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 details what we do with your personal information.
2. Consenting to our use of cookies in accordance with this policy when you first visit our website allows 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 referring source, length of visit, page views, and website navigation paths;
3. Information generated when you use our site, including when, how often and under what circumstances you use it;
Before disclosing personal information about another person to us, you must obtain that person's consent to the disclosure and processing of that personal information in accordance with this policy.

D. Use of your personal information

Personal information provided to us through our website will be used for the purposes described in this policy or on the relevant pages of the website. We may use your personal information to:
1. Administer our website and business;
2. Personalize our website for you;
3. Enable your use of the services offered on our website;
4. Send you push notifications that you have expressly requested;
5. Provide statistical information about our users to third parties (without these third parties being able to identify any individual user with this information);
6. Maintain the security of our website and prevent fraud;
Without your explicit consent, we will not provide your personal information to third parties for their or other third parties' direct marketing.

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 current or future legal proceedings;
3. 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 which we wish (or are considering) selling; and
5. To any person we reasonably believe to be part of a court or other competent authority for the disclosure of such personal information if, in our opinion, such court or authority would be likely to request disclosure of such personal information.
Except as otherwise provided in this policy, we will not share your personal information with third parties.

F. 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. The information 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. You expressly agree to the transfer of personal information described in this Section F.
G. Retention of your personal information
1. This Section G details 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 generally delete personal data in these categories at the date and time specified below:

• Google Analytics data: 13 months

4. 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 the documents may be relevant to any current or potential legal proceedings; and
• 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 organizational precautions to prevent the loss, misuse or alteration of your personal information.
2. We will store all personal information you provide to us on secure servers (password and firewall protected).
3. You acknowledge that the transmission of information via the internet is inherently insecure, and that we cannot guarantee the security of your data sent via the internet.

I. Amendments

We may occasionally update this policy by posting a new version on our website. You should check this page regularly to ensure 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 request that we provide you with any personal information we hold about you; the transfer of such information will be subject to the following conditions:
1. Submission of sufficient evidence of your identity (for these purposes, we generally accept a notarized photocopy of your passport plus an original copy of a utility bill showing your current address).
We may withhold 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 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 sites and are not responsible for their privacy policies or practices.

L. Updating information

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

Mr. Cookies

Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) 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 can be "persistent" or "session": 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 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 only use session cookies and persistent cookies on our website.

1. The names of the cookies we use on our website and the purposes for which we use them are described below:

• We use Google Analytics on our website to: recognize a computer when a user visits the website/ track users as they navigate the website/ improve the usability of a website/ analyze the use of the website/ administer the website/ prevent fraud and improve the security of the website/ personalize the website for each user/
• Most browsers allow you to refuse or accept cookies. For example:
  • with Internet Explorer (version 10), you can block cookies using the cookie management override settings available by clicking on “Tools”, “Internet Options”, “Privacy” then “Advanced”;
  • with 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 unchecking "Accept cookies from sites"; and
  • With Chrome (version 29), you can block all cookies by accessing the "Customize and control" menu, then clicking "Settings", "Show advanced settings", and "Content settings", then selecting "Block sites from setting any data" in the "Cookies" header.

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.

• You can delete cookies already stored on your computer. For example:
  • with Internet Explorer (version 10), you must delete the cookies file manually (you can find instructions for doing so here http://support.microsoft.com/kb/278835);
  • with Firefox (version 24), you can delete cookies by clicking "Tools," "Options," and "Privacy," then selecting "Use custom settings for history" and clicking "Show cookies," then "Remove all cookies"; and
  • With Chrome (version 29), you can delete all cookies by accessing the "Customize and control" menu and then clicking on "Settings", "Show advanced settings" and "Delete browsing data" then "Delete cookies and plug-in data from other sites" before clicking on "Delete browsing data".
  • Deleting cookies will have a negative impact on the usability of many websites.