Privacy Policy

A. Introduction

  1. The privacy of our website visitors is very important to us, and we are committed to protecting it. This policy explains what we do with your personal information.
  2. By consenting to our use of cookies in accordance with this policy when you first visit our website, you allow us to use cookies every time you visit our site.

B. Source
This document was created using a template from SEQ Legal (seqlegal.com).

C. Collection of personal information

The following types of personal information may be collected, stored and used:

  1. Information about your computer, including your IP address, geographical location, browser type and version, and operating system;
  2. Information about your visits to and use of this website, including the referral source, length of visit, pages viewed and website navigation paths;
  3. Information such as your email address, which you provide to us when you register on the website;
  4. Information that you enter when you create a profile on our website, such as your name, profile picture, gender, date of birth, relationship status, interests and hobbies, educational background and employment history;
  5. Information such as your name and email address, which you enter in order to subscribe to our emails and/or newsletters;
  6. Information that you enter when you use the services on our website;
  7. Information generated while you use our website, including when, how often and under what circumstances you use it;
  8. Information relating to purchases you make, services you use or transactions you carry out on our website, which includes your name, address, telephone number, email address and bank details;
  9. Information that you post on our website with the intention of publishing it on the internet, which includes your username, profile pictures and the content of your posts;
  10. Information contained in any communications that you send to us by email or through our website, including their content and metadata;
  11. Any other personal information that you provide to us.

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

D. Use of your personal information

Personal information submitted to us through our website will be used for the purposes set out in this policy or on the relevant pages of the website. We may use your personal information to:

  1. Administer our website and our business;
  2. Personalise our website for you;
  3. Enable you to use the services available on our website;
  4. Send you goods purchased on our website;
  5. Supply you with services purchased on our website;
  6. Send you statements, invoices and payment reminders, and collect payments from you;
  7. Send you non-marketing commercial communications;
  8. Send you email notifications that you have specifically requested;
  9. Send you our newsletter by email, if you have requested it (you can inform us at any time if you no longer wish to receive our newsletter);
  10. Send you marketing communications relating to our business or to carefully selected third-party businesses which we think may be of interest to you, in published form or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer wish to receive marketing communications);
  11. Provide third parties with statistical information about our users (without those third parties being able to identify any individual user from that information);
  12. Deal with enquiries and complaints relating to your website made by you or about you;
  13. Keep our website secure and prevent fraud;
  14. Verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website's private messaging service); and
  15. Other uses.

If you submit personal information for publication on our website, we will publish it and may use that information in accordance with the permissions you grant us.

Your privacy settings can be used to limit the publication of your information on our website and can be adjusted in your privacy settings on the website.

Without your express consent, we will not supply your personal information to any third party for their direct marketing or that of any other third party.

E. Disclosure of your personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar 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 means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

  1. To the extent that we are required to do so by law;
  2. In connection with any ongoing or future legal proceedings;
  3. In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
  4. To the purchaser (or prospective purchaser) of any business or asset in our possession that we wish (or are considering) to sell; and
  5. To any person whom we reasonably believe to be part of a court or other authority competent for the disclosure of that personal information where, in our opinion, such court or authority would be likely to request disclosure of that personal information.

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

F. International data transfers

  1. Information that we collect may be stored, processed and transferred in any of the countries in which we operate, in order to enable us to use the information in accordance with this policy.
  2. Information that we collect may be transferred to the following countries, which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China and India.
  3. Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use, or misuse, of such information by others.
  4. You expressly agree to the transfers of personal information described in this Section F.

G. Retention of your personal information

  1. This Section G sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.
  2. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  3. Without prejudice to Article G-2, we will usually delete personal data falling within the categories set out below at the date and time set out below:
    1. This type of personal data will be deleted {ENTER DATE/TIME}; and
    2. {ENTER OTHER DATES/TIMES}.
  4. Notwithstanding the other provisions of this Section G, we will retain documents (including electronic documents) containing personal data:
    1. To the extent that we are required to do so by law;
    2. If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
    3. In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

H. Security of your personal information

  1. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
  2. We will store all the personal information you provide to us on secure (password- and firewall-protected) servers.
  3. All electronic financial transactions entered into through our website will be protected by encryption technology.
  4. You acknowledge that the transmission of information over the internet is inherently insecure, and that we cannot guarantee the security of data sent over the internet.
  5. You are responsible for keeping the password you use to access our website confidential; we will not ask you for your password (except when you log in to our website).

I. Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page regularly to make sure you are aware of any changes to this policy. We may notify you of changes to this policy by email or through the private messaging service on our website.

J. Your rights

You may ask us to provide you with any personal information we hold about you; the transfer of such information will be subject to the following conditions:

  1. Payment of a fee; and
  2. Provision of sufficient evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a notary plus an original copy of a utility bill showing your current address).

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

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

In practice, you will either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

K. Third-party websites

Our website contains hyperlinks to third-party websites and information about them. We have no control over these websites and are not responsible for their privacy policies or practices.

L. Updating information

Please let us know if the personal information that 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 web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie is stored by the browser and remains valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, expires at the end of the user session, when the browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. We use only session cookies and persistent cookies on our website.

  1. The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
    1. We use Google Analytics and Adwords on our website to: track users as they navigate the website, enable the use of a shopping basket on the website, improve the usability of the website and analyse the use of the website.
  2. Most browsers allow you to refuse or accept cookies. For example:
    1. in Internet Explorer (version 10), you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
    2. in Firefox (version 24), you can block all cookies by clicking “Tools”, “Options”, “Privacy”, then selecting “Use custom settings for history” from the drop-down menu and unticking “Accept cookies from sites”; and
    3. in Chrome (version 29), you can block all cookies by opening the “Customise and control” menu, clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.

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 features of our website.

  1. You can delete cookies already stored on your computer. For example:
    1. in Internet Explorer (version 10), you must delete the cookie files manually (you can find instructions for doing so here http://support.microsoft.com/kb/278835);
    2. in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies” and then “Remove All Cookies”; and
    3. in Chrome (version 29), you can delete all cookies by opening the “Customise and control” menu, clicking “Settings”, “Show advanced settings” and “Clear browsing data”, then “Delete cookies and other site and plug-in data”, before clicking “Clear browsing data”.
  2. Deleting cookies will have a negative impact on the usability of many websites.