Privacy and Data
Protection Policy
This Privacy and Data Protection Policy
sets out the basis which (�we�, �us�, or �our�) may collect, use or otherwise
process personal data via our website (�Website�) and all related websites as
specified below, downloadable software, mobile applications including desktop
applications (collectively �Products�), and other services provided by us and
on which a link to this Privacy Policy is displayed, and all other
communication with individuals through written or oral means, such as email,
chat or phone (collectively together with the Website and Products, our
�Services�).
We are committed to safeguarding
your personal information that you entrust to us while using our websites and
Services, and
other company websites including subdomains.
Definitions
Personal Data: means any information
relating to an identified or identifiable natural person (�data subject�); an
identifiable natural person is one who can be identified, directly or indirectly,
in particular by reference to an identifier such as a name, an identification
number, location data, an online identifier or to one or more factors specific
to the physical, physiological, genetic, mental, economic, cultural or social
identity of that natural person.
Processing: means any operation or
set of operations which is performed on personal data or on sets of personal
data, whether or not by automated means, such as collection, recording, organization,
structuring, storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure or destruction.
Restriction of Processing: means the
marking of stored personal data with the aim of limiting their processing in
the future.
Controller: means the natural or
legal person, public authority, agency or other body which, alone or jointly
with others, determines the purposes and means of the processing of personal
data; where the purposes and means of such processing are determined by Union
or Member State law, the controller or the specific criteria for its nomination
may be provided for by Union or Member State law.
Processor: means a natural or legal
person, public authority, agency or other body which processes personal data on
behalf of the controller.
Consent of the Data Subject: means
any freely given, specific, informed and unambiguous indication of the data subject�s
wishes by which he or she, by a statement or by a clear affirmative action,
signifies agreement to the processing of personal data relating to him or her.
1. Collection and use
of information
1.1 We generally
collect information that:
a) You directly provide us via our
websites or upon your request regarding our products or services,
b) We receive from the use of our products and services including but not
limited to our websites
1.2 We may collect
your personal information through several different sources, including but not
limited to:
1.3 We may collect and
use your personal data for any or all of the following purposes:
(a) performing obligations under a
contract or in the course of or in connection with our provision of the
services requested by you;
(b) verifying your identity;
(c) responding to, handling, assessing queries, requests, applications,
complaints, vacancy requests, and feedback;
(d) managing your relationship with us;
(e) sending you marketing information, including but not limited to surveys and
questionnaires, about our products or services;
(f) complying with any applicable laws, regulations, codes of practice,
guidelines, directives or rules, or to assist in law enforcement and
investigations conducted by any governmental and/or regulatory authority;
(g) any other purposes for which you have provided the information;
(h) transmitting information to any affiliated third parties, including our
third party service providers and agents, and relevant governmental and/or
regulatory authorities, whether in Europe or no EU jurisdictions, for the
aforementioned purposes in this section;
(i) any other incidental business purposes related to
or in connection with the above;
(j) update, fix errors, administer and improve the features and functionality
of our applications and associated services;
(k) to analyze application performance via collection of statistical data.
The purposes listed in the above
clauses may continue to apply even in situations where your relationship with
us (for example, pursuant to a contract) has been terminated or altered in any
way, for a reasonable period thereafter (including, where applicable, a period
to enable us to enforce our rights under any contract with you or other lawful
purposes).
In addition to the specific purposes
for which we may process your personal data set out in this Section, we may
also process 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 person.
We provide our services in
collaboration with companies that provide services on our behalf, such as
handling the processing and delivery of information, publication of information
in the applications, delivery of content and services provided by the applications
and services of our websites, or performing statistical analysis on the use of
the applications and the aforementioned services. These service providers will
be given limited or no access to your information as is reasonably necessary to
deliver the Service, and we will require that such third parties comply with
this Privacy Policy, or operate under a similar privacy policy.
We do not sell, rent, lease or
freely distribute our mailing lists to any third party.
When you voluntarily disclose your
personal information in your profile, on forums and comment online in forum
/chat areas, it becomes publicly available and can be viewed by other users.
Forums, chats, and other areas of the community of users of our applications,
that are available through our websites and applications, are public. In such
areas, you should not disclose any information that can be used to establish
your identity or the identity of any other person. We are not responsible for
the security and protection of information disclosed by you in such areas.
1.4 Minor�s personal
information and privacy
We recognize the importance of
protecting the information about minors and we do not knowingly collect any
personal information from minors under eighteen (18) years of age. Our website and
services are directed to persons over eighteen (18) years of age, We accepts no responsibility for any failure to comply with
this requirement.
We encourage parents and legal
guardians to take the appropriate measures to prevent children under eighteen
years of age from viewing at this Website without the appropriate permission.
In the event we become aware that we
have received personal information from a visitor under the age of eighteen
(18) years of age, we shall delete as soon as reasonably practicable and not
make use of such information.
1.5. Collection of
other information
We may collect other non-personal
information about the use of our Software Applications, visits to our websites
or use of additional services, including links you have clicked, software
or information you have downloaded, as well as other actions related to the use
of our products or services. We may also collect certain technical information
necessary for the operation and update of our products/services and the collection
of anonymous statistics on the use of such products/services, along with any
error reports about our products.
Contact Us
If you have questions about this
Cookies Policy or the way personal information is processed or used in
connection with the use of our Software Applications or websites, Your request must include your name and other information
needed for the identification, as well as for the full and complete processing
of your request.
3. Protection of
personal data
We endeavor to ensure protection
of the information submitted to us, both during transmission and once we
receive it. We maintain appropriate administrative, technical and physical
safeguards to protect Personal Data against accidental or unlawful destruction,
accidental loss, unauthorized alteration, unauthorized disclosure or access,
misuse, and any other unlawful form of processing of the Personal Data in our
possession. This includes, for example, firewalls, password protection and
other access and authentication controls. However, no method of transmission
over the Internet, or method of electronic storage, is 100% secure. We cannot
ensure or warrant the security of any information you transmit to us and
you do so at your own risk. We also cannot guarantee that such information may
not be accessed, disclosed, altered, or destroyed by breach of any of our
physical, technical, or managerial safeguards. If you believe your Personal
Data has been compromised.
4. Retention of
personal data
We may retain data for different
periods of time for different purposes as required by statute, our legitimate
interests or best business practices. Other statutory obligations, legal
processes and inquiries may also necessitate the retention of certain data.
5. Data Transfers
outside the EEC
We have global presence with
representative offices located in many countries. We may have processors in
different countries around the world and thus your personal data may be
processed, used or transferred outside the EEC. We ensure that all necessary
safeguards and security measures are in place, as deemed appropriate, under the
relevant national, international laws.
6. Changes to this
Privacy and Data Protection Policy
6.1 We reserve the right to revise
and update this Privacy and Data Protection Policy from time to time in part or
in full by publishing the new version on our website.
6.2 We encourage you to check our
Privacy Policy periodically to keep yourselves updated with the changes.
6.3 To view the latest version
of our Privacy Policy, click the <Privacy and Data Protection Policy>. In
case of such revisions, the new revised version of the Privacy Policy shall
become effective on the date of its publication, unless otherwise is provided
by the revised version of the Privacy Policy.
6.4 We may notify you of
changes to this policy by email or through the messaging system on our website.
7. Your Rights
(a) The right to
access
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.
(b) The right to rectification
You have the right to request 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.
(c) The
right to erasure
In some circumstances you have the
right to request the erasure of your personal data if established that the
personal data is no longer necessary in relation to the purposes for which it
was collected or otherwise processed; you withdraw permission to
authorization-based processing; you object to the processing under certain
rules of applicable data protection law and if established that the personal
data has 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 defense of legal
claims and for reasons of public interest.
(d) The right to restrict
processing
In some circumstances you have the
right to restrict the processing of your personal data, for example when 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
defense 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 and we will
only process it for the establishment, exercise or defense of legal
claims, for the protection of the rights of another natural or legal person or
for reasons of important public interest.
(e) The right to
object to processing
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
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
defense of legal claims
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.
You have the right to object to the
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.
(f) The right to data portability
You have the right to obtain the
personal information provided to us given that
(g) The right to complain to a
supervisory authority
If you consider that the 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.
(h) The right to withdraw
authorization.
To the extent that the legal basis
for our processing of your personal information is authorization, you have the
right to withdraw that authorization at any time in which case we may not be
able to provide to you some of the features and functionality of our Services.
Withdrawal of permission will not affect the lawfulness of processing prior to
the withdrawal request.
8. Notification of
Breaches
In the event of unauthorized
breaches or intrusions into our systems, that may affect your personal data
security, we will notify you as soon as it is practically feasible and we will
take all necessary measures and actions to avoid future occurrences and similar
phenomena.
9. Contact us
If
you have questions about this Privacy and Data Protection Policy or the way
personal information is processed or used in connection with the use of our Software
Applications or websites, Your request must include
your name and other information needed for the identification, as well as for
the full and complete processing of your request.