some information that cannot be readily used to identify you, e.g. the domain name and IP address of your computer, type of browser you are using, operating system and platform, technical information, geographical location information about your visit to our Website (length of visit, products you viewed, page respond time, navigation paths, as well as information about the timing, frequency and pattern of your service use etc.). We may use this information, individually or in the aggregate, for technical administration of our Website, analytic tracking system, research and development. The legal basis for this processing is our legitimate interests, for monitoring and improving of our Website and services.
2. PROCESSING OF PERSONAL INFORMATION
We protect your data by limiting access to your data only to persons that need access to conduct or facilitate any transaction between you and us, or persons that otherwise need to complete activities outlined in this section.
2.1. We may process your information included in your personal profile on our Website. The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. We do not knowingly collect information about people under 18 years old. The profile data may be processed for the purposes of enabling and monitoring your use of our Website and services, creating and managing your personal profile, operating our Website, providing our services, ensuring the security of our Website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests for proper administration of our Website and business.
2.2. We may process information that you post for publication on our Website or through our services. The publication data may be processed for the purposes of enabling such publication and administering our Website and services. The legal basis is our legitimate interests for proper administration of our Website and business.
2.3. We may process information contained in any enquiry you submit to us regarding goods and/or services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you and for the processing of your specific request. The legal basis is our legitimate interests for proper administration of our Website and business.
2.4. We may process information relating to our customer relationships, including customer contact information. The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, assisting with product selection and making recommendations to you, and promoting our products and services to customers. The legal basis for this processing is the proper management of our customer relationships.
2.5. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters, communications about our products, services and promotional materials. After you have subscribed to the newsletter on our Website, we will send you a message to the indicated email address asking for your confirmation. If you do not confirm your subscription, your subscription will automatically be deleted. You may at any time with future effect revoke your consent to receive our newsletter. To declare that you wish to unsubscribe, you may use the respective link included in all newsletters, contact us via mail at the address listed in Section 12 “How to contact us”, or call us at 0800-400-405. The legal basis is our legitimate interests for proper administration of our Website and business.
2.6. In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. PROVIDING YOUR PERSONAL DATA TO OTHERS
We do not rent lists, sell or otherwise disclose personal information we collect, except as described hereunder. We may share your personal to complete activities outlined in this section.
3.1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2. We may disclose your personal data to our service providers who perform services on our behalf based on our instructions, insurers and professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice and provision of services.
We may share your personal data with our service providers who are involved in our business processes.
Example of personal data usage by our service providers:
- we pass your personal information to service providers that assist us with our marketing and data analytics efforts to inform you and make recommendations about our products, including sales, special offers and new Website features and to send you other promotional communication.
Our marketing and data providers are “Google Analytics”, “Contact Form 7”, “AddThis”. Privacy Policies of our service providers are available at their Websites accordingly. We do not authorize these service providers, insurers and professional advisers to use or disclose personal information except as necessary to perform services on our behalf or comply with legal requirements.
3.3. In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
In this Section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.1. We share your personal data with our contractual parties outside the European Economic Area (EEA) to perform services on our behalf and/or comply with legal requirements. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
4.2. The hosting facilities for our Website are situated in Kyiv, Ukraine (hosting service: Mirohost.net) datacenter services. Transfers to hosting facilities are protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5. RETAINING AND DELETING PERSONAL DATA
This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.1. We may keep your personal information only for so long as is necessary or where we have a legitimate interest to continue doing so. Where We no longer requires information to be in a format where you can be identified personally, e.g. where we keep information for analytical and research purposes or transaction information, we will remove any personal details about you.
5.3. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.
6.1. We may update this policy from time to time by publishing a new version on our Website.
7. YOUR RIGHTS AND RESPONSIBILITIES
In this Section we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.1. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.2. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw consent to consent-based processing;
- you object to the processing under certain rules of applicable data protection law;
- the processing is for direct marketing purposes;
- and the personal data have been unlawfully processed.
However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
7.3. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.4. To help us protect your privacy, be sure:
- to log off the Website when you are finished;
- to provide us true, accurate and complete information;
- not to use our Website if you are younger than 18 years old;
- not to provide us information about anyone else unless you have their permission to do so.
7.5. Should you wish to know more about what information we hold about you including making changes to, or requesting the deletion of, information that we hold about you, you are also entitled by law to make a Data Subject Request. You can make such a request by emailing us at email@example.com. Please note that we may need to exclude certain information as part of your request, e.g. in order to protect the privacy of other individuals or if we are permitted to exclude the information for legal or other reasons.
7.6. Please be advised that deleting your personal information will limit our ability to contact you in connection with our offerings, which may limit your ability to utilize our offerings.
8.1. 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.
8.2. 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.
9. COOKIES THAT WE USE
10. COOKIES USED BY OUR SERVICE PROVIDERS
10.3. Analytics cookies allow us to understand more about how many visitors we have to the Website, how many times they visit our Website and how many times a user viewed specific webpages within our site. Although analytics cookies allow us to gather specific information about the pages that you visit and whether you have visited our Website multiple times, we cannot use them to find out details such as your name or address.
11. MANAGING COOKIES
11.1. If you do not want to accept cookies from our Website, you can change your browser settings so that cookies are not accepted. If you choose to do this, please be aware Website may no longer function as intended.
11.2. All popular browsers (e.g. Chrome, Internet Explorer, Firefox, Opera and Safari) allow you to amend your cookie settings so that cookies are no longer enabled across all Websites that you visit. You can find information explaining how to disable cookies for the main browsers in the ‘Where to find information about controlling cookies’ section at the Information Commissions Website ico.org.uk/for-the-public/online/cookies.
12. HOW TO CONTACT US
For questions regarding the processing of your personal data please contact:
We always welcome and greatly appreciate your feedback, any comments or suggestions, which may contribute to a better quality of our work.