The introduction

  1. The privacy of our website visitors is very important to us, and we are committed to protecting it. This policy explains what we will do with your personal information.

  2. Consenting to the use of cookies in accordance with the terms of this policy when you first visit our website allows us to use cookies each time you visit our website (ie, we are able to recognize you when you visit us again).

B. Credits
This document was created using a template from SEQ Legal and adapted to our needs.

C. Collection of Personal Information

The following types of personal information can be collected, stored and used:

  1. information about your visits to and use of this website, including referral source, length of visit, page views and navigation paths on the website;

  2. information, such as your e-mail address, which you enter when you register on our website (but we do not pass on our visitors' personal data to third parties);

  3. information you enter when creating a profile on our site – for example, your name, profile photos, gender, date of birth, relationship status, interests and hobbies, educational and employment information (may be used for internal use);

  4. information, such as your name and email address, that you enter to set up subscriptions to our emails and/or newsletters;

  5. information you enter while using the services on our website;

  6. information generated when using our website, including when, how often and under what circumstances you use it;

  7. information relating to everything you buy, services you use or transactions you carry out through our website, including your name, address, telephone number, email address. However, we do not have any access to debit card data or  credit;

  8. information that you post on our website with the intention of posting it on the internet, including your username, profile pictures and the content of your publications;

  9. information contained in any communications you send us by email or through our website, including the content and metadata of the communication;

  10. any other personal information you submit to us.

Before disclosing another person's personal information to us, you must obtain that person's consent to the disclosure and processing of that personal information in accordance with this policy. 

D. Use of your personal information

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for the following:

  1. administer our website and our business;

  2. customize our website for you;

  3. enable you to use the services available on our website;

  4. send products purchased through our website;

  5. provide services purchased through our website;

  6. send statements, invoices and payment reminders, as well as collect your payments;

  7. send commercial non-marketing communications;

  8. send email notifications specifically requested by you;

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

  10. send marketing communications relating to our business or the businesses of carefully selected third parties that we believe may be of interest to you, by mail or, where you specifically agreed to do so, by email or similar technology (you can let us know at any time if you don't more want more to receive marketing communications);

  11. provide third parties with statistical information about our users (but such third parties will not be able to identify any individual users from this information);

  12. handle questions and complaints made by or about you in relation to our website;

  13. keep our website secure and prevent fraud ;

  14. verify compliance with the terms and conditions governing use of our website (including monitoring private messages sent via our website's private messaging service); and

  15. other uses.

If you submit personal information for posting on our website, we will post and use that information in accordance with the license you grant us.

Your privacy settings may be used to limit the publication of your information on our website and adjusted through the use of privacy controls on the website.

Without your express consent, we will not provide your personal information to third parties for direct marketing purposes by them or third parties.

E. Disclosure of Personal Information

We may disclose your personal information to any of our employees, officers, insurers, professional advisors, 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 (this means our subsidiaries, our holding company and all of 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 relation to any ongoing or potential legal proceedings;

  3. to establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and credit risk reduction);

  4. to the buyer (or potential buyer) of any business or asset we are selling (or contemplating selling); and

  5. to anyone we reasonably believe may request a court or other competent authority to disclose such personal information when, in our reasonable opinion, such court or authority is likely to order the disclosure of such personal information.

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

F. International Data Transfers

  1. The information we collect may be stored, processed and transferred between any of the countries in which we operate in order to allow us to use the information in accordance with this policy.

  2. The information we collect may be transferred to the following countries that do not have data protection laws equivalent to those in force in the European Economic Area: United States of America, Russia, Japan, China and India.

  3. Personal information that you post (without requiring confidentiality or privacy) on social media websites or on our own website may be available, over the internet, around the world. We cannot prevent the use or misuse of such information by third parties.

  4. You expressly consent to the transfers of personal information described in this section F.

G. Retention of Personal Information

  1. Section G sets out our data retention policies and procedures, designed to help ensure compliance with our legal obligations regarding the retention and deletion of personal information.

  2. Personal information that we process for any purpose or purposes must not be kept longer than necessary for that purpose or purposes.

  3. Without prejudice to Article G-2, we will generally delete personal data belonging to the categories defined below at the date/time defined below:

    1. type of personal data will be deleted {INSERT DATE/TIME}; and


  4. Notwithstanding the other provisions of this section G, we will retain documents (including electronic documents) that contain personal data:

    1. to the extent that we are required to do so by law;

    2. if we believe the documents may be relevant to any ongoing or potential legal proceedings; and

    3. to establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and credit risk reduction).

H. Security of your personal information

  1. We will take appropriate technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.

  2. We will store all of your personal information you provide on our secure servers (protected by password and firewall).

  3. All electronic financial transactions carried out through our website will be protected by 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 sent over the internet.

  5. You are responsible for keeping the password used to access our website confidential; we will not ask for your password (except when you log in to our website).

I. Changes

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

J. Your rights

You can instruct us to delete any personal information we hold about you; If this information and data of yours is subject to a contract(s) entered into between you and us, this may require contractual cancellation and may be subject to contractual fees.  

  1. payment of a fee {If applicable or materially required}; and

  2. providing appropriate evidence of your identity (ID) document.

  3. a statement by you giving up possible contractual rights.

We may retain requested personal information to the extent permitted by law.

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

In practice, you will generally expressly agree in advance to the use of your personal information for marketing purposes, or we will offer you the opportunity to not allow the use of your personal information for marketing purposes.

K. Third Party Sites

Our website includes links to and details of third-party websites. We have no control over and are not responsible for the privacy policies and practices of third parties.

L. Information Update

Please let us know if the personal information we hold about you is incorrect, 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) that is sent by a web server to a 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” cookies or “session” cookies: a persistent cookie will be stored by a browser and will remain valid until the defined expiration date, unless deleted by the user before the expiration date; a session cookie , on the other hand, will expire at the end of the user's session, when the browser is closed. Cookies normally do not contain any information that personally identifies a user, but the personal information we store about you may be linked to information stored and obtained from cookies. {SELECT CORRECT PHRASE We only use session cookies / only persistent cookies / persistent and session cookies on our website.}

  1. The names of the cookies we use on our website and the purposes for which they are used are described below:

    1. we use Google Analytics and Adwords on our website to { INCLUDE ALL COOKIE USE CASES ON YOUR WEBSITE recognize a computer when a user accesses the website / track users as they browse the website / allow the use of a shopping cart on the website site / improve site usability / analyze site usage / administer the site / prevent fraud and improve site security / customize the site for each user / target ads that may be of particular interest to specific users / describe purpose(s) )};

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

    1. in Internet Explorer (version 10), you can block cookies using the available cookie handling cancellation settings by clicking on “Tools”, “Internet Options”, “Privacy” and “Advanced”;

    2. in Firefox (version 24), you can block all cookies by clicking on “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu and unchecking “Accept cookies from websites” ; and

    3. in Chrome (version 29), you can block all cookies by going to the "Custom and Control" menu and clicking "Settings", "Advanced" and "Site Settings" and then selecting "Block Third-Party Cookies" in section “Cookies and website data”.

Blocking all cookies will negatively impact 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 that are already stored on your computer – for example:

    1. in Internet Explorer (version 10), you must delete the cookie files manually (see instructions to do this in  );

    2. in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history”, clicking “Show cookies” and then “Remove all cookies”; and

    3. in Chrome (version 29), you can delete all cookies by going to the “Custom and Control” menu and clicking on “Settings”, “Advanced”, “Clear browsing data” and then selecting “Delete cookies and other data of websites and plugins” before clicking on “Clear browsing data”.

  2. Deleting cookies will negatively impact the usability of many websites.