Paragraph I: About the company
The type of personal information we collect
- We collect certain personal information about visitors and users of our Sites.
- The most common types of information we collect include things like: usernames, names, email addresses, address, phone number, IP addresses, other contact details, survey responses, blogs, payment information such as payment agent details, transactional details, tax information, support queries, forum comments, content you direct us to make available on our Sites (such as item descriptions) and web analytics data. We will also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).
How we collect personal information
- We collect personal information directly when you provide it to us, automatically as you navigate through the Sites, or through other people when you use services associated with the Sites.
- We collect your personal information when you provide it to us when you complete a form and buy or provide items or services on our Sites, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.
Personal information we collect about you from third parties
- Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:
- Third party service providers (like Google, Facebook, Instagram, Mailchimp…) which may provide information about you when you link, connect, or login to your account with the third party provider and they send us information such as location, interest, age, IP address, this only occurs if you are using this provider and they have been authorized by you via your privacy settings at that service provider. The use of User Content and other information provided by You to such third parties is governed by their privacy policies, not our Privacy Policy. We are not responsible for such third party privacy policies or their compliance with such policies.
- Other third party sources/and or partners with your consent; and
- we may allow third-party ad servers or ad networks to serve advertisements and/or collect information on the Service. These third-party ad servers or ad networks use technology to send, directly to your browser, the advertisements and links that appear on our site. They automatically receive your IP address when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content. We do not provide any personally identifiable information to these third-party ad servers or ad networks without your consent. However, please note that if an advertiser asks us to show an advertisement to a certain audience and you respond to that advertisement, the advertiser or ad-server may conclude that you fit the description of the audience they are trying to reach. In addition, third-party advertisers may use information (not including your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements on the Service, other websites and other forms of media about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here. Our Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers for more information.
How we use personal information
- We will use your personal information:
- Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
- operating the Sites;
- remember information so that you will not have to re-enter it during your current or subsequent visits to the Service;
- providing you with services described on the Sites;
- provide custom, personalized content and information;
- monitor the effectiveness of our marketing campaigns;
- monitor aggregate metrics such as total number of visitors and traffic;
- track User Content, and status in any promotions, sweepstakes, and contests;
- to improve the quality and design of the Service and to create new features by storing, tracking, and analyzing your preferences and trends;
- verifying your identity when you sign in to any of our Sites;
- responding to support tickets, and helping facilitate the resolution of any problem;
- updating you with operational news and information about our Sites and services e.g. to notify you about changes to our Sites, website disruptions or security updates;
- carrying out technical analysis to determine how to improve the Sites and services we provide;
- monitoring activity on the Sites, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites;
- managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;
- improving our products and service.
- Where you give us consent
- providing you with marketing information about products and services which we feel may interest you; and
- customising our services and websites, like advertising that appear on the Site – where this involves the use of cookies or similar technologies – in order to provide a more personalised experience.
- For purposes which are required by law.
- For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
- Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
When we disclose your personal information
- We may share your Personally Identifiable Information with third parties solely for the purpose of providing the Service to you. If we do this, such third parties’ use of your information will be bound by this Privacy Policy. We may store personal information in locations outside the direct control of us (for instance, on servers or databases co-located with hosting providers).
- In order to describe our Service to prospective partners, advertisers and other third parties we may disclose aggregate user information. We share Non-Personally Identifiable Information (such as anonymous use data) with third parties to assist them in understanding our Service, including Users’ use of our Service and the success of promotions.
- We may release collected information if required to do so by law, or if we believe that such action is appropriate to comply with state and federal laws or respond to a court order, law enforcement request or demand, subpoena, or search warrant. We may disclose collected information to applicable entities (for example, the Internal Revenue Service and third party payment providers) with respect to payment and tax-related purposes. We may also share collected information in order to investigate, prevent, or take action regarding suspected or actual illegal activities, including but not limited to, fraud; potential threats to public safety or the physical safety, property, or rights of any person; or violations of our Terms of Use.
How we keep your personal information secure
- We store personal information on secure servers that are managed by us and our service providers. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.
How you can access your personal information
- You have the right to make a request to access all the personal information we hold about you and to request corrections or deletion of that data.
Marketing Choices regarding your personal information
- Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
- You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Sites may not work properly in your case.
Cookies and web analytics
- When you visit our Sites, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:
- your IP address or proxy server IP address’;
- the domain name you requested;
- the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
- the date and time of your visit to the website;
- the length of your session;
the pages which you have accessed; - the number of times you access our site within any month;
- the file URL you look at and information relating to it;
- the website which referred you to our Sites; and
- the operating system which your computer uses.
- Occasionally, we will use third party advertising companies to serve ads based on prior visits to our Sites. For example, if you visit our Sites, you may later see an ad for our products and services when you visit a different Site.
Cookies set by us:
| Name | Provider | Purpose | Expiry | Type |
|---|---|---|---|---|
| Apbct_cookies_test | Site | Cookie to validate other cookies, so they can’t be spoofed. | Session | HTTP Cookie |
| Apbct_page_hits | Site | Cookie that is set from backend and contain information about current user. | Session | HTTP Cookie |
| Apbct_prev_referer | Site | Cookie that is set from backend and contain information about current user. | Session | HTTP Cookie |
| Apbct_site_landing_ts | Site | Cookie that is set from backend and contain information about current user. | Session | HTTP Cookie |
| Apbct_timestamp | Site | Cookie that is set from backend and contain information about current user. | Session | HTTP Cookie |
| Apbct_visible_fields | Site | Cookie that is set from backend and contain information about current user. | Session | HTTP Cookie |
| Apbct_visible_fields_count | Site | Cookie that is set from backend and contain information about current user. | Session | HTTP Cookie |
| Ct_checkjs | Site | Cookie used for storing dynamic variables from browser. | Session | HTTP Cookie |
| Ct_cookies_test | Site | Cookie used for storing dynamic variables from browser. | Session | HTTP Cookie |
| Ct_fkp_timestamp | Site | Cookie used for storing dynamic variables from browser | Session | HTTP Cookie |
| Ct_pointer_data | Site | Cookie used for storing dynamic variables from browser. | Session | HTTP Cookie |
| Ct_ps_timestamp | Site | Cookie used for storing dynamic variables from browser. | Session | HTTP Cookie |
| Ct_timestamp | Site | Cookie used for storing dynamic variables from browser. | Session | HTTP Cookie |
| Ct_timezone | Site | Cookie used for storing dynamic variables from browser. | Session | HTTP Cookie |
| Ct_sfw_pass_key | Site | Cookie used for our SpamFireWall technology. | Session | HTTP Cookie |
Cookies set by third parties:
Facebook Cookies:
| Name | Provider | Purpose | Expiry | Type |
|---|---|---|---|---|
| Datr | Share on Facebook button | Facebook session | HTTP Cookie | |
| Fr | Advertisement | Facebook session | HTTP Cookie | |
| Locale | Share on Facebook button | Facebook session | HTTP Cookie | |
| Sb | Share on Facebook button | Facebook session | HTTP Cookie | |
| Wd | Share on Facebook button | Facebook session | HTTP Cookie |
Google Cookies:
| Name | Provider | Purpose | Expiry | Type |
|---|---|---|---|---|
| _ga | Google advertising cookie used for user tracking and ad Analytics purposes | 10 year | HTTP Cookie | |
| _gat_gtag_UA_{id} | Google Analytics Cookie to identify the user by UA | 10 year | HTTP Cookie | |
| 1P_JAR | Google Analytics Cookie to identify the user by id | 10 year | HTTP Cookie | |
| APISID | Google advertising cookie used for user tracking and ad Analytics purposes | 10 year | HTTP Cookie | |
| HSID | Pieces of information to measure the number and behaviour of Google Maps users. | 10 year | HTTP Cookie | |
| NID | Pieces of information to measure the number and behaviour of Google Maps users. | 10 year | HTTP Cookie | |
| OGP | Pieces of information to measure the number and behaviour of Google Maps users. | 10 year | HTTP Cookie | |
| SAPISID | Pieces of information to measure the number and behaviour of Google Maps users. | 10 year | HTTP Cookie | |
| SID | Pieces of information to measure the number and behaviour of Google Maps users. | 10 year | HTTP Cookie | |
| Ct_fkp_timestamp | Pieces of information to measure the number and behaviour of Google Maps users. | 10 year | HTTP Cookie | |
| SIDCC | Pieces of information to measure the number and behaviour of Google Maps users. | 10 year | HTTP Cookie | |
| SSID | Pieces of information to measure the number and behaviour of Google Maps users. | 10 year | HTTP Cookie |
Soundcloud Cookies:
| Name | Provider | Purpose | Expiry | Type |
|---|---|---|---|---|
| Sc_anonymous_id | Soundcloud | To determine | 10 year | HTTP Cookie |
| Sclocale | Soundcloud | Soundcloud Language | 10 year | HTTP Cookie |
Scorecard Research:
| Name | Provider | Purpose | Expiry | Type |
|---|---|---|---|---|
| UID | Scorecard Research | Advertising (low impact) | 1 year | HTTP Cookie |
| UIDR | Scorecard Research | Advertising (low impact) | 1 year | HTTP Cookie |
YouTube Cookies:
| Name | Provider | Purpose | Expiry | Type |
|---|---|---|---|---|
| APISID | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
| HSID | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
| SID | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
| SIDCC | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
| SSID | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
| LOGIN_INFO | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
| PREF | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
| SAPISID | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
| VISITOR_INFO1_LIVE | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
| YSC | YouTube | Includes a mixture of pieces of information to measure the number and behaviour of YouTube users, including information that links your visits to our website with your Google account if you are signed in to one. | 10 year | HTTP Cookie |
Cloudflare Cookies:
| Name | Provider | Purpose | Expiry | Type |
|---|---|---|---|---|
| __cfduid | Cloudflare | The __cfduid cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. | 5 year | HTTP Cookie |
| optimizelyEndUserId | Cloudflare | Stores a visitor’s unique Optimizely identifier, for both Optimizely Classic and Optimizely X Web | 6 months | HTTP Cookie |
| trwv.uid | Cloudflare | These cookies are tools for analyzing and tracking visitor behavior, in order to deliver customized content and features based on user choices and past browsing on the site. | 2 year | HTTP Cookie |
Instagram Cookies
| Name | Provider | Purpose | Expiry | Type |
|---|---|---|---|---|
| rur | Instagram Widgets | Session | HTTP Cookie | |
| csrftoken | Helps prevent Cross-Site Request Forgery (CSRF) attacks | Session | HTTP Cookie | |
| urlgen | Instagram Widgets | Session | HTTP Cookie |
Children ’s Privacy
- Protecting the privacy of children is especially important. For that reason, we do not knowingly collect Personally Identifiable Information submitted by persons under 18 years of age. If you are under 18 years of age, then please do not submit any information to the Service at any time or in any manner.
Information you make public or give to others
- If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, like when you post a public message on a forum thread, share information via social media, or make contact with another user (such as a third party Author) whether via our Sites or directly via email. Before making your information publicly available or giving your information to anyone else, think carefully. If giving information to another user via our Sites, ask them how they will handle your information. If you’re sharing information via another website, check the privacy policy for that site to understand its information management practices as this privacy policy will not apply.
How long we keep your personal information
- We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information, you can request that we erase your personal information. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.
When we need to update this policy
- We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
- When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.
How you can contact us
- If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact us
Visitors from the European Economic Area:
- For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.How you can access your personal information. You are also entitled to ask us to port your personal information, to erase it, or restrict its processing.
- Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
- If you have unresolved concerns you also have the right to complain to data protection authorities.The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
Both personal information and personal data have the same meaning in the context of this Privacy Policy.
RC Law 09/04/2018