A. Introduction

The privacy of our website visitors is very 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 visit our website for the first time allows us to use cookies each time you visit our website.

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, geographic location, browser type and version, and operating system;
  • information about visits and use of this website, including referral source, duration of visit, page views and website navigation paths;
  • information such as your email address, name and telephone number, which you enter when completing the contact form on our website;
  • information such as your name and email address, which you enter to set up subscriptions to our emails and/or newsletters;
  • information that is generated while you use our website, including when, how often and under what circumstances you use it;
  • information contained in any communications you send us by email or through our website, including the content of the communications and their metadata;
  • any other personal information you send us.

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

D. Use of your personal information

The personal information transmitted through our website will be used for the purposes specified in this policy or in the respective pages of the website. We may use your personal information to:

  • administering the website and our business; personalizing our website for you;
  • authorization to use the services available on our website;
  • providing the services purchased through our website;
  • sending reports, invoices and payment notices to you and collecting payments from you;
  • sending commercial communications for information purposes;
  • sending expressly requested notices by e-mail;
  • sending our newsletter by email, if you have requested it (you can inform us at any time if you no longer want this communication);
  • sending marketing communications about our business or the companies of carefully selected third parties that we think may be of interest to you via e-mail or similar technologies (you can tell us at any time if you no longer wish to receive marketing communications);
  • providing statistical information about our users to third parties (those third parties will not be able to identify any user with this information);
  • dealing with requests and complaints made by you or about you relating to our website;
  • keeping our website secure and preventing fraud; verifying compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our private messaging service); and other uses.

If you submit personal information for publication on our website, we will publish and use that information in accordance with the extent of the consent you provide to us.

Privacy settings can be used to limit the publication of your information on our website and can be changed using the privacy switches on the website.

Without your express consent, we will not provide your personal information to third parties for direct marketing by those third parties or any other third party.

E. Disclosure of Personal Information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, 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 includes our subsidiaries, our parent company and all of its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

  • to the extent we are required to do so by law;
  • in connection with any potential or pending legal proceedings;
  • to establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and credit risk reduction);
  • to the buyer (or prospective buyer) of any business or good that we have sold (or plan to sell);
  • and to any person we reasonably believe could apply to a court or other authority having jurisdiction over the disclosure of personal information where, in our reasonable opinion, such court or authority could order the disclosure of the personal information.

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

F. 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.

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

You expressly consent to the transfers of personal information described in this Section (F).

G. Retention of personal information

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

2. Personal information that we process for any purpose or purposes will not be kept longer than is necessary for that purpose or purposes.

3. Notwithstanding Article G-2, we usually delete personal data that falls into the categories set out below.

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

  • to the extent we are required to do so by law;
  • if we believe that the documents may be relevant to any ongoing or future legal proceedings;
  • and to establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and credit risk reduction);

H. 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 personal information you provide on our secure (password and firewall protected) servers.

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

I. Amendments

We reserve the right to update this policy from time to time by publishing a new version on our website. You should check this page occasionally to make sure 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.

J. Your rights

You can ask us to provide you with any personal information we hold about you; the provision of this information will be subject to the following terms:

  • payment of a fee (to be determined at that time)
  • and providing sufficient proof of your identity (we usually accept a notarized photocopy of your passport/ID).

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

You can ask us at any time not to process your personal information for marketing purposes.

In practice, you will usually either give your express prior consent to the use of your personal information for marketing purposes, or we will give you the opportunity to opt out of the use of your personal information for marketing purposes.

Our website includes hyperlinks 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.

L. Updating information

Please let us know if the personal information we hold about you needs to be corrected or updated.

M. Cookies

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

  • we use Google Analytics on our website to recognize a computer when a user visits the website, track users while they browse the website, improve website usability, analyze website usage, administer the website, prevents fraud and improves website security, directs advertisements that may be of particular interest to the user;

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

  • in Firefox you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu and unchecking “Accept cookies from websites”;
  • and In Chrome you can block all cookies by going to the “Personalization and control” menu, clicking “Settings”, “Show advanced settings” and “Content settings”, then selecting “Block sites from sending any data” under the heading “Cookies”.

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 functions on our website.

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

  • In Firefox you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show cookies”, then “Clear all Cookies “;
  • and in Chrome you can delete all cookies by going to the “Personalization and control” menu, clicking “Settings”, “Show advanced settings” and “Clear browsing data”, then selecting “Clear cookies and other website data and plugins” and click “Clear browsing data”.

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