Privacy and Cookie Policy

This Policy applies to collection of your personal data, as well as to the use of “cookie” files and similar technologies on the [PRODUCT_SITE_NAME] website (the “Website”). The Website is operated by [MERCHANT_NAME], with its registered office at [MERCHANT_ADDRESS], “We” or “Our”).

Your Privacy is important to us!

We recognize that your privacy is very important to you and that it is your right to control what information we process about you and how we process it. We know that providing personal data is an act of trust and we take that trust seriously. [MERCHANT_NAME]will never sell, rent or otherwise disclose your personal data, except as outlined in the Privacy and Cookie Policy, provided that we have an appropriate legal basis for such a disclosure (your consent or a legal obligation). [MERCHANT_NAME] is the controller of your personal data and takes appropriate steps to ensure security of your data.

By your continued use of our services following the posting of this Privacy Policy (as applicable), you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy forms part of and should be read in conjunction with our Terms of Use and any additional applicable terms on our Services.

For important reasons, we may periodically be required to make changes to our Privacy Policy (for example if we substantially change the way our services or the Website functions, or following legislative changes). We will notify you of these changes by e-mail and by posting the modified Privacy Policy on the Website. We recommend that you revisit this Privacy Policy regularly. If we are going to use your personal data in a manner materially different from that stated at the time of collection, we will notify you by e-mail and/or by posting a notice once you log onto your account. You may determine when this Privacy Policy was last updated by referring to the date found at the top of the first page of this Privacy Policy.

1. Consent to Privacy Policy

By your continued use of the [PRODUCT_SITE_NAME] Services following the posting of this Privacy Policy (as applicable), you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy forms part of and should be read in conjunction with our Terms of Use and any additional applicable terms.

2. Information Collection and Personally Identifiable Information

In the course of your use of our services, we collect the following personal data:

Registration data: your e-mail address and password, first name, last name, phone number, and payment details. We process this information in order to create and manage your account with us, contact you as well as to enable payment for our services. We only use payment information, such as credit card or bank account numbers, as necessary for completing a particular transaction or providing a service and to prevent fraud or abuse of our services.

Provision of registration data is mandatory – otherwise, we will not be able to provide our services to you. Legal basis of processing: processing of your registration data is necessary for the purpose of concluding and performing the contract with you (i.e. for creation of your user account with us and offering services to you).

Data collected through your use of our services: when you use our services, we collect information about your activity in our services. We collect such data in order to: (i) tailor our services to your needs, (ii) enhance our relationship with you, (iii) help delivering first-rate experience through improving our services, customizing the content and advertising materials, (iv) identify content you share when you use our services, (v) compile aggregate data for internal and external business purposes, and (vi) conduct research. By doing that, we may profile your personal data, which means that we may use the data we collect to adjust the services we provide to meet your needs. In such cases, we do not use your personal data in a way that would result in automated decision-making that could affect your legal rights, produce legal effects or otherwise similarly affect you (i.e. we do not use algorithms to make decisions which would have an impact on your individual legal rights or significantly affect your legal status or rights under the agreement between us). Provision of such data is necessary if you wish to use our tailored services – otherwise we will not be able to give you customized content. Legal basis of processing: (i) performance of the contract with you, for processing of data for the purpose of tailoring services to your needs; (ii) our legitimate interest in direct marketing of our services for processing your data for customizing advertisements.

Marketing. We also process your data for general marketing purposes, i.e. sending you marketing e-mails, provided that you did not opt out from such forms of communication. In processing your data for this purpose, we pursue our legitimate interest in direct marketing of our own services, which constitutes the legal basis for processing of your data. Provision of your personal data is voluntary, but if you don’t provide us with your e-mail address, we will not be able to reach out to you. Legal basis of processing: our legitimate interest in direct marketing of our services.

Your rights

You have the right to object to the processing of your data by us, when it is based on legitimate interest (in particular when processed for marketing purposes). You also have the right to request that we correct or delete your data, if you find out that certain information about you is incorrect or outdated.

If you file a request that we stop processing your data and delete it, we will do so unless there exists an important overriding legal interest (e.g. defense of claims or existence of a legal obligation to retain the data, for example for accounting or tax purposes) which will entitle us to keep your personal data for a longer period. You also have the right of access to your data, to request a copy of data that we process about you, as well as the right to data portability and to restriction of processing.

We process your personal data only for as long as necessary for the purposes, for which it was collected. In establishing the appropriate retention period for your personal data, we take into account, among others, the following criteria: (i) whether you express continuous interest in our services, (ii) whether you still have an account with us and if you use it, (iii) whether there are specific legal obligations to retain your data (e.g. for accounting and tax purposes).

We entrust the processing of your personal data to entities, which act on our behalf and solely based on our instructions (data processors). In particular, we use data processors, whom we select carefully, to store your data on secure servers located within the territory of the EU. Appropriate safeguards are applied, in particular we take care to appoint only trusted and verified processors and we sign GDPR-compliant data processing agreements with them.

We share your personal data with payment service providers for the purpose of processing your payments. The transfer is made based on our legitimate interest and because it is necessary for the performance of the contract with you. We may also be obliged to share your personal data with competent authorities (in particular the police or prosecution service), if they approach us with such a request, provided that there exists an appropriate legal basis for making your personal data available to them (e.g. a court order).

If you have any questions with regard to the processing of your data by us or if you wish to exercise your rights, you can contact us at support[at] [PRODUCT_SITE_URL]. You also have the right to file a complaint to data protection authority.

3. Information use

Payment Information. We only use payment information, such as credit card numbers, as necessary for completing a particular transaction or fulfilling a service and to prevent abuse.

Other Information. We use the other information we collect from or about you in order to establish and enhance our relationship with you and to help deliver first-rate experience. Our use of this information includes the following general purposes: contacting you; customizing the content and advertising you view; fulfilling your requests for products or services; identifying content you share when you use the [PRODUCT_SITE_NAME] Services; improving our services; conducting research; compiling aggregate data for internal and external business purposes; preventing potentially illegal activities; protecting our rights; other uses in accordance with our Terms of Use; and for any other purpose disclosed to you at the time we collect your information.

Recommendations and Advertising. We (and service providers acting on our behalf) may use information about you, including your use of our Services, to provide recommendations and advertisements on our Services and elsewhere on the web.

Promotional Communications. We may use your information to:

1. Provide you with promotional information about our services, and other offerings that may be of interest to you;
2. Provide information or offers to you that are related to our Services on behalf of ours business partners.

4. Information sharing and disclosure

We are committed to protecting your personal information. We will not disclose your personally identifiable information to third parties without your consent except:

1. where we are required by law to disclose information to third parties;
2. where the disclosure is necessary for the performance of our operations (e.g. mail delivery, hosting services, protecting us from fraud, and payment of your account);
3. we buy or sell subsidiaries or business units in connection with a corporate transaction, such as a sale, merger, consolidation or asset sale, or an internal reorganization, or in the unlikely event of an insolvency. If such a transaction or event required the transfer of customer information, then that information would be one of the transferred assets, but would remain subject to the commitments made in any pre-existing Privacy Policy or equivalent.

We also may share your personal information with third parties (i.e. agents or sub-contractors) specifically engaged by us to provide services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us.

We also provide analyses of our customers in the aggregate to prospective partners, advertisers, content distributors and other third parties. We do this so that we and our business partners can understand you better, and so we can keep bringing you first-rate services. We may also disclose, on an anonymous basis, literal statements made by our customers. At no time, however, will we disclose personal information about specific customers.

Linked websites are not under our control and we are not responsible for the conduct of companies linked to our Website. Before disclosing your personal information on any other website we advise you to examine its terms and use and privacy policy.

5. Changing or Deleting Your Information

All our members may review, update, correct, or delete the Personal Information in their registration profile by contacting us. If you completely delete all such information, your account may be deactivated. We may retain an archived copy of your records as required by law or for legitimate business purposes.

6. Our use of cookies and similar technologies

In order to improve the operation of our site, we use cookies, web beacons, device fingerprinting, and similar technologies.

Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. The following types of cookies are used on the Website:

• Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
• Session cookies – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
• Strictly necessary cookies – These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. These cookies are essential to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
• Performance cookies – These cookies collect anonymous information on the pages visited. By using the Website, you agree that we can place these types of cookies on your device. These cookies collect information about how visitors use the Website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.
• Functionality cookies – These cookies remember choices you make to improve your experience. By using the Website, you agree that we can place these types of cookies on your device. These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
• Targeting or advertising cookies – These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

Web beacons (also known as pixel tags) are transparent image files used to monitor your journey around a single interaction with the Website and its content.

Device fingerprinting is a technology that allows us to collect information about your device (what browser or operating system you use, plug-ins, time zone, other settings). We use this information to identify you and to ensure the security of our website.

Google Analytics is a tool we use in order to calculate visits to our website, check which functionalities of our website are used most and improve the operation of the Website.

Cookies and similar technologies are used for statistical purposes, to adapt the website content, performance, and structure to users’ individual preferences, to provide users with advertising content adapted to their preferences. Cookies and web beacons for ads targeting purposes can be linked to other online services, such as Facebook. Please note that cookies may collect personal information to enhance the site’s functionality. Such data is stored in encrypted form and the access to them is limited. Cookies that are used by the third parties via the Website, including, in particular, the users of the website, are subject to their own privacy policy.

Handling and use of “cookies” and similar technologies is allowed automatically. However, these settings can be changed at any time. For details on how cookies are handled and used, see the settings of your web browser. You can learn more about cookies and similar technologies and check how to disable them for the browser you use by visiting the following website: allaboutcookies.org

7. Behavioral advertising and online privacy

A guide to behavioral advertising and online privacy has been produced by the internet advertising industry which can be found at youronlinechoices.eu. The guide contains an explanation of the IAB’s self-regulatory scheme to allow you greater control of the advertising you see.

Using browser settings to manage cookies:

The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.

However, because cookies allow you to take advantage of some of the Website’s essential features, we recommend you leave them turned on. For example, if you block or otherwise reject cookies you will not be able to add items to your Shopping Basket, proceed to Checkout, or use any of our products and services that require you to Sign in. If you leave cookies turned on, remember to sign off when you finish using a shared computer.

8. Changes and updates

We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the modified terms on the Website. We recommend that you revisit this Privacy Policy regularly. If we are going to use Personal Information in a manner materially different from that stated at the time of collection, we will notify you via email. You may determine when this Privacy Policy was last updated by referring to the date found at the top of the first page of this Privacy Policy “This Privacy Policy was last modified and is effective as of”.

9. Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to our support mail: vasupport[at] [PRODUCT_SITE_URL]