Privacy Policy

A. Introduction

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

B. How we collect your personal data

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, page views, and website navigation paths.
  3. Information that you enter when you register with our website, such as
    your email website.
  4. Information that you enter when you create a profile on our website. For
    example, your name, profile pictures, gender, birthday, relationship
    status, interests and hobbies, educational details, and employment
  5. Information that you enter in order to set up subscription to our emails
    and/or newsletters.
  6. Information that is generated while using our website, including when,
    how often, and under what circumstances you use it.
  7. Information relating to anything you purchase, services you use, or
    transaction you make through our website, which includes your name,
    address, telephone number, email address, and credit card details.
  8. Information that you post to our website with the intention of publishing
    it on the internet.
  9. Any other personal information you send to us.

C. Using Personal Information

Personal information submitted to us through 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:

  1. Administering our website and business
  2. Personalizing our website for you
  3. Enabling your use of the services available on our website
  4. Sending you goods purchased through our website
  5. Supplying services purchased through our website
  6. Sending statements, invoices, and payment reminders to you, and
    collecting payments from you.
  7. Sending you on-marketing commercial communications
  8. Sending you email notifications you have specifically requested.
  9. Sending you our email newsletter if you signed up for it (you can
    unsubscribe at any time).
  10. Sending you marketing communications relating to our business or the
    businesses of third parties which we think may be of interest to you.
  11. Providing third parties with statistical information about our users.
  12. Dealing with inquiries and complaints made by or about you relating to
    our website
  13. Keeping our website secure and prevent fraud.
  14. Verifying compliance with the terms and conditions governing the use of
    our website.
  15. Other uses.

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.

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

We will not, without your expressed consent, supply your personal information to
any third party for their or any other third party’s direct marketing.

D. Disclosing 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 means our subsidiaries, our ultimate holding company and all its
subsidiaries) 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 prospective 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 that we
    are (or are contemplating) selling; and
  5. to any person who we reasonably believe may apply to a court or other
    competent authority for disclosure of that personal information where, in our
    reasonable opinion, such court or authority would be reasonably likely to
    order disclosure of that personal information.

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

E. International data transfers

  1. Information that we collect may be stored, processed in, and transferred
    between 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 E.
  5. Retaining personal information
    1. This Section E sets out our data retention policies and procedure, 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/time set out below:
      a. personal data type will be deleted {ENTER DATE/TIME}; and
    4. Notwithstanding the other provisions of this Section G, we will retain
      documents (including electronic documents) containing personal data:
      a. to the extent that we are required to do so by law;
      b. if we believe that the documents may be relevant to any ongoing or
      prospective legal proceedings; and
      c. 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).

F. Security of your personal information

  1. We will take reasonable technical and organizational precautions to prevent
    the loss, misuse, or alteration of your personal information.
  2. We will store all the personal information you provide on our 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 we cannot guarantee the security of data sent over
    the internet.
  5. You are responsible for keeping the password you use for accessing our
    website confidential; we will not ask you for your password (except when
    you log in to our website).

G. 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 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.

H. Your rights

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

  1. the payment of a fee {ENTER FEE IF RELEVANT}; and
  2. the supply of appropriate evidence of your identity ({ADJUST TEXT TO
    REFLECT YOUR POLICY 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

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

In practice, you will usually 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

I. Third party websites

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

J. 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 is 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 will be stored by a web browser and will
remain valid until its set expiry date, unless deleted by the user before the expiry
date; a session cookie, on the other hand, will expire at the end of the user session,
when the web 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. {SELECT
ACCURATE PHRASING We use only session cookies / only persistent cookies / both
session 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:
    a. we use Google Analytics and Adwords on our website to recognize a
    computer when a user {INCLUDE ALL USES THAT COOKIES ARE USED
    FOR ON YOUR SITE visits the website / track users as they navigate the
    website / enable the use of a shopping cart on the website / improve the
    website’s usability / analyze the use of the website / administer the
    website / prevent fraud and improve the security of the website /
    personalize the website for each user / target advertisements which may
    be of particular interest to specific users / describe purpose(s)};
  2. Most browsers allow you to refuse to accept cookies—for example:
    a. 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”;
    b. in Firefox (version 24) you can block all cookies by clicking “Tools,”
    “Options,” “Privacy,” selecting “Use custom settings for history” from
    the drop-down menu, and unticking “Accept cookies from sites”; and
    c. in Chrome (version 29), you can block all cookies by accessing the
    “Customize and control” menu, and 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 upon the usability of many
    websites. If you block cookies, you will not be able to use all the features on our
  3. You can delete cookies already stored on your computer—for example:
    a. in Internet Explorer (version 10), you must manually delete cookie
    files (you can find instructions for doing so
    at );
    b. 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 clicking “Remove All
    Cookies”; and
    c. in Chrome (version 29), you can delete all cookies by accessing the
    “Customize and control” menu, and clicking “Settings,” “Show
    advanced settings,” and “Clear browsing data,” and then selecting
    “Delete cookies and other site and plug-in data” before clicking “Clear
    browsing data.”
  4. Deleting cookies will have a negative impact on the usability of many


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