Introduction

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We ("we" or "us") care about the privacy of users ("user" or "you") of our website and/or mobile space (the "Site" and "Mobile Space", respectively) and are committed to protecting the information that users share with us while using our Site and/or Mobile Space (collectively, the "Digital Properties"), and we are fully committed to protecting and using your information in accordance with applicable law.

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This Privacy Policy describes our practices for collecting, using and disclosing your information through our digital properties (the "Services"), when you access the Services from your device.

 

Before accessing or using any of our Services, please read this Privacy Policy carefully and make sure that you fully understand our practices regarding your information. If you read and fully understand this Privacy Policy, and you still object to our practices, you must immediately cease all use of our Digital Properties and Services. By using our Services, you accept the terms of this Privacy Policy and your continued use of the Services constitutes your acceptance of this Privacy Policy and any amendments thereto.

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In this Privacy Policy, you will find explanations on the following issues:

• The information we collect

• How we collect information

• Why we collect the information

• With whom we share the information

• Where the information is stored 

• How long the information is kept for

• How we protect the information

• Minors

• Changes or updates to the Privacy Policy

 

The information we collect

 

Below are the different types of information we may collect.

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• Non-personally identifiable information, which may be provided by you during the registration process or collected when you use our Services ("Non-Personal Information"). Non-Personal Information does not allow us to identify the person from whom it was collected. The Non-Personal Information we collect consists primarily of technical information and aggregate usage information.

• Information that identifies you individually, i.e. information that identifies you or that can, with a reasonable effort, identify you ("Personal Information"). The Personal Information we collect through our Services includes name, email address, address, telephone number, IP address or other information requested whenever necessary. If we combine Personal Information with Non-Personal Information, we will treat the combined information as Personal Information for as long as it remains combined.

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How we collect information 

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Below are the main methods we use to collect information:

• We collect information when you use the Services. When you visit our Digital Properties or use our Services, we may collect, collate and record such usage, sessions and related information.

• We collect information that you voluntarily provide to us. For example, we collect information you provide to us when you contact us directly through any communication channel (for example when you send us an email containing a comment or feedback).

• We may collect information from third party sources as described below.

• We collect information from you if you connect to our Services through third party services such as Facebook or Google.

 

Why we collect information

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We use your Personal Information for the following purposes:

• To provide and operate the Services

• To develop, personalise and improve our Services

• To respond to your feedback, requests and enquiries and to provide you with support

• To analyse demand and usage patterns

• For other internal, research or statistical purposes

• To enhance our data security and fraud prevention capabilities

• To investigate possible breaches, enforce our terms or policies, or comply with any applicable law, regulation or government authority.

• To send you updates, notices, promotional materials and other information regarding our Services. If we send you promotional emails, you may opt out of receiving them by clicking on the unsubscribe link that such emails contain.​

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With whom we share information

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We may share your information with our service providers, in order to operate our Services (for example, storing information on third party hosting services, providing our technical support, etc.).

 

We may also disclose your information in the following circumstances: (i) to investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security matters; (ii) to establish or exercise our rights of defence against legal claims; (iii) to protect our rights, property or personal safety and those of our users or the general public ; (iv) if we or any of our affiliates undergo a change of control, including by way of merger, acquisition or purchase of all or substantially all of our assets; (v) to collect, hold and/or manage your information through our authorised third party service providers (e.g. online service companies), as is reasonable for business purposes; or (vi) to cooperate with third parties to improve your experience. For the avoidance of doubt, we may transfer and disclose to third parties or otherwise use Non-Personal Information in our sole discretion.

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Cookies and similar technologies

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When you visit or access our Service, we allow certain third parties to use web beacons, cookies, web beacons, scripts, tags and other analytics technologies and services ("Tracking Technologies"). These Tracking Technologies may enable third parties to automatically collect information about you in order to improve the way you browse our Digital Properties, to improve the performance of our Digital Properties and to personalise your experience on our Digital Properties, as well as for security and fraud prevention purposes.

 

We will not share your e-mail address, or any other Personal Information, with online advertising companies or ad networks without your consent.

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Where is the information stored

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Non-personal information

 

Please note that our businesses, as well as the partners and service providers we trust, are located around the world. Any Non-Personal Information we collect is stored and processed in various jurisdictions around the world for the purposes detailed in this Privacy Policy.

 

Personal information

 

Personal Information may be retained, processed and stored in the United States of America, Ireland, Japan, Israel and other jurisdictions as necessary for the proper provision of our services and/or as required by law (as explained in more detail below).

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How long we keep information

 

Please note that we retain the information we collect for as long as necessary to provide the Services and to comply with our legal or contractual obligations to you, resolve disputes and enforce our agreements.

We may correct, supplement or delete incomplete or inaccurate information at any time at our sole discretion.

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How we protect information

 

The hosting service for our Digital Properties provides us with the online platform that enables us to provide the Service to you. Your data may be stored through our hosting provider's data storage, database or general purpose applications. They store your information on secure servers behind a firewall and offer secure HTTPS access to most of their services.

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All direct payment gateways offered by the host of our Digital Properties and used by us comply with the standards established by PCI-DSS, as administered by the PCI Security Standards Council, which is a joint effort of companies such as Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure processing of credit card information by our shop and its service providers, including physical, electronic and procedural measures.

 

Regardless of the efforts made and measures taken by us and our hosting provider, we cannot and do not guarantee the absolute protection and security of any information you upload, post or otherwise share with us or anyone else.

We encourage you to set strong passwords and to avoid providing us or anyone else with sensitive information the disclosure of which you believe could cause you substantial or irreparable harm. In addition, as e-mail and instant messaging are not recognised as secure forms of communication, we ask and encourage you not to share sensitive information via these methods.

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Minors

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The Services are not intended for underage users. We do not knowingly collect information from children. If you are under the age of majority, you must not download or use the Services or provide any information to us.

 

We reserve the right to request proof of age at any time to ensure that minors do not use our Services. If we become aware that a person under the age of majority is using our Services, we may prohibit and block that user's access to our Services, as well as delete all information stored with us relating to that user. If you have reason to believe that a minor has shared information with us, please contact us as indicated below.

 

We will only use your Personal Information for the purposes set out in this Privacy Policy, if:

• The use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (for example, to provide you with the Services or to provide you with our customer or technical support)

• It is necessary for us to use your Personal Information to comply with a relevant legal or regulatory obligation

• It is necessary for us to use your Personal Information for our legitimate interests as a business, provided that such use is at all times proportionate and respectful of your privacy rights.

 

If you reside in the EU, you may:

• Request confirmation as to whether or not Personal Information about you is being processed, and access the Personal Information we store about you, as well as certain additional information.

• Request to receive Personal Information that you provide to us directly on a voluntary basis in a structured, commonly used and machine-readable format

• Request rectification of your Personal Information that is under our control

• Request the erasure of your Personal Information

• Object to the processing of your Personal Information by us

• Request the restriction of the processing of your Personal Information by us.

• File a complaint with a supervisory authority

 

However, please note that these rights are not absolute and may be subject to our own legitimate interests or regulatory requirements. If you have any general questions about the Personal Information we collect and how we use it, please contact us as set out below.

In the course of providing the Services to our users, we may transfer information to affiliated entities or other third parties beyond the borders of your country or jurisdiction to other countries or jurisdictions around the world. By using the Services, you consent to the transfer of your information outside the EEA.

If you are located in the EEA, your Personal Information may only be transferred to locations outside the EEA if we are satisfied that an adequate or comparable level of protection is in place to protect the Personal Information. We will take reasonable steps to ensure that we have appropriate contractual arrangements with our third parties to ensure that adequate safeguards are in place so that the risks of unlawful use, alteration, deletion, loss or theft of your Personal Information are minimised, and that such third parties act at all times in compliance with applicable laws.

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CCPA Rights relating to your information

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If you are a California resident using the Services, the California Consumer Privacy Protection Act (the "CCPA") may give you the right to request access to and deletion of your information.

 

To exercise your right to access and delete your information, please contact us as set forth below.

 

Users of the Services who are residents of California and under the age of 18 may request and obtain the removal of any content they have posted by sending an e-mail to us at the address set forth below in the "Contact Us" section.  Any such request must include the words "California Removal Request" in your e-mail. Any such request must include a description of the content you wish to remove and information reasonably sufficient to permit us to locate the content. We reject all "California Removal Requests" that are not properly marked or sent, and we may not be able to respond if you do not provide adequate information. Please note that your request does not guarantee complete or exhaustive removal of the content concerned. For example, documents published by you may be republished by another user or a third party.

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Changes or updates to the Privacy Policy

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We may revise this Privacy Policy from time to time in our sole discretion, and the most current version will always be posted on our website (as indicated in the "Last Revised" section). We encourage you to periodically review this Privacy Policy for any changes. If there are material changes, we will post a notice on our website announcing those changes.  Your continued use of the Services following the posting of changes on our website will constitute your acknowledgement of, and consent to, such changes to the Privacy Policy and your agreement to be bound by the terms of such changes.

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Contacting us

If you have any general questions about the Services or the information we collect about you, or how we use it, please contact us.