We get information about you in a range of ways and this includes personal information:
We use the personal information that we collect generally to fulfill the purpose for which it was provided. We have set out below a description of the ways we plan to use your personal information. We note that unless otherwise stated, we rely on the legal basis of legitimate interest to process your personal information:
We may share personal information as follows:
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on or to our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies We Use
Our Site uses the following types of cookies for the purposes set out below:
You can typically remove and reject cookies from our Site with your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
You have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. In accordance with applicable laws, you may send requests about personal information to our Contact Information below regarding the following:
If you wish to exercise any of these rights, you may contact Rick Carback, who we have designated as the Company’s Data Protection Officer under the GDPR (as defined below), at [email protected]. In your request, please make clear: (i) what personal information is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note, certain applicable laws may require that we maintain a record of certain personal information notwithstanding your wish to exercise these rights, such as financial information for purposes of complying with anti-money laundering laws or sanctions laws. Whenever possible, we will disclose any conflicts between such laws and your request to exercise your rights under this section and work with you to reach a resolution in compliance with applicable laws.
We take your privacy very seriously and work hard to protect the Company and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of information we collect and store. Your personal information will be stored on a series of servers which have implemented industry standard security measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure and/or access. We encrypt the Site using SSL encryption technology and all traffic on the Site is forced to use SSL. We review all information practices on a regular basis, and we restrict access to information on a need-to-know basis for all employees and other Company service providers who are subject to confidentiality obligations and are subject to termination or disciplinary action, including legal action, should such employees or service providers breach these obligations. While two factor authentication is not presently required to access the Site and use our services, we reserve the right to require use of two factor authentication in the future. By submitting to us personal information, you give your express consent to the transfer and storage of your personal information as described in this Policy.
All collection, processing and storing of personal data is performed in accordance with the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”), and the Company’s processing will take place in accordance with the GDPR. You can exercise your right to complain to a data protection authority by using the contact info found here.
Your information, including personal information that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy. One such step we will take to ensure the security of your personal information is to enter into specific contract clauses approved by the European Commission which ensure your personal information is given the same protection it has in Europe.
We will only retain your personal information for as long as is reasonably required for you to use the Site and our services (and in the event you have created an account with us, until you close such account), unless a longer retention period is required or permitted by law. For instance, certain anti-money laundering requirements may require that we retain certain financial information for five or more years.
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
The Site and our services are not intended for individuals under the age of 18. By using or interacting with our Site, you are affirming that you are at least 18 years old. We do not knowingly collect personal information from children under 13. If you believe that a child under the age of 13 has provided information to us, please notify us at [email protected]. If we inadvertently collect information of children under 13, we will delete that information immediately upon notice. We are not liable for any damages that may result from the user’s misrepresentation of age.
We may update this Policy from time to time in our sole discretion. We may update the Policy for a variety of reasons. For instance, we may update the Policy in order to reflect changes to our practices or for other operational, legal or regulatory reasons. If we make any substantial changes, we may notify you by sending you an e-mail to the last e-mail address you provided to us (if any), and/or by prominently posting notice of the changes on our Site. You are responsible for providing us with your most current e-mail address or other contact information. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. Continued use of our Site and any related services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at: [email protected]. You may direct privacy inquiries to the attention of Rick Carback, our designated Data Protection Officer.