Effective Date: 10.08.2022
2. Who processes your personal information
To provide you with access to the Sites and Services, your Personal information is collected and used by Company.
3. What is the purpose of this Policy
Privacy and security of your Personal information are extremely important to us. When you use the Sites and/or Services, Company processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.
As part of our commitment to protecting your Personal information, we use this Policy to transparently inform you about the following:
(a) why and how your Personal information is collected and used (also, “processed”) by Company when you access the Sites or Services;
(b) Company’s role and responsibilities in this context as the legal entity deciding why and how your Personal information is processed;
(c) what instruments you may use to limit the amount of Personal information collected by Company; and
(d) what your rights are in relation to the above processing.
4. What type of Personal information is collected by Company
Personal information collected by Company when you access, interact with or operate the Sites and/or Services includes:
(i) information provided by you when you register (create) a user account, such as your name, mobile phone number, address and age;
(ii) electronic data (http headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software);
(iii) date and time of accessing the Sites or Services;
(iv) information related to your activity when using the Sites or Services (e.g. your search history, email addresses of your contacts, content of your emails together with attachments, as well as files stored in Company systems);
(v) (geo)location information;
(vi) other information about you that needs to be processed according to the terms and conditions of any specific Company Site or Service;
Company does not perform any form of profiling, which has the potential to significantly impact your rights and freedoms in accordance with applicable laws
5. What are the legal basis for processing your Personal information and the purposes of it
Company is not allowed to process your Personal information if it does not have a valid legal ground. Company will therefore only process your Personal information if:
(i) the processing is necessary to perform our contractual obligations towards you including providing you with Sites and/or Services (i.e. providing you with the results of your search query);
(ii) the processing is necessary to comply with our legal or regulatory obligations;
(iii) in case it is provided by applicable law, the processing is necessary for the legitimate interests of Company and does not unduly affect your interests or fundamental rights and freedoms. Please note that when we process your Personal information on this basis, we will always seek to maintain a balance between our legitimate interest and the protection of your privacy.
Examples of such ‘legitimate interests’ referred in (iii) immediately above are:
(a) to better understand how you interact with our Sites and/or Services;
(b) to enhance, maintaining accessibility, modify, personalize or otherwise improve the Sites and Services for the benefit of all users;
(c) to offer you other products and services from Company or other companies which we think can be of interest to you (i.e. personally-targeted advertising);
(iv) for specific purposes or if consent is required under the applicable laws and regulations, we may ask your consent for processing of your Personal information. In those jurisdictions in which consent is the legal basis, you provide such consent by agreeing to use our Sites and/or Services. We hereby inform you, and you hereby acknowledge, that you have no legal obligation to provide us with any Personal Information when you use the Sites or Services, and the provision of it is solely based on your free will. However, you are aware that without the provision of Personal Information, we will not be able to provide you with Services and your use of the Sites will be limited.
Company always processes your Personal information for a specific purpose and only processes Personal information which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes:
(i) to provide you with the Sites and/or Services (i.e. delivery of search results in response to your search queries, taking into account your preferences, search history and other Personal information about you available to Company);
(ii) to provide you with access to your user account, including your email and storage service, if you have an account for these Services;
(iii) to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application;
((v) to personalize advertisements and/or commercial offers based on your preferences, search history and other Personal information available to Company;
(v) to improve user experience, including offering more relevant search results and more personalised Sites and/or Services, as well as improving other Company products, applications and services;
(vi) to develop new products, applications and services;
(vii) to protect your rights and the rights of Company;
(viii) to collect, process and present statistical data or big data, or perform other research and/or analysis of Personal information.
6. How Company protects your Personal information
In most cases, Personal information is processed automatically without access to it by our staff. However, if such access is necessary, your Personal information can be accessed only by those Company employees whose professional tasks require using this information. To protect your Personal information and ensure its confidentiality, these employees must comply with internal rules and follow protocols for processing Personal information. They are also required to follow all technical and organisational security measures protecting your Personal information.
Company has also implemented adequate technical and organisational measures to protect Personal information against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information.
7. Who else has access to your Personal information and who is it shared with
Company may also transfer Personal information to third parties outside the Company Group to complete the purposes listed in Section 5 above. Please note that the level of protection of Personal Information in some countries may not be identical to the level in your jurisdiction and by using the Services you consent to such transfer.
Such third parties may include:
(i) Partners, such as media publishers, advertising networks and other partners providing Company with services related to the placement and display of advertisement on the websites, programs, products and/or services owned or operated by such Partners;
(ii) Advertisers or other Partners serving targeted advertisement on the Company Sites or Services; and third parties who process Personal information, such as our (IT) systems providers and/or consultants.
Company may also transfer Personal information to the following third parties outside the Company Group:
(i) any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
(ii) any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;
(iii) third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you;
8. How long we store your Personal information
Company will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.
Unless otherwise legally required or agreed, the emails and documents, which are stored by you on our systems as part of the Service, will remain stored as long as you have an account with us, but you can delete them at any time.
If you wish to have any Personal information removed from our databases, you can have it removed via your account or using interface of the Sites or Services (where applicable).
9. Your rights
9.1 What are your rights
If it is provided by applicable law, you have a right of access to your Personal information as processed by Company under this Policy.
If you believe that any information, we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.
If it is provided by applicable law, you also have the right to:
- request erasure of your Personal information or certain parts of it, as well as withdraw consent to the processing of the Personal information;
- request the restriction of the processing of your Personal information;
- object to the processing of your Personal information if it is provided by applicable law.
Company will honor any such requests or objections as required under applicable law.
To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.
9.2 How can you exercise your rights
To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact Company (see Section 13 hereof).
If you are not satisfied with how Company processes your Personal information, please let us know and we will investigate your concern. If you are not satisfied with Company’s response, you have the right to make a complaint to the competent data protection authority.
10.1 What are cookies and what does Company use them for
Cookies are small text files placed on the device you use to access our Sites. They contain information that is collected from your device and sent back to the Sites on each subsequent visit so as to remember your actions and preferences over time.
The following types of cookies are used on the Sites:
- strictly necessary cookies / technical cookies: these cookies are required to run the Sites and provide you with the Services and may, among other, allow Company to identify your hardware and software, including your browser type;
- statistical / analytic cookies: these cookies enable us to recognize users, count the number of users and collect information such as your actions on the Sites and the Services, including the web pages you visit and the content you retrieve;
- performance cookies: these cookies collect information about how users interact with our Sites and Services, enabling us to identify errors and test new functionalities to improve the performance of the Sites and the Services;
- functionality cookies: these cookies enable us to provide specific functionalities in order to improve your experience on the Sites, for example by storing your preferences (e.g. language and location);
- (third party) tracking / advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable us to display advertising which may be of interest to you based on collected Personal information. These cookies are also used for statistical and research purposes.
10.2 How long are those cookies stored on your device
Company only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.
10.3 Who else has access to the information contained in the cookies
Personal information collected through cookies placed on your device may be transmitted to and accessed by Company or the third parties referred to in Section 7 hereof. The use of Personal information outside of the Sites for advertising purposes, if any, may be subject to separate policies available on the above third parties’ websites. Company or those third parties might also provide you with a possibility to opt out of personalized advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings.
Company may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes:
(i) to track your actions on the Sites and when using the Services, by accessing and interacting with the cookies stored on your computer;
(ii) to collect statistical information related to operating the Sites, the Services or products, utilities, advertisements or other Company offerings.
11. Age Restrictions
Our Sites and Services are not intended for children under 18 years of age (hereinafter, «Children»).
We deliberately do not collect Personal information about children under 18 years of age. If you are a parent or legal guardian and know, that your Children provided us their Personal Information, please contact us. If we become aware that Children have attempted to or have submitted Personal Information without permission from their parent or legal guardian, we may take steps to remove such information from our servers or may replace with Personal information of parent or legal guardian.
12. Updates to this Policy
This Policy may be subject to amendments. Company shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and Services.
Company undertakes not to introduce significant changes, imposing additional obligations or reducing your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the Site or Services (e.g. via a pop-up or web banner) prior to such changes taking effect, and you may also be notified via other channels (e.g. by email) if you have provided us with your contact details.
13. Questions and Suggestions
We welcome your questions or suggestions concerning implementation of or amendments to this Policy. To contact us please send e-mail: email@example.com. You can also use this e-mail adress to exercise your rights or report any inaccuracies in your Personal information or protest its processing.