Privacy Policy

A. Introduction

1. We find it very important to protect the personal information of the visitors to our website and we are committed to ensuring this accordingly. This privacy statement provides information about how we handle your personal data.
2. By agreeing to the use of cookies in accordance with the terms of this privacy statement the first time you visit our website, you authorize us to use cookies each time you visit our website.

B. Source

This document is based on the SEQ Legal ( template modified by Website Planet (

C. Collection of personal information

We may collect, store and use the following types of personal information:
1. information related to your computer, including your IP address, geographic location, browser type and version, and your operating system;
2. information about your visit to and use of our website, including details of the sender’s link, the length of your visit, pageviews and information about navigation on the website;
3. information provided during registration on our website, such as your email address;
4. information provided when creating your profile on our website – e.g. your name, profile picture, sex, birthday, relationship status, interests and hobbies, education and employment details;
5. information provided on our website when signing up to the e-mail mailing list and/or newsletters, such as your
name, e-mail address;
6. the information provided on our website when using our services;
7. information generated while using our website, including when, how often and under
what circumstances you use our website;
8. information related to the services you have purchased, the services you use or transactions made through our website, including your name, address, telephone number, email address and your bank card details;
9. information sent to our website for publication on the Internet, including your username, profile pictures and the content of your messages;
10. the information you submit via email or through our website, including its content and metadata;
11. any other personal information you have sent us.
Before disclosing another person’s personal information to us, you must have that person’s consent to sharing and processing their personal information in accordance with the provisions of this Privacy Statement.

D. How your personal information is used

We will use the personal information you send to us through our website for the purposes set out in this privacy statement or on relevant pages of the website. We may use your personal information for the following purposes:
1. administration of our website and business;
2. customize our website for you;
3. make the services on our website available to you
4. posting goods purchased on our website to you;
5. provide services purchased on our website;
6. send invoices and payment reminders and collect payments from you;
7. send you non-marketing commercial communications;
8. send you e-mail notifications that you have specifically requested;
9. send you our e-mail newsletter if you have requested it (you can notify us at any time if you no
longer request the newsletter);
10. send you marketing communications related to our business(es) or select third party businesses, by post or, if you have expressly agreed to it, by email or using similar technology (you can notify us at any time if you no longer request the newsletter);
11. provide statistical information about our users to third parties (however, these third parties may not identify any user based on this information);
12. handling inquiries and complaints by you or about you and in connection with our website;
13. preserve the security of our website and prevent fraud;
14. check compliance with the terms and conditions regulating the use of our website (including tracking of private messages sent through the private messaging service of the website); as well as
15. other uses.
If you send us personal information to be published on our website, we will disclose and otherwise use that information in line with your permission.
Your privacy settings may restrict the disclosure of your information on our website. These settings may be changed on the website using the privacy settings options.
We will not transfer your personal information to third parties for the purpose of direct marketing by
these or other third parties without your express consent.

E. Disclosure of personal information

We may disclose your personal information to any of our employees, officers, insurance companies, professional consultants, agents, suppliers or subcontractors as long as this is reasonable and necessary to achieve the purposes set out in this privacy statement.
We may disclose your personal information to any member of our group of companies (i.e. our subsidiaries, our holding company, and all of its subsidiaries) as long as this is reasonable and necessary to achieve the purposes set out in this privacy statement.
We may disclose your personal information:
1. to the extent required by law;
2. in connection with pending or future court proceedings;
3. to establish, exercise or protect our legal rights (including providing information to others to prevent fraud and reduce credit risk);
4. to the buyer of any business or asset we sell (or will sell in the future); and
5. to any person in respect of whom we may reasonably assume that they may have recourse to a court or other competent authority to disclose personal information if, in our reasonable opinion, such court or authority is likely to order the disclosure of the personal information in question.
Except as provided in this privacy statement, we do not disclose your personal information to third parties.

F. International data transfer

1. The information we collect may be stored, processed and transmitted between any countries in which we carry out business activity in order to use the information in accordance with this privacy statement.
2. We may pass on the information we collect to the following countries that do not have laws equivalent to the applicable data protection laws in the European Economic Area: the United States, Russia, Japan, China and India.
3. The personal data that you disclose on our website or you submit for publication on our website may be available on the Internet worldwide. We cannot prevent the use of such information by others or the misuse of such information by others.
4. You expressly consent to the transfer of your personal data as described in this Section F.

G. Retention of personal information

1. This Section G sets out our data retention policies and procedures intended to ensure that we act in compliance with our legal obligations to retain and delete personal information.

2. The personal data that we process for any purpose(s) must not be retained for longer than is necessary for such purpose or purposes.
3. Without prejudice to Section G-2, personal data generally falling into the categories set out below will be deleted at the date/time specified below:
1. the personal data type is deleted at {DATE/TIME}; and
4. Without prejudice to the other provisions of Section G, documents containing personal information (including electronic documents) will be retained in accordance with the following:
1. to the extent required by law;
2. where the documents may be relevant in any pending or future court proceedings; and
3. to establish, exercise or protect our legal rights (including providing information to others to prevent fraud and reduce credit risk).
H. Security of your personal information
1. We take appropriate technical and organizational precautions to prevent the loss, abuse or alteration of your personal information.
2. All personal information you provide is stored on our secure (password and firewall protected) servers.
3. All electronic financial transactions made through our website are protected through encryption.
4. You acknowledge that transmitting information over the Internet is fundamentally insecure and that we cannot guarantee the security of data transmitted over the Internet.
5. You are responsible for treating the password you use to access our website in confidence; we do not ask for your password (unless when you log in to our website).
I. Modifications
We may from time to time update this privacy statement by publishing its new version on our website. Check this page from time to time to learn about changes to this privacy statement. We may notify you of changes to this privacy statement via email or through the private messaging system on our website.

J. Your rights
You can ask us to provide you with any personal information that we have about you; such information shall be provided under the following conditions:
1. payment of the required fee ({AMOUNTOF FEE, IF RELEVANT}); and

2. appropriate proof of your identity ({OVERWRITE AS APPLICABLE for this purpose; in general, we accept a photocopy of your passport, certified by a notary public, along with an original copy of a public utility bill containing your current address}).
To the extent permitted by law, we may withhold the personal information you request. You can ask us at any time not to process your personal information for marketing purposes.
In practice, you generally expressly agree in advance that we may use your personal data for marketing purposes, or we will provide you with the opportunity to object to the use of your personal information for marketing purposes.

K. Third Party websites

Our website contains links to and details regarding third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
L. Update data
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 (letters and numbers) that a web server sends to a web browser and that is stored by the browser. Then the ID is sent back to the server each time the browser queries a specific page from the server. Cookies can be “persistent” or “session” cookies: persistent cookies are stored by the browser and remain valid until the specified expiration date, except when deleted by the user before the expiration date; session cookies, on the other hand, expire at the end of a user session when the browser is closed by the user. Cookies do not usually contain information that could personally identify a user; however, the personal data we hold about you may be linked to information stored in or read from cookies.
{CHOOSE THE RIGHT PHRASE We use only uses session cookies / only persistent cookies / session cookies and persistent cookies on our website.}
1. Below we describe the names and the purpose of the cookies that we use on
our web site:
1. to recognize a computer on our website using Google Analytics and Adwords when a user {ADD ALL USE PURPOSES] visits the website / track users while navigating the website / use a shopping cart on the website / improve website usability / analyze the use of the website / administer the website / prevent fraud and improve the security of the
website / customize the website for each user / use targeted advertisements that may be of particular interest to specific users / describe additional purposes};
2. Most browsers can be set to decline cookies, for example:

1. In Internet Explorer (version 10), you can disable cookies in the settings that override cookie handling by clicking “Tools”, “Internet options”, “Privacy” tab, and finally “Advanced”;

2. To disable all cookies in Firefox (version 24), click “Settings”, “Options”, „Privacy”, then select “Use custom settings for history” from the drop-down menu and uncheck “Accept Cookies”; and

3. To disable all cookies in Chrome (version 29), select the “Customize and control”
menu, then click “Settings”, “Show advanced settings”, “Content settings”, and select
“Disable data backup on websites” in the “Cookies” menu.

If you disable the use of all cookies, the usability of many websites will deteriorate.
And some features on our website will not be available to you.
3. You can also delete cookies already stored on your computer e.g.:
1. you must manually delete cookies in Internet Explorer (version 10) (see how to do so);

2. To delete cookies in Firefox (version 24), click:
“Tools”, “Options” “Privacy” then select “Use custom settings for history” and then click “Show Cookies” and finally “Remove All”; and
3. In Chrome (version 29), to delete all cookies, select “Customize and control”,
then click “Settings”, “Show advanced settings”, “Clear browsing data” and select
“All cookies and website data” before clicking “Clear browsing data”.
4. If you delete cookies, the usability of many websites will deteriorate.