INTRODUCTION

The privacy of our website visitors is particularly important to us, and we are committed to protecting it. This policy explains what we will do with your personal information. Consenting to the use of cookies in accordance with the terms of this policy when you first visit our website allows us to use cookies every time you visit our website.

CREDITS

This document has been created using a SEQ Legal template (seqlegal.com) modified by Website Planet (www.websiteplanet.com)

COLLECTION OF PERSONAL INFORMATION

The following types of Personal Information may be collected, stored, and used:

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

information about your visits and use of this website, including source of reference, duration of the visit, page views and navigation paths on the website;

information, such as your e-mail address, entered when you register on our website;

information you enter when creating a profile on our website – for example, your name, profile photos, gender, date of birth, relationship status, interests and hobbies, educational and employment information;

information, such as your name and email address, entered to set up subscriptions to our emails and/or newsletters;

information that you enter during the use of the services on our website;

information generated when using our website, including when, how often and under what circumstances you use it;

information related to everything you purchase, services you use or transactions you carry out through our website, including name, address, telephone number, email address and credit card details;

information that you post on our website with the intention of posting it on the internet, including your username, profile photos and the content of your publications;

information contained in any communications you send us by email or through our website, including the content and metadata of the communication;

any other personal information you send us.

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

USE OF YOUR PERSONAL INFORMATION

The personal information sent to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for the following:

administer our website and our business;

customize our website for you;

enable the use of the services available on our website;

send products purchased through our website;

provide services purchased through our website;

send statements, invoices and payment reminders, as well as collect your payments;

send non-marketing commercial communications;

send email notifications specifically requested by you;

send our newsletter by email if you have requested it (you can inform us at any time if don’t want to receive any longer the newsletter);

send marketing communications related to our business or to the carefully selected third party businesses that we believe may be of your interest, by mail or, where you specifically agreed to this, by email or similar technology (you can inform us at any time if you don’t want to receive any longer marketing communications);

provide third parties with statistical information about our users (but these third parties will not be able to identify any individual users from that information);

deal with questions and complaints made by you or about you in relation to our website; keep our website safe and prevent fraud;

verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website’s private messaging service); and other uses.

If you submit personal information for publication on our website, we will post and use this information in accordance with the license you have granted to us. Your privacy settings may be used to limit the posting of your information on our website and adjusted using privacy controls on the website. Without your express consent, we will not provide your personal information to third parties for direct marketing purposes by them or third parties.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose your personal information to any of our employees, executives, insurers, professional consultants, agents, suppliers, 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 (this means our subsidiaries, our holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

to the extent that we are required to do so by law; in relation to any ongoing or potential legal proceedings;

to establish, exercise or defend our legal rights (including providing information to third parties for fraud prevention and credit risk reduction purposes);

to the buyer (or potential buyer) of any business or asset we are selling (or contemplating selling);

and any person we believe may request from a court or other competent authority to disclose such personal information where, in our reasonable opinion, such court or authority is likely to order the disclosure of such personal information.

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

INTERNATIONAL DATA TRANSFERS

The information we collect may be stored, processed, and transferred between any of the countries in which we operate to enable us to use the information in accordance with this policy.

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

The personal information you post on our website or submit for publication on our website may be available, over the internet, worldwide. We cannot prevent the use or misuse of such information by third parties.

You expressly agree to the transfers of personal information described in this section F.

Retention of personal information

This section G sets out our data retention policies and procedures designed to help ensure compliance with our legal obligations regarding the retention and deletion of personal information.

The personal information we process for any purpose or purposes should not be kept longer than necessary for that purpose or purposes.

Without prejudice to Article G-2, we will delete personal data belonging to the categories defined below on the date/time defined below:

Type of personal data will be deleted {ENTER DATE/TIME}; and {ENTER ADDITIONAL DATES/TIMES}.

Notwithstanding the other provisions of this section G, we will retain documents (including electronic documents) containing personal data:

to the extent that we are required to do so by law; if we believe that documents may be relevant to any ongoing or potential legal proceedings;

and to establish, exercise or defend our legal rights (including providing information to third parties for fraud prevention and credit risk reduction purposes).

Security of your personal information

We will take appropriate technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.

We will store all your personal information provided on our secure servers (protected by password and firewall).

All electronic financial transactions conducted through our website will be protected by encryption technology.

You acknowledge that the transmission of information over the internet is inherently insecure and that we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password used to access our site confidential; we will not ask for your password (except when you log in to our site).

Changes

We may update this policy from time to time by posting an updated version on our website. You should check this page from time to time to ensure that you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.

YOUR RIGHTS

You may instruct us to provide any personal information we hold about you; the provision of this information is subject to the following:

Payment of a fee {INSERT FEE, IF RELEVANT};

and providing appropriate evidence of your identity ({ADJUST THE TEXT TO REFLECT YOUR POLICY for this purpose; we will generally accept an authenticated copy of your passport plus an original copy of a service invoice showing your current address }).

We may retain the requested personal information to the extent permitted by law.

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

In practice, you will expressly agree in advance to the use of your personal information for marketing purposes, or we will offer you the opportunity not to allow the use of your personal information for marketing purposes.

THIRD PARTY WEBSITES

Our website includes links 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.

Information Update – Tell us if the personal information we hold about you needs to be corrected or updated.

Cookies – Our website uses cookies. A cookie is a file that contains an identifier (a sequence of letters and numbers) sent by a web server to a browser and stored by the browser. The identifier is then sent back to the server every time the browser requests a page from the server. Cookies may be “persistent” or “session” cookies: a persistent cookie will be stored by a browser and will remain valid until the set expiration date unless it is deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user’s session when the browser is closed. Cookies usually do not contain any information that personally identifies a user, but the personal information we store about you may be linked to the information stored and obtained from cookies. {SELECT CORRECT PHRASE We only use session cookies / persistent cookies / persistent and session cookies on our website.}

The names of the cookies we use on our website and the purposes for which they are used are described below: We use Google Analytics and Adwords on our site to { INCLUDE ALL CASES OF COOKIE USE ON YOUR SITE Recognize a computer when a user accesses the site / track users while they browse the site / allow the use of a shopping cart on site / improve site usability / analyze site usage / administer the site / prevent fraud and improve site security / customize the site for each user / target advertisements that may be of particular interest to specific users / describe purpose(s)};

Most browsers allow you to refuse to accept cookies – for example:

in Internet Explorer (version 10), you can block cookies using the available cookie-handling opt-out settings by clicking “Tools”, “Internet Options”, “Privacy” and “Advanced”;

in Firefox (version 24), you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu and deselecting “Accept cookies from sites”;

and in Chrome (version 29), you can block all cookies by accessing the “Customize and Control” menu and clicking “Settings”, “Advanced” and “Site Settings” and then selecting “Block third-party cookies” in the “Cookies and Site Data” section.

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 the features on our website.

You can delete cookies already stored on your computer – for example:

in Internet Explorer (version 10), you must delete the cookie files manually (see instructions for doing so at http://support.microsoft.com/kb/278835);

in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history”, clicking “Show cookies” and then clicking “Remove all cookies”;

and in Chrome (version 29), you can delete all cookies by accessing the “Customize and Control” menu and clicking “Settings”, “Advanced”, “Clear browsing data” and then selecting “Delete cookies and other data from websites and plugins” before clicking “Clear browsing data”.

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