Data protection

A. Introduction

  • The privacy of visitors to our website is very important to us, and we are committed to protecting it. This policy details what we do with your personal information.
  • Consenting to our use of cookies in accordance with this policy during your first visit to 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)
    and has been modified by LANOTA.

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, geographic location, browser type and version, and operating system;
  2. Information about your visits and use of this website, including referral source, length of visit, pages viewed, and website navigation paths;
  3. Information such as your email address, which you provide to us when registering on the site;
  4. Information you enter when creating a profile on our website, such as your name, profile picture, gender, date of birth, marital status, interests and hobbies, educational and professional background;
  5. Information such as your name and email address, which you enter to subscribe to our emails and/or newsletters;
  6. Information you enter when using our website's services;
  7. Information generated when using our site, including when, how often, and under what circumstances you use it;
  8. Information related to purchases you make, services you use, or transactions you conduct on our site, which include your name, address, phone number, email address, and banking information;
  9. Information you publish on our website with the intention of publishing it on the internet, including your username, profile pictures, and the content of your posts;
  10. Information contained in any communications you send us by email or through our website, including their content and metadata;
  11. Any other personal information you provide to us.


Before disclosing to us any personal information about another person, you must obtain the consent of that person regarding the disclosure and processing of such personal information in accordance with the terms of this policy.

D. Use of Your Personal Information

The personal information provided to us through our website will be used for the purposes described in this policy or on the relevant website pages. We may use your personal information to:

  1. Administer our website and business;
  2. Customize our website for you;
  3. Enable your use of the services offered on our website;
  4. Send you the goods purchased on our site;
  5. Provide you with the services purchased on our site;
  6. Send you statements, invoices, and payment reminders, and collect your payments;
  7. Send you non-marketing commercial communications;
  8. Send you email notifications that you have expressly requested;
  9. Send you our newsletter by email, if you have requested it (you can inform us at any time of your desire to no longer receive our newsletter);
  10. Send you marketing communications related to our company or carefully selected third-party companies that we believe may be of interest to you, in the form of publications, or if you have expressly given your consent, by email or similar technology (you can inform us at any time of your desire to no longer receive marketing communications).
  11. Provide statistical information about our users to third parties (without these third parties being able to identify individual users with this information);
  12. Process requests and complaints about your website made by you or concerning you;
  13. Maintain the security of our website and prevent fraud;
  14. Verify compliance with the general conditions governing the use of our website (including monitoring private messages sent through our website's private messaging service); and
  15. Other uses.

If you submit personal information on our website for the purpose of publishing it, we will publish it and may use this information in accordance with the permissions you grant us.

Your privacy settings may be used to limit the publication of your information on our website and can be adjusted in your privacy settings on the website.

Without your explicit consent, we will not provide your personal information to third parties for their direct marketing, nor that of other third parties.

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 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 (meaning our subsidiaries, our ultimate holding company, and all its subsidiaries) 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 ongoing or prospective 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 buyer (or prospective buyer) of any business or asset that we are (or are contemplating) selling; and
  5. To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

F. Transfers of personal data

  • The information that we collect may be stored, processed, and transferred to any country where we operate, to enable us to use the information in accordance with this policy.
  • The information that 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.
  • Personal information that you publish on our website or submit for publication may be available, via the internet, around the world. We cannot prevent the use, good or bad, of this information by third parties.
  • You expressly agree to the transfer of personal information described in this Section F.

G. Conservation of your personal information

  • This Section G details our data retention policies and procedures, designed to help ensure compliance with our legal obligations regarding the retention and deletion of personal information.
  • 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.
  • Without prejudice to Article G-2, we will generally delete personal data from these categories on the date and time specified below:
    1. This type of personal data will be deleted {ENTER DATE/TIME}; and
    2. {ENTER OTHER DATES/TIMES}.
  • Notwithstanding the other provisions of this Section G, we will retain documents (including electronic documents) containing personal data:
    1. To the extent that we are required to do so by law;
    2. If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
    3. 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

  • We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.
  • We will store all the personal information you provide on secure servers (password- and firewall-protected).
  • All electronic financial transactions made through our website will be protected by encryption technology.
  • You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
  • You are responsible for keeping the password you use to access our website confidential; we will not ask you for your password (except when you log in to our website).

I. Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page regularly to ensure that you are familiar with 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; provision of such information will be subject to the following:

  1. Payment of a fee {INSERT FEES IF APPLICABLE}; and
  2. Supply of appropriate evidence of your identity {ADJUST TEXT TO REFLECT YOUR POLICY} (for this purpose, we will usually accept a photocopy of your passport certified by a notary plus an original copy of a utility bill showing your current address).

We may withhold personal information that you request to the extent permitted by law.

You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually 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 may contain hyperlinks to third-party websites and information about them. We have no control over these websites 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.

M. 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" cookies: a persistent cookie is stored by the browser and remains valid until its expiration date, unless deleted by the user before the expiration date; a session cookie, on the other hand, expires at the end of the user session, when the browser is closed. Cookies generally do not contain any information that personally identifies a user, but personal information we store about you may be linked to the information stored in and obtained from cookies. {SELECT THE APPROPRIATE FORMULA: We only use session cookies / we only use persistent cookies / we use both session and persistent cookies on our website.}

  1. The names of the cookies that we use on our website and the purposes for which we use them are described below:
    1. We use Google Analytics and Adwords on our website to: {INCLUDE ALL WAYS COOKIES ARE USED ON YOUR SITE} recognize a computer when a user visits the website/ track users as they navigate the website/ enable the use of a shopping cart on the website/ improve the website's usability/ analyze the use of the website/ administer the website/ prevent fraud and improve the security of the website/ personalize the website for each user/ serve targeted advertisements that may be of interest to certain users (describe your other purposes);
  2. Most browsers allow you to refuse or accept cookies. For example:
    1. with Internet Explorer (version 10), you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
    2. with Firefox (version 24), you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unchecking "Accept cookies from sites"; and
    3. with Chrome (version 29), you can block all cookies by accessing the "Customize and control" menu, clicking "Settings", "Show advanced settings" and "Content settings", and selecting "Block sites from setting any data" under the "Cookies" header.

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

  1. You can delete cookies already stored on your computer. For example:
    1. with Internet Explorer (version 10), you must manually delete the cookie file (you can find instructions on how to do this here http://support.microsoft.com/kb/278835);
    2. with Firefox (version 24), you can delete cookies by clicking on "Tools", "Options", and "Privacy", then selecting "Use custom settings for history" and clicking on "Show Cookies", and then "Remove All Cookies"; and
    3. with Chrome (version 29), you can delete all cookies by accessing the "Customize and Control" menu and clicking on "Settings", "Show Advanced Settings", and "Clear Browsing Data", then "Delete cookies and other site and plug-in data" before clicking "Clear Browsing Data".
  2. Deleting cookies will have a negative impact on the use of many websites.
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