This Privacy Policy outlines our approach to handling your data,
detailing how we collect, use, and share your information when you
interact with our Service, as well as informing you of your privacy
rights and legal protections. By using our Service, you consent to
our practices regarding data collection and usage, as outlined in
this Policy.
Key Terms and Their Meanings
Definitions:
-
Account: A distinct account created for your
access to our Service or specific sections of it.
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Business: In the context of the CCPA (California
Consumer Privacy Act), this refers to our Company, which is
responsible for gathering and processing personal information of
consumers, determining how and why this information is handled,
and operating within California.
-
Company: Referred to as "We," "Us," or "Our,"
this term refers to the business located at 73-75 Charing Cross
Rd, London WC2H 0NE, United Kingdom. Under GDPR, the Company acts
as the Data Controller.
-
Consumer: Defined under the CCPA as any
individual who is a resident of California, either temporarily
within or outside the USA, but considered a permanent resident.
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Cookies: Small data files placed on your device
by websites, used for storing details like your browsing history.
-
Country: Refers to the location of our Company at
73-75 Charing Cross Rd, London WC2H 0NE, United Kingdom.
-
Data Controller: As per the GDPR, the Company
that determines the purposes and methods of processing Personal
Data.
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Device: Any tool capable of accessing our
Service, such as a computer, smartphone, or tablet.
-
Do Not Track (DNT): A U.S.-promoted initiative,
especially by the FTC, allowing users to manage how their online
activities are tracked across different websites.
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Personal Data: Information that identifies or can
identify an individual.
The above definitions and policies apply regardless of whether terms
are used in singular or plural form.
For the purposes of GDPR, "Personal Data" encompasses any
information related to you, such as your name, identification
number, location data, online identifiers, or attributes specific to
your physical, physiological, genetic, mental, economic, cultural,
or social identity.
Under the CCPA, "Personal Data" refers to any information that can
identify, describe, or be linked directly or indirectly to you.
-
Sale: Within the scope of the CCPA, a "sale"
involves the transfer, disclosure, or communication of a
consumer's personal information to another business or third
party, in exchange for monetary or other valuable consideration.
- Service: Refers to the Website.
-
Service Provider: Any individual or legal entity
that processes data on behalf of the Company. This term includes
third-party companies or individuals hired by the Company to
assist with providing, facilitating, or analyzing the Service.
Under GDPR, these entities are known as Data Processors.
-
Third-party Social Media Service: Refers to any
social network or website through which a user can log in or
create an account to access the Service.
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Usage Data: Data automatically collected through
the use of the Service or the infrastructure of the Service
itself, such as the duration of a page visit.
-
Website: The website accessible from the
specified web address.
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You: The individual using or accessing the
Service, or the company or other legal entity represented by that
individual. Under GDPR, you may be referred to as the Data Subject
or User, indicating that you are the individual utilizing the
Service.
Collection and Use of Your Personal Data
Types of Data Collected
Personal Data:
While engaging with our
Service, we may request certain personally identifiable details from
you that can be utilized to contact or identify you. This data may
include, but is not limited to:
- Email address
- First and last name
- Phone number
-
Address details (Street, State, Province, ZIP/Postal code, City)
-
Social Media Profile Information (e.g., using "Connect with
Facebook" or "Sign In with Twitter")
- Additional Information
Usage Data:
Usage Data is gathered
automatically when you interact with the Service. This data might
encompass details like your Device's Internet Protocol (IP) address,
browser type, browser version, the specific pages you visit on our
Service, the date and time of your visit, time spent on those pages,
unique device identifiers, and other diagnostic data.
When accessing the Service via a mobile device, we may automatically
collect specific information, such as the type of mobile device, its
unique ID, IP address, mobile operating system, mobile Internet
browser type, unique device identifiers, and additional diagnostic
data.
Additionally, we may gather data that your browser sends each time
you visit our Service or access it via a mobile device.
Information from Third-Party Social Media Services:
Our Company enables you to create an account and log in to
use the Service through various Third-Party Social Media Services,
including:
If you opt to register or grant us access via a Third-Party Social
Media Service, we may collect personal data already associated with
your social media account, such as your name, email address,
activities, or contact list linked to that account.
You may also have the choice to share additional data with us
through your Third-Party Social Media account. By providing such
information and Personal Data, whether during registration or
otherwise, you grant the Company permission to use, share, and store
this data in line with this Privacy Policy.
Tracking Technologies and Cookies
We employ Cookies and similar tracking tools to monitor activity on
our Service and store certain types of information. These tracking
mechanisms include beacons, tags, and scripts that help in gathering
and analyzing data to enhance our Service. The specific technologies
we use may involve:
-
Cookies or Browser Cookies: Cookies are small
files placed on your device. You can configure your browser to
reject all Cookies or to alert you when a Cookie is being sent.
However, declining Cookies may limit your ability to use certain
features of our Service. Unless you have adjusted your browser
settings to refuse Cookies, our Service may utilize them.
-
Web Beacons: Some parts of our Service and emails
might contain small electronic files called web beacons (also
known as clear gifs, pixel tags, or single-pixel gifs). These
allow us to count users who have visited specific pages or opened
an email and are used for other website statistics, such as
gauging the popularity of certain content and verifying system
integrity.
Cookie Types:
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Persistent Cookies: These remain on your device
even when you are offline.
-
Session Cookies: These are deleted as soon as you
close your browser.
We use both types of Cookies for the following purposes:
-
Necessary / Essential Cookies:
Type: Session
Cookies
Administered by: Us
Purpose: These Cookies are
crucial for providing you with services available through our
Website and enabling you to use certain features. They
authenticate users and prevent fraudulent use of user accounts.
Without these Cookies, some services you request cannot be
provided.
-
Cookies Policy / Notice Acceptance Cookies:
Type: Persistent Cookies
Administered by: Us
Purpose:
These Cookies track whether you have accepted the use of cookies
on the Website.
-
Functionality Cookies:
Type: Persistent
Cookies
Administered by: Us
Purpose: These Cookies allow
us to remember your preferences, such as login details or language
selection, to enhance your experience and avoid the need to
re-enter your choices each time you use the Website.
-
Tracking and Performance Cookies:
Type:
Persistent Cookies
Administered by: Third-Parties
Purpose:
These Cookies collect information about how visitors use the
Website, which may identify you indirectly through a pseudonymous
identifier linked to your device. We may also use these Cookies to
test new pages, features, or functions of the Website to see how
users respond.
-
Targeting and Advertising Cookies:
Type:
Persistent Cookies
Administered by: Third-Parties
Purpose:
These Cookies track your online behavior to display advertising
that is more relevant to your interests. They use your browsing
history to group you with other users who have similar interests,
allowing third-party advertisers to place relevant ads based on
this information, with our permission.
For more information on the Cookies we use and your choices
regarding them, please refer to our Cookies Policy or the Cookies
section of our Privacy Policy.
Use of Your Personal Data
The Company may utilize your Personal Data for the following
purposes:
-
To provide and maintain our Service: Including
monitoring the usage of our Service.
-
To manage Your Account: Managing your
registration as a user of the Service, allowing you access to
different functionalities available to registered users.
-
For the performance of a contract: Fulfilling and
managing any contract between you and us, such as purchasing
products or services through the Service.
-
To contact You: Reaching out via email, phone
calls, SMS, or other electronic communications, such as push
notifications from mobile apps, to inform you of updates or other
information related to the functionalities, products, or services
you have contracted, including security updates.
-
To provide You with news and offers: Keeping you
informed about goods, services, and events similar to those you
have already purchased or inquired about, unless you opt out of
receiving such information.
-
To manage Your requests: Handling and responding
to any inquiries or requests you make.
-
To deliver targeted advertising: Using your
information to create and display content and advertisements that
match your interests or location, and working with third-party
vendors to do so.
-
For business transfers: Evaluating or conducting
mergers, divestitures, reorganizations, dissolutions, or other
transactions involving the sale or transfer of our assets, where
your Personal Data may be included as part of the transferred
assets.
-
For other purposes: Employing your information
for tasks such as data analysis, identifying usage trends,
evaluating the effectiveness of promotional campaigns, and
improving our Service, products, services, marketing, and your
experience.
Sharing Your Personal Information
Your personal information may be shared in the following scenarios:
-
With Service Providers: We may share your
information with third-party providers to monitor and analyze
Service usage, display advertisements, process payments, or
contact you.
-
For business transfers: Sharing or transferring
your information during negotiations or completion of any merger,
asset sale, financing, or acquisition of our business by another
entity.
-
With Affiliates: Sharing your information with
our affiliates, who will be required to adhere to this Privacy
Policy. Affiliates include our parent company, subsidiaries, joint
ventures, or other companies we control or are under common
control with us.
-
With business partners: Sharing your information
with business partners to offer you certain products, services, or
promotions.
-
With other users: If you interact publicly with
other users, your information may be viewed by others and shared
outside the platform. For example, if you register or interact via
a Third-Party Social Media Service, your contacts on that platform
may see your profile, name, and activity.
-
With Your consent: Disclosing your personal
information for any other purpose if you have given consent.
Retention and Storage of Personal Information
Your Personal Information will only be kept by the Company for the
duration necessary to fulfill the purposes outlined in this Privacy
Policy. This retention is done to comply with legal
responsibilities, resolve disputes, and enforce our legal agreements
and policies. If we are legally required to keep your information,
such as for compliance with laws, we will retain it. Additionally,
we may hold onto Usage Data for internal analysis, although this is
generally kept for a shorter period unless it’s needed for
improving security, functionality, or to meet legal obligations.
Transfer of Information
Your data, including Personal Information, may be processed and
stored in locations outside of your current jurisdiction, including
at the Company’s operational offices and other locations where
involved parties are based. This means your data might be
transferred to and stored on computers in jurisdictions with
different data protection laws than your own. By submitting your
information and agreeing to this Privacy Policy, you consent to such
transfers. The Company will ensure that your data is handled
securely and in accordance with this Privacy Policy, and will only
transfer your data to a country or organization that has adequate
data protection measures in place.
Disclosure of Personal Information
-
Business Transactions: If the Company undergoes a
merger, acquisition, or sale of assets, your Personal Information
might be transferred as part of that transaction. We will notify
you before your data is transferred and becomes subject to a
different Privacy Policy.
-
Legal Requirements: The Company may be required
to disclose your Personal Information to comply with legal
obligations or in response to valid requests from authorities
(e.g., courts or government agencies).
-
Other Legal Reasons: We may disclose your
information if it is necessary to:
- Fulfill a legal obligation.
- Protect and defend the rights or property of the Company.
-
Prevent or investigate possible wrongdoing in relation to the
Service.
- Safeguard the safety of users or the public.
- Defend against legal liabilities.
Data Security
We prioritize the protection of your Personal Information, but
it’s important to remember that no method of data transmission
or electronic storage is completely secure. While we use
commercially reasonable measures to safeguard your data, we cannot
guarantee absolute security.
Processing by Service Providers
Our Service Providers, who may have access to your Personal
Information, are bound by their own Privacy Policies. These third
parties collect, store, use, process, and transfer your information
in line with their privacy practices while providing services such
as analytics or payment processing.
Analytics
We may engage third-party analytics services to monitor and evaluate
the use of our Service. For example:
-
Google Analytics: This service tracks and reports
website traffic, and Google may use the data collected to
personalize its advertising network. You can prevent your activity
from being tracked by Google Analytics by installing an opt-out
browser add-on. For more details, visit Google’s Privacy
Policy at
https://policies.google.com/privacy.
Payment Processing
For paid services or products, we may utilize third-party payment
processors. Your payment details are handled directly by these
processors and are not stored or collected by us. These processors
comply with PCI-DSS standards, which ensure secure handling of
payment data. Examples include:
GDPR Compliance
Legal Grounds for Data Processing
We may process your Personal Data based on the following legal
grounds:
-
Consent: You have given explicit permission for
one or more specific purposes.
-
Contractual Necessity: The processing is required
for fulfilling a contract with you or to take pre-contractual
steps.
-
Legal Obligations: Processing is required to
comply with a legal obligation to which the Company is subject.
-
Vital Interests: Processing is necessary to
protect your vital interests or those of another individual.
-
Public Interest: Processing is related to a task
carried out in the public interest or in the exercise of official
authority vested in the Company.
-
Legitimate Interests: Processing is necessary for
the legitimate interests pursued by the Company.
The Company is available to clarify the legal basis for processing
your Personal Data, including whether the provision of data is
legally or contractually required, or necessary to enter into a
contract.
Your GDPR Rights
The Company is committed to safeguarding your Personal Data and
ensuring you can exercise your rights under the GDPR. If you are
within the EU, you have the following rights under this Privacy
Policy and applicable law:
-
Access Your Data: You have the right to access,
update, or delete the information we hold about you. This can
usually be done directly through your account settings. If
you’re unable to perform these actions, you can contact us
for assistance. You can also request a copy of your Personal Data
that we hold.
-
Rectify Inaccuracies: If any information we have
is incomplete or incorrect, you have the right to have it
corrected.
-
Object to Processing: You may object to our
processing of your Personal Data where we rely on legitimate
interest as the basis, especially if there’s something
specific about your situation that makes you want to object. You
can also object if your data is being processed for direct
marketing purposes.
-
Request Erasure: You have the right to ask for
the deletion of your Personal Data when there’s no valid
reason for us to continue processing it.
-
Data Portability: You can request that your
Personal Data be provided to you or a third party in a structured,
machine-readable format. This right applies only to automated
information that you initially consented to be used or that was
used to perform a contract with you.
-
Withdraw Consent: You can withdraw your consent
to our use of your Personal Data at any time. Be aware that this
may limit your access to certain functionalities of the Service.
Exercising Your GDPR Rights
To exercise your rights to access, rectify, cancel, or object to
your data’s processing, please contact us. We may ask for
verification of your identity before processing such requests. We
aim to respond as quickly as possible. If you’re in the EEA
and have concerns about our data practices, you also have the right
to lodge a complaint with your local Data Protection Authority.
California Consumer Privacy Act (CCPA) Rights
This section of the Privacy Policy is specifically for California
residents and provides additional details relevant to those living
in the State of California.
Categories of Personal Information Collected
We collect information that can identify, relate to, describe, or be
associated with you or your device. The categories of personal
information we may collect or have collected from California
residents within the last 12 months include:
-
Category A: Identifiers (e.g., real name, alias,
postal address, email address, account name, IP address,
driver’s license number, passport number).
-
Category B: Personal Information Categories per California
Customer Records statute
(e.g., name, Social Security number, physical characteristics,
address, telephone number, bank account number, health insurance
information).
-
Category C: Protected Classification Characteristics
under California or federal law (e.g., age, race, religion,
marital status, disability, sexual orientation, veteran status).
-
Category D: Commercial Information (e.g., records
of products or services purchased).
-
Category E: Biometric Information (e.g.,
fingerprints, voiceprints, retina scans).
-
Category F: Internet Activity (e.g., browsing
history, interaction with websites).
-
Category G: Geolocation Data (e.g., approximate
physical location).
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Category H: Sensory Data (e.g., audio,
electronic, visual information).
-
Category I: Professional or Employment Information
(e.g., job history, performance evaluations).
-
Category J: Non-public Education Information
(e.g., student records, grades).
-
Category K: Inferences Drawn from Personal Information
(e.g., profiles indicating preferences, characteristics).
Note that the categories listed above reflect those defined by the
CCPA and do not necessarily mean we have collected all examples from
each category. We collect personal information directly from you,
indirectly through your activity on our Service, automatically via
cookies, and from third-party service providers.
Use of Personal Information
We may use or disclose personal information for "business" or
"commercial" purposes as defined under the CCPA. This includes:
-
Operating the Service: Ensuring the functionality
and delivery of our Service.
-
Providing Support: Responding to inquiries,
addressing concerns, and improving our Service.
-
Fulfilling Transactions: Using personal
information to process payments or facilitate orders.
-
Legal Compliance: Responding to law enforcement
requests or complying with legal obligations.
-
Administrative Purposes: Conducting internal
audits and analysis.
-
Security: Detecting and protecting against
security incidents and fraud.
These examples are illustrative, not exhaustive. If we collect new
categories of personal information or use existing information for
new purposes, we will update this Privacy Policy accordingly.
Disclosure of Personal Information
In the last 12 months, we may have disclosed the following
categories of personal information for business or commercial
purposes:
- Category A: Identifiers
-
Category B: Personal Information Categories (Cal. Civ. Code
§ 1798.80(e))
- Category D: Commercial Information
- Category F: Internet Activity
When we disclose personal information for a business or commercial
purpose, we ensure that the recipient is bound by contract to keep
the information confidential and only use it for the agreed purpose.
Sharing of Personal Information
We may share your personal information, as categorized above, with
the following types of third parties:
- Service Providers
- Payment Processors
- Affiliates
- Business Partners
-
Third-Party Vendors: These are entities to whom
you or your representatives have authorized us to disclose your
personal information in connection with the services or products
we provide.
Your Rights Under the CCPA
If you reside in California, the CCPA grants you specific rights
concerning your personal data:
-
Right to Be Informed: You have the right to know
what categories of personal data are being collected and for what
purposes.
-
Right to Access: You can request that we disclose
information regarding our collection, use, and sharing of your
personal data. Upon receiving and verifying your request, we will
provide details such as:
- Categories of personal data collected.
- Sources of personal data.
-
Business or commercial purposes for data collection or sale.
- Third parties with whom data is shared.
- Specific pieces of personal data collected.
-
If applicable, categories of personal data sold or disclosed for
business purposes.
-
Right to Opt-Out: You can instruct us not to sell
your personal data. To exercise this right, please contact us.
-
Right to Deletion: You may request that we delete
your personal data, subject to certain exceptions. Once verified,
we will delete your data unless it is necessary for:
- Completing transactions or services requested by you.
-
Detecting and protecting against security incidents or illegal
activities.
- Debugging and repairing issues.
- Exercising legal rights, such as free speech.
- Compliance with legal obligations.
-
Engaging in research that adheres to ethical and privacy laws,
where deletion would impair the research.
-
Other internal and lawful uses compatible with the context in
which you provided the data.
-
Right to Non-Discrimination: You will not face
discrimination for exercising your rights. This means we
won’t:
- Deny you goods or services.
-
Charge different prices or offer different levels of service.
-
Suggest that you may receive a different price or level of
service if you exercise your rights.
How to Exercise Your CCPA Rights
To exercise any of your rights under the CCPA, if you are a
California resident, please contact us via:
Only you or an authorized agent registered with the California
Secretary of State can make a verifiable request regarding your
personal information. Your request must:
-
Provide sufficient information to verify your identity or your
authorized representative’s identity.
-
Describe your request in sufficient detail to allow us to
understand, evaluate, and respond to it.
We may not respond to your request if we cannot verify your identity
or confirm that the information relates to you. We will provide the
requested information free of charge within 45 days, with the
possibility of extending this timeframe once by an additional 45
days, if necessary.
California Shine the Light Law
Under California Civil Code Section 1798, California residents who
have an established business relationship with us can request
information once per year about how we share their personal data
with third parties for direct marketing purposes. If you wish to
request this information, please contact us using the details
provided below.
California Privacy Rights for Minors
California residents under 18 who are registered users of online
services can request the removal of publicly posted content. To
request such removal, please contact us and include the email
address associated with your account. Note that this removal is not
guaranteed and may not be possible under certain legal
circumstances.
Links to External Sites
Our Service may contain links to third-party websites, which we do
not operate. If you click on such a link, you will be redirected to
the third party’s site. We recommend reviewing the Privacy
Policy of every site you visit, as we do not control and are not
responsible for the content, policies, or practices of these sites.
Changes to Our Privacy Policy
We may update this Privacy Policy periodically. We will notify you
of significant changes by posting the new policy on this page and
updating the "Last Updated" date. We may also inform you via email
or a prominent notice on our Service before the changes take effect.
We encourage you to review this Privacy Policy periodically to stay
informed about any changes.
Contact Information
If you have any questions about this Privacy Policy, please contact
us via:
