A. Introduction

1. The privacy of visitors to our website, is very important to us and we are committed to its protection. Our policy explains how we will use your personal information.

2. Your consent to the use of cookies, in accordance with the terms of our policy during your first visit to the website, allows us to use cookies every time you visit our website.

B. Acknowledgements

This document was created using a template by SEQ Legal.

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, your geographical location, your browser type and version, and your operating system.

2. Information about your visits and use of the site including the external source, the duration of the visit, the page views and the navigation path to the site.

3. Information such as your email address, which you give when registering on the site.

4. Information you give when creating your profile on our site — for example, your name, profile photos, gender, date of birth, personal status, your interests and hobbies, information about education and employment details.

5. Information such as your name and email address, which you give when setting up your subscriptions and for sending emails and/or newsletters.

6. Information you enter when using services on our website.

7. Information that arises when using the website, such as when, how often and under what conditions you use it.

8. Information regarding your purchases, the services you use and the transactions you make on the website, which include your name, address, telephone number, email address and your credit card information.

9. Information you post on the site with the intent of posting it on the web, which includes your username, your profile information and the content of your posts.

10. Information contained in any of your communication with us via email or through the website, including communication content of the communication, and metadata.

11. Any other personal information you send us.


Before disclosing any personal information to a third party, you must have that individual consent to the disclosure and processing of his or her personal information in accordance with the present policy.

D. Use of your personal information

The personal information submitted to us is used for the purposes set out in this policy on the associated pages of the website. We may use personal information for the following purposes:


1. management of our website and business

2. personalised site layout for you

3. activating the use of your available services on our website

4. shipping the goods you buy through our website

5. providing services you purchase through our website

6. sending transactions, invoices and payment reminders to you, as well as collect payments from you

7. sending non-advertisement communications

8. sending email notifications regarding your requests

9. sending our newsletter via email if you have requested it (you can let us know at any time if you no longer want to receive the newsletter)

10. sending promotional communications related to your business or to specific third party companies which we believe may be of interest to you, through notifications or, if you have agreed to it, by email or similar technology (you may notify us at any time if you no longer want advertising communications)

11. provision of our users’ statistical data to third parties (who will not be able to identify any user through this information)

12. managing requests and complaints that either you have submitted or are related to your site

13. maintaining the security of the site and preventing any fraud

14. confirmation of compliance with the terms and conditions for providing our website (including the monitoring of personal messages circulating through our private online messaging service) and

15. other uses.


If you submit personal information for publication on our website, we will post or use this information in accordance with your license.


Your privacy settings can be used to restrict the posting of your information on our site and can be configured using the site privacy check.


We will not pass on your personal information to any third party or any third party commercial department without your consent.

E. Disclosure of personal information

We may disclose your personal information to any of our employees, managers, insurers, or professional consultants, representatives, suppliers or subcontractors, as required for the purposes set forth in the present policy.


We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our controlling portfolio company and its affiliates) as required for the purposes set out in this policy.


We may share your personal information:


1. to the extent required by law
2. in relation to any current or future legal proceedings
3. for the purpose of consolidating, exercising or defending our legal rights (including the provision of information to third parties with a view to preventing fraud and reducing credit risk)
4. to the buyer (or potential buyer) of any business good that we sell (or intend to sell); and
5. to any other competent authority regarding the disclosure of information which we believe may belong to the judiciary or any other relevant authority, in the event that we consider that the relevant authority will require the disclosure of the specific personal information.


Also as stated in the present policy, we will not provide your personal information to third parties.

F. International data transfer

1. The information we collect may be stored, processed and moved between any countries in which we operate so that we may use it in accordance with this policy.

2. The information we collect may be transferred to the following countries which do not have the same personal data protection legislation as that in the European Economic Area: the USA, Russia, Japan, China and India.

3. The personal information you post on our website or submit to our website may be available online worldwide. We cannot prevent the use or misuse of such information by third parties.

4. You expressly agree to the transfer of temporary data described in section F.

G. Retention of personal data

1. Section G sets out the procedure and policy for keeping personal data, which has been designed to ensure compliance with our legal obligations regarding the retention and deletion of personal data.

2. Personal data we process for any purpose will not be retained for longer than is necessary for that purpose.

3. Notwithstanding G. 2, personal data is usually deleted by the user himself by changing or deleting the account.

1. Personal data are not deleted by us, except for old data where they are no longer used for 2 years whereby they can be deleted.

4. Notwithstanding the other provisions of Section G, we will retain documents (including electronic documents) containing personal data,

1. to the extent required by law.

2. if we consider that the documents may be related to any ongoing legal process and

3. for the purpose of consolidating, exercising or defending our legal rights (including the provision of information to third parties with a view to preventing fraud and reducing credit risk)

H. Security of your personal data

1. We will take the necessary precautions at the technical and organisational level to prevent the loss, misuse or alteration of your personal data.

2. We will store all the personal data you provide on secure (with a password, and firewall-protected) servers.

3. All electronic money transactions on our site are protected by our 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 transmitted over the Internet.

5. You are responsible for maintaining the confidentiality of the password you use; we will not ask for your password (except when you log in to our site).

I. Modifications

We may update our policy from time to time by posting a new version on our website. You should check the page from time to time to make sure you understand any changes to our policy. We may notify you of changes to our policy via email or through a private messaging system on our website.


J. Your rights

You may ask us to give you any information we hold about you. The provision of such information is subject to the following:


1. Providing us with sufficient information such as your identification, only with a photocopy of your passport or identity card certified by a notary, and a photocopy of a utility bill on which your current address appears.


We may withhold the personal information you request for the period permitted by law.


You can ask us at any time not to process your personal information for advertising purposes.


In practice, you will usually either explicitly agree in advance to the use of your personal information for advertising purposes, or we will give you the possibility to exclude your information from use for advertising purposes.


K. Third party sites

Our site includes hyperlinks and information from third-party sites. We cannot control, and are not responsible for the protection policies and practices of third parties.


L. Information updates

Please let us know if the information we have about you needs updating or correction.

M. Cookies

Our website uses cookies. A cookie is a file that contains an identifier (a series of letters and numbers) that is sent through a server and stored in the browser. The ID is then sent back to the server each time the browser requests a page from the server. Cookies can be either "permanent" or "login" cookies: a permanent cookie is stored in a browser and remains valid until its expiration date, unless deleted earlier by the user; a login cookie on the other hand will expire at the end of the user login when the browser is closed. Cookies usually do not contain information that can identify the user but your personal data we hold may be linked to data stored or retrieved by cookies. Connection cookies and permanent cookies on our website:

1. The names of the cookies that we use on our website and the purpose of their use are defined below:

1. we use Google Analytics and Adwords on our site to identify a computer when a user visits the site/to locate users while browsing the site/to allow the use of a shopping cart on the site/to improve the functionality of the site/to analyze the use of the site/to manage the site/to protect you from fraud and improve the site’s protection/to target ads that may be of interest to specific users.

2. Most browsers allow you to refuse cookies, for example:

1. on Internet Explorer (version 10) you can block cookies using the cookie settings found by clicking "Tools", "Internet Options", "Privacy" and "Advanced"

2. on Firefox (version 24) you can block all cookies by clicking "Tools," "Options," "Privacy," selecting "Use custom settings for history" from the menu and removing the option "Accept cookies from sites"; and

3. on Chrome (version 29), you can block all cookies by going to the "Customize and Control" menu and clicking "Settings", "View advanced settings", and "Content settings" and selecting "Block sites from data" under the "Cookies" heading.

Blocking all cookies will have a negative effect on the functionality of many websites. If you block cookies, you will not be able to use all the functions of your website.

3. You can delete cookies already stored on your computer — for example:

1. on Internet Explorer (version 10), you have to manually delete the cookie files (you can find instructions at http://support.microsoft.com/kb/278835);

2. on Firefox (version 24), you can delete cookies by clicking "Tools," "Options," and "Privacy", then selecting "Use custom history settings", by clicking "View Cookies" and "Remove All" Cookies” and

3. on Chrome (version 29), you can delete all cookies by entering the "Customize and check" menu, and clicking "Settings", "View Custom settings" and "Clear browsing data" and then selecting "Delete cookies and other site data" before clicking “Clear browsing data”.

4. Deleting all cookies will have a negative effect on the functionality of many websites.