Privacy Policy (cont.) II

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Privacy Policy (cont.) II

1.               Promotional Emails


1.1            You agree that we may from time to time send e-mail messages to you which offer products and services, promotions, subscriptions or registration-based services or other material. If you wish to discontinue receiving such email, you may opt-out by writing us through email at [email protected]. Your preferences will then be updated.


2.               How We Use and Process the Data


2.1            The Data collected by us from you may be used to provide you the Website Services and better understand your needs in relation thereto, to correspond with you and reply to any of your questions relating to the Website Services.


2.2            We will not rent or sell your Data to others. We may store the Data in locations outside our direct control (for instance, on servers or databases co-located with hosting providers).


2.3            If you provide any Data to us, you are deemed to have authorized us to collect, retain and use that data for the following purposes:


                 i.                    verifying your identity;


               ii.                    sending you a welcome e-mail;


             iii.                    providing you with customer service and responding to your queries, feedback or disputes;


             iv.                    conducting marketing analysis, sending surveys or newsletters, contacting you about the Website Services, products, activities, special events or offers from us or our partners and for other marketing, information, product development and promotional purposes;


               v.                    making such disclosures as may be required for any of the above purposes or as required by law, regulations and guidelines or in respect of any investigations, claims or potential claims brought on or against us;


             vi.                    sending you notices (for example, in the form of e-mails, mailings and the like) regarding products or services you are receiving and for billing and collection purposes;


            vii.                    provide and maintain the Website Services;


          viii.                    notifying you about changes to the Website Services;


             ix.                    sending you information we think you may find useful or that you have requested from us;


               x.                    enhancing and improve the Website or the Website Service such as through personalized features and content;


             xi.                    analysing the use of the Website and the Website Services and the people visiting to improve our content and Website and the Website Services;


            xii.                    investigating, preventing or taking action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies or as otherwise required by law;


2.4            We shall ensure that:


                 i.                    The Data collected and processed for and on our behalf by any party is collected and processed in accordance with applicable data privacy laws;


               ii.                    You are always made fully aware of the reasons for the collection of Data and are given details of the purpose(s) for which the Data will be used;


             iii.                    The Data is only collected to the extent that is necessary to fulfil the purpose(s) for which it is required;


             iv.                    No Data is held for any longer than necessary in light of the purpose(s) for which it is required.


               v.                    Whenever cookies or similar technologies are used online by us, they shall be used strictly in accordance with applicable laws;


             vi.                    You will be informed if any Data submitted by you online cannot be fully deleted at your request under normal circumstances and how to request deletion of any other copies of that Data, where it is within your right to do so;


            vii.                    Appropriate technical and organizational measures are taken to protect the Data;


          viii.                    Data is transferred securely, whether it is transmitted electronically or in hard copy;


             ix.                    You can fully exercise your rights with ease and without hindrance.


3.               Disclosure of Data


3.1            We shall not be able to keep your Data private in response to legal process, i.e. a court order or a subpoena or a law enforcement agency’s request. If, in our view, it is deemed appropriate to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use or as otherwise required by law, we may be compelled to disclose the Data. Moreover, in case of takeover, merger or acquisition, we reserve a right to transfer your Data to new platform.


3.2            We may disclose the Data in the good faith belief that such action is necessary to:


                 i.                    comply with a legal obligation;

               ii.                    protect and defend our rights or property;

             iii.                    prevent or investigate possible wrongdoing;

             iv.                    protect the personal safety of users of the Website Services or the public;

               v.                    protect against legal liability.


3.3            When necessary, we may also disclose and transfer your Data to our professional advisors, law enforcement agencies, insurers, government and regulatory and other organizations.


4.               Data Storage


4.1            Your Data may be stored and processed at the servers in United Kingdom, Canada, United States, Europe or any other country in which we or our subsidiaries, affiliates or service providers maintain facilities.


4.2            We may transfer your Data to affiliated entities or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.


4.3            We will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with this Privacy Policy and no transfer of your Data will take place to an organization or a country unless there are adequate controls in place including the security of your Data.


4.4            We will only retain your Data preferably for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any record retention or reporting requirements under applicable laws. When deciding what the correct time is to keep the Data, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

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