At the outset
It is emphasized and clarified, for the avoidance of doubt and without any room for misinterpretation: no confidential or sensitive information should be submitted through the website.
A. Introduction
The privacy of visitors to our website is very important to us, and we are committed to protecting it. This policy explains what we do with your personal information.
Consent to our use of cookies in accordance with the terms of this policy during your first visit to our website allows us to use cookies every time you visit the site.
B. Collection of Personal Information
The following types of personal information may be collected, stored, and used:
Information about your computer, including your IP address, geographical location, browser type and version, and operating system.
Information about your visits to and use of the website, including referral source, length of visit, page views, and navigation paths.
Information such as your email address that you provide when registering on our website.
Information you enter when creating a profile on our website—e.g., your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, education details, and employment details.
Information such as your name and email address that you enter to subscribe to our email notifications and/or newsletter.
Information entered when using services on our website.
Information generated while using our site, including when, how often, and under what circumstances you use it.
Information related to any purchases, services used, or transactions made through our website, including your name, address, phone number, email address, and credit card details.
Information you post to our website with the intent of publishing it online, including your username, profile pictures, and comment content.
Information contained in communications sent to us by email or through our website, including the content and metadata of those messages.
Any other type of personal information you choose to send us.
Note: Before disclosing another person’s personal information to us, you must obtain their consent to both the disclosure and the processing of their personal information in accordance with this policy.
C. Use of Your Personal Information
Personal information submitted to us via 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 purposes:
Administering our website and business
Personalizing the website for you
Enabling your use of the services available on our website
Sending you goods purchased through the website
Supplying services purchased through the website
Sending you statements, transaction invoices, and payment reminders, and collecting payments from you
Sending you non-marketing commercial messages
Sending you email notifications that you specifically requested
Sending you our newsletter by email if you requested it (you may inform us at any time if you no longer require the newsletter)
Sending marketing communications related to our business or carefully selected third-party businesses that we believe may interest you, by post or, where you have specifically agreed, by email or similar technologies (you may inform us at any time if you no longer wish to receive marketing communications)
Providing third parties with statistical information about our users (without the ability to identify individual users)
Handling inquiries and complaints submitted by or about you in relation to our website
Keeping our website secure and preventing fraud
Verifying compliance with the terms of service governing use of the website (including monitoring private messages sent through the site’s private messaging system)
Other uses as needed
If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant us. You may use your privacy settings to limit the publication of your information on our site and modify those settings via the privacy controls on the site.
We will not provide your personal information to any third party for their or any third party’s direct marketing purposes without your explicit consent.
D. Disclosure of Personal Information
We may disclose your personal information to:
Any of our employees, managers, insurers, professional advisors, agents, suppliers, or subcontractors, as reasonably necessary for the purposes stated in this policy
Any company within our corporate group (this includes our subsidiaries, the parent company, and its subsidiaries) as reasonably necessary for the purposes stated in this policy
We may disclose your personal information:
As required by law
In connection with any existing or future legal proceedings
To establish, exercise, or defend our legal rights (including providing information to others for fraud prevention and credit risk reduction)
To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling
To any person who we reasonably believe may seek disclosure from a court or other competent authority, where in our reasonable opinion, such court or authority would likely order disclosure of that information
Except as provided in this policy, we will not provide your personal information to third parties.
E. International Data Transfers
Information we collect may be stored, processed, and transferred between any countries in which we operate to enable us to use the information in accordance with this policy.
Information may be transferred to countries without equivalent data protection laws to those in the European Economic Area, including the United States of America, Russia, Japan, China, and India.
Personal information that you publish on our website or submit for publication may be available via the internet worldwide. We cannot prevent the use or misuse of such information by others.
By submitting such information, you consent to the international transfers described in this section.
F. Retaining Personal Information
This section outlines our data retention policy and procedures to help ensure compliance with legal obligations regarding personal data retention and deletion.
Personal data processed for any purpose shall not be kept longer than necessary for that purpose.
Without prejudice to the above, we will usually delete personal data in the categories listed below on the date/time specified below:
{Insert type and date/time of data deletion}
Notwithstanding the other provisions in this section, we may retain documents (including electronic documents) containing personal data:
As required by law
If we believe the documents may be relevant to any ongoing or prospective legal proceedings
To establish, exercise, or defend our legal rights (including providing information to others for fraud prevention and credit risk reduction)
G. Security of Your Personal Information
We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
We will store all the personal data you provide on secure servers (protected by password and firewall).
All computer-based financial transactions entered via our website will be protected by encryption technology.
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent online.
You are responsible for keeping your password confidential. We will not ask you for your password (except when logging into the website).
H. Amendments
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are familiar with any changes.
We may notify you of changes via email or through the private messaging system on our site.
I. Your Rights
You may instruct us to provide you with any personal information we hold about you. Provision of such information is subject to:
Payment of a fee {Insert fee if applicable}
Supplying appropriate evidence of your identity (e.g., a notarized copy of your passport along with an original utility bill showing your current address)
We may withhold 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 generally either expressly consent in advance or be given an opportunity to opt out.
J. Third-Party Websites
Our website includes external links and details about third-party websites.
We have no control over and are not responsible for the privacy policies and practices of third parties.
K. Updating Information
Please let us know if the personal information we hold about you needs to be corrected or updated.
L. Cookies
Our website uses cookies.
A cookie is a file containing an identifier (a string 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 whenever the browser requests a page.
Cookies may be either “persistent” or “session” cookies:
A persistent cookie will be stored by the browser and remain valid until its expiry date, unless deleted earlier
A session cookie will expire at the end of your current browsing session, when you close your browser
Cookies typically do not contain information that personally identifies users, but personal information we store about you may be linked to the information stored in and obtained from cookies.
{Choose precise wording: We use only session cookies / only persistent cookies / both session and persistent cookies on our website.}
The names of the cookies we use and their purposes are listed below:
We use Google Analytics and Adwords on our website to:
Identify a computer when a user visits
Track users
Enable cart functionality
Improve usability
Analyze usage
Administer the website
Prevent fraud and improve security
Personalize user experience
Use targeted advertising for specific users
{Describe other uses as appropriate}
Blocking cookies (by browser):
Internet Explorer (v10): Tools → Internet Options → Privacy → Advanced
Firefox (v24): Tools → Options → Privacy → Use custom settings for history → uncheck “Accept cookies from sites”
Chrome (v29): Settings → Show advanced settings → Content settings → Block sites from setting any data
Blocking all cookies may negatively impact your experience on many websites.
Deleting cookies:
IE (v10): Delete cookies manually (instructions: http://support.microsoft.com/kb/278835)
Firefox (v24): Options → Privacy → Show Cookies → Remove All Cookies
Chrome (v29): Clear browsing data → Select “Delete cookies and other site and plug-in data”
Deleting cookies may also negatively affect website usability.