Privacy policy
1. Introduction
1.1 We are
committed to safeguarding the privacy of our website visitors and service
users.
1.2 This policy
applies where we are acting as a data controller with respect to the personal
data of our website visitors and service users; in other words, where we
determine the purposes and means of the processing of that personal data.
1.3 By using our
website and agreeing to this policy, you consent to our use of cookies in
accordance with the terms of this policy.
1.4 Our website
incorporates privacy controls which affect how we will process your personal
data. By using the privacy controls, you can specify whether you would like to
receive direct marketing communications and limit the publication of your
information. You can access the privacy controls by clicking the unsubscribe
link in any of our automated e-mails.
1.5 In this
policy, "we", "us" and "our" refer to
2. How we use your personal data
2.1 In this
Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly
from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may
process ("usage data"). The usage data may include your IP
address, geographical location, browser type and version, operating system,
referral source, length of visit, page views and website navigation paths, as
well as information about the timing, frequency and pattern of your service
use]. The source of the usage data is our analytics tracking system. This usage
data may be processed for the purposes of analysing
the use of the website and services. The legal basis for this processing is consent
OR our legitimate interests, namely monitoring and improving our website and
services.
2.3 We may
process ("account data").The account data may be processed for
the purposes of 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 consent OR our
legitimate interests, namely the proper administration of our website and
business OR the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
2.4 We may
process your information included in your personal profile on our website
("profile data"). 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. The profile data may be processed for the purposes of
enabling and monitoring your use of our website and services. The legal basis
for this processing is consent OR our legitimate interests, namely the proper
administration of our website and business OR the performance of a contract
between you and us and/or taking steps, at you request, to enter into such a
contract.
2.5 We may
process your personal data that are provided in the course of the use of our
services ("service data"). The service data may be processed for
the purposes of 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 consent OR our
legitimate interests, namely the proper administration of our website and
business OR the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
2.6 We may
process information that you post for publication on our website or through our
services ("publication data"). The publication data may be
processed for the purposes of enabling such publication and administering our
website and services. The legal basis for this processing is consent OR our
legitimate interests, namely the proper administration of our website and
business OR the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
2.7 We may
process information contained in any enquiry you submit to us regarding goods
and/or services ("enquiry data"). The enquiry data may be
processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is consent.
2.8 We may
process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our
website ("transaction data"). The transaction data may include
your contact details, your card details and the transaction details. The
transaction data may be processed for the purpose of supplying the purchased
goods and services and keeping proper records of those transactions. The legal
basis for this processing is the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract and our
legitimate interests, namely our interest in the proper administration of our
website and business.
2.9 We may
process information that you provide to us for the purpose of subscribing to
our email notifications and/or newsletters ("notification data").
The notification data may be processed for the purposes of sending you the
relevant notifications and/or newsletters. The legal basis for this processing
is consent OR the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
2.10 We may process
information contained in or relating to any communication that you send to us
("correspondence data"). The correspondence data may include the
communication content and metadata associated with the communication. Our
website will generate the metadata associated with communications made using
the website contact forms. The correspondence data may be processed for the
purposes of communicating with you and record-keeping. The legal basis for this
processing is our legitimate interests, namely the proper administration of our
website and business and communications with users.
2.14 In addition to
the specific purposes for which we may process your personal data set out in
this Section 2, 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.
2.15 Please do not
supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
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 insurers and/or professional advisers
insofar as reasonably necessary for the purposes of obtaining or maintaining
insurance coverage, managing risks, obtaining professional advice, or the
establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
3.4 Financial
transactions relating to our website and services may be handled by our payment
services providers, PayPal, Stripe, or Transferwise. We
will share transaction data with our payment services providers only to the
extent necessary for the purposes of processing your payments, refunding such
payments and dealing with complaints and queries relating to such payments and
refunds. You can find information about the payment services providers' privacy
policies and practices at https://www.paypal.com/en/webapps/mpp/ua/privacy-full,
https://stripe.com/be/privacy, https://transferwise.com/privacy-policy.
3.5 We may
disclose your enquiry data to one or more of those selected third party suppliers
of goods and services identified on our website for the purpose of enabling
them to contact you so that they can offer, market and sell to you relevant
goods and/or services. Each such third party will act as a data controller in
relation to the enquiry data that we supply to it; and upon contacting you,
each such third party will supply to you a copy of its own privacy policy,
which will govern that third party's use of your personal data.
3.6 In addition
to the specific disclosures of personal data set out in this Section 3, 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 defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this
Section 4, we provide information about the circumstances in which your personal
data may be transferred to countries outside the European Economic Area (EEA).
4.2 We and our
other group companies have offices and facilities in the Netherlands. The
European Commission has made an "adequacy decision" with respect to the
data protection laws of each of these countries. 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, a copy of which can be obtained from the European commission’s website.
4.3 The hosting
facilities for our website are situated in Frankfurt, Germany. The European Commission has made an
"adequacy decision" with respect to the data protection laws of each
of these countries. 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.
4.5 You
acknowledge that personal data that you submit for publication through our
website or services may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section
5 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.
5.2 Personal data
that we process for any purpose or purposes shall not be kept for longer than
is necessary for that purpose or those purposes.
5.3 We will retain
your personal data from the date of your submission until 30 days after a
removal is requested, directed at our data protection officer.
5.5 Notwithstanding
the other provisions of this Section 5, 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 natural person.
6. Amendments
6.1 We may update
this policy from time to time by publishing a new version on our website.
6.2 You should
check this page occasionally to ensure you are happy with any changes to this
policy.
6.3 We may notify
you of changes to this policy by email or through the private messaging system
on our website.
7. Your rights
7.1 In this
Section 7, we have summarised 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.
7.2 Your
principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the
right to confirmation as to whether or not we process your personal data and,
where we do, access to the personal data, together with certain additional
information. That additional information includes details of the purposes of
the processing, the categories of personal data concerned and the recipients of
the personal data. Providing the rights and freedoms of others are not
affected, we will supply to you a copy of your personal data. The first copy
will be provided free of charge, but additional copies may be subject to a
reasonable fee.
7.4 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.
7.5 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 defence of legal claims.
7.6 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 defence 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 defence
of legal claims; for the protection of the rights of another natural or legal
person; or for reasons of important public interest.
7.7 You have the
right to object to our processing of your personal data on grounds relating to
your particular situation, but only to the extent that the legal basis for the
processing is that the processing is necessary for: the performance of a task
carried out in the public interest or in the exercise of any official authority
vested in us; or the purposes of the legitimate interests pursued by us or by a
third party. If you make such an objection, we will cease to process the
personal information unless we can demonstrate compelling legitimate grounds
for the processing which override your interests, rights and freedoms, or the
processing is for the establishment, exercise or defence
of legal claims.
7.8 You have the
right to object to our processing of your personal data for direct marketing purposes
(including profiling for direct marketing purposes). If you make such an
objection, we will cease to process your personal data for this purpose.
7.9 You have the
right to object to our processing of your personal data for scientific or
historical research purposes or statistical purposes on grounds relating to
your particular situation, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.
7.10 To the extent
that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a
contract to which you are party or in order to take steps at your request prior
to entering into a contract,
and such processing is carried out by automated means, you
have the right to receive your personal data from us in a structured, commonly
used and machine-readable format. However, this right does not apply where it
would adversely affect the rights and freedoms of others.
7.11 If you
consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged
infringement.
7.12 To the extent
that the legal basis for our processing of your personal information is
consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.
7.13 You may
exercise any of your rights in relation to your personal data by written notice
to us.
8. About cookies
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.
8.3 Cookies do
not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.
9. Cookies that we use
9.1 We use
cookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit
our website and as you navigate our website;
(b) status - we use cookies to help us to determine if you are
logged into our website;
(c) personalisation - we use cookies to
store information about your preferences and to personalise
the website for you;
(d) security - we use cookies as an element of the security
measures used to protect user accounts, including preventing fraudulent use of
login credentials, and to protect our website and services generally;
(e) advertising - we use cookies to help us to display
advertisements that will be relevant to you;
(f) analysis - we use cookies to help us to analyse
the use and performance of our website and services; and
(g) cookie consent - we use cookies to store your preferences in
relation to the use of cookies more generally.
10. Cookies used by our service providers
10.1 Our service
providers use cookies and those cookies may be stored on your computer when you
visit our website.
10.2 We use Google
Analytics to analyse the use of our website. Google
Analytics gathers information about website use by means of cookies. The
information gathered relating to our website is used to create reports about
the use of our website. Google's privacy policy is available at:
https://www.google.com/policies/privacy
11. Managing cookies
11.1 Most browsers
allow you to refuse to accept cookies and to delete cookies. The methods for
doing so vary from browser to browser, and from version to version. You can
however obtain up-to-date information about blocking and deleting cookies via
these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/kb/PH21411
(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
11.2 Blocking all
cookies will have a negative impact upon the usability of many websites.
11.3 If you block
cookies, you will not be able to use all the features on our website.
12. Our details
12.1 This website
is owned and operated by .
12.2 We are
registered in under registration number , and our registered
office is at .
12.3 Our principal
place of business is at .
12.4 You can
contact us:
(a) by post, to the postal address given above;
13. Data protection officer
13.1 Our data
protection officer's contact details are: , .