Privacy policy
1. Introduction
1.1 We are committed
to safeguarding the privacy of our website visitors; in this policy, we explain
how we will treat your personal information.
1.2 [We will ask you
to consent to our use of cookies in accordance with the terms of this policy
when you first visit our website.] OR [By using our website and agreeing to
this policy, you consent to our use of cookies in accordance with the terms of
this policy.]
2. Credit
2.1 This document was
created using a template from SEQ Legal (http://www.seqlegal.com).
You must retain the above credit. Use of this
document without the credit is an infringement of copyright. However, you can
purchase from us an equivalent document that does not include the credit.
3. Collecting personal information
3.1 We may collect,
store and use the following kinds of personal information:
(a) [information
about your computer and about your visits to and use of this website (including
[your IP address, geographical location, browser type and version, operating
system, referral source, length of visit, page views and website navigation
paths])];
(b) [information
that you provide to us when registering with our website (including [your email
address])];
(c) [information that
you provide when completing your profile on our website (including [your name,
profile pictures, gender, date of birth, relationship status, interests and
hobbies, educational details and employment details])];
(d) [information
that you provide to us for the purpose of subscribing to our email
notifications and/or newsletters (including [your name and email address])];
(e) [information
that you provide to us when using the services on our website, or that is
generated in the course of the use of those services (including [the timing,
frequency and pattern of service use])];
(f) [information
relating to any purchases you make of our [goods] OR [services] OR [goods
and/or services] or any other transactions that you enter into through our
website (including [your name, address, telephone number, email address and
card details])];
(g) [information
that you post to our website for publication on the internet (including [your
user name, your profile pictures and the content of your posts])];
(h) [information contained
in or relating to any communication that you send to us or send through our
website (including [the communication content and metadata associated with the
communication])]; and
(i) [any other
personal information that you choose to send to us].
3.2 Before you
disclose to us the personal information of another person, you must obtain that
person's consent to both the disclosure and the processing of that personal
information in accordance with this policy.
4. Using personal information
4.1 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.
4.2 We may use your
personal information to:
(a) [administer
our website and business];
(b) [personalise
our website for you];
(c) [enable your
use of the services available on our website];
(d) [send you
goods purchased through our website];
(e) [supply to
you services purchased through our website];
(f) [send
statements, invoices and payment reminders to you, and collect payments from
you];
(g) [send you
non-marketing commercial communications];
(h) [send you
email notifications that you have specifically requested];
(i) [send you
our email newsletter, if you have requested it (you can inform us at any time
if you no longer require the newsletter)];
(j) [send you
marketing communications relating to our business [or the businesses of
carefully-selected third parties] which we think may be of interest to you, by
post or, where you have specifically agreed to this, by email or similar
technology (you can inform us at any time if you no longer require marketing
communications)];
(k) [provide
third parties with statistical information about our users (but those third
parties will not be able to identify any individual user from that
information)];
(l) [deal with
enquiries and complaints made by or about you relating to our website];
(m) [keep our
website secure and prevent fraud]; and
(n) [verify
compliance with the terms and conditions governing the use of our website [(including
monitoring private messages sent through our website private messaging
service)]].
4.3 If you submit
personal information for publication on our website, we will publish and
otherwise use that information in accordance with the licence you grant to us.
4.4 Your privacy
settings can be used to limit the publication of your information on our
website, and can be adjusted using privacy controls on the website.
4.5 We will not,
without your express consent, supply your personal information to any third
party for the purpose of their or any other third party's direct marketing.
4.6 All our website
financial transactions are handled through our payment services provider. You
can review the provider's privacy policy at their website. We will share information
with our payment services provider only to the extent necessary for the
purposes of processing payments you make via our website, refunding such
payments and dealing with complaints and queries relating to such payments and
refunds.
5. Disclosing personal information
5.1 We may disclose
your personal information to [any of our employees, officers, insurers,
professional advisers, agents, suppliers or subcontractors] insofar as
reasonably necessary for the purposes set out in this policy.
5.2 We may disclose
your personal information to any member of our group of companies (this means
our subsidiaries, our ultimate holding company and all its subsidiaries)
insofar as reasonably necessary for the purposes set out in this policy.
5.3 We may disclose
your personal information:
(a) to the extent
that we are required to do so by law;
(b) in connection
with any ongoing or prospective legal proceedings;
(c) in order to
establish, exercise or defend our legal rights (including providing information
to others for the purposes of fraud prevention and reducing credit risk);
(d) [to the
purchaser (or prospective purchaser) of any business or asset that we are (or
are contemplating) selling]; and
(e) [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].
5.4 Except as
provided in this policy, we will not provide your personal information to third
parties.
6. International data transfers
6.1 Information that
we collect may be stored and processed in and transferred between any of the
countries in which we operate in order to enable us to use the information in
accordance with this policy.
6.2 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].
6.3 Personal
information that you publish on our website or submit for publication on our
website may be available, via the internet, around the world. We cannot prevent
the use or misuse of such information by others.
6.4 You expressly agree
to the transfers of personal information described in this Section 6.
7. Retaining personal information
7.1 This Section 7
sets out our data retention policies and procedure, which are designed to help
ensure that we comply with our legal obligations in relation to the retention
and deletion of personal information.
7.2 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.
7.4 Notwithstanding
the other provisions of this Section 7, we will retain documents (including
electronic documents) containing personal data:
(a) to the extent
that we are required to do so by law;
(b) if we believe
that the documents may be relevant to any ongoing or prospective legal proceedings;
and
(c) in order to
establish, exercise or defend our legal rights (including providing information
to others for the purposes of fraud prevention and reducing credit risk).
8. Security of personal information
8.1 We will take
reasonable technical and organisational precautions to prevent the loss, misuse
or alteration of your personal information.
8.2 We will store all
the personal information you provide on our secure (password- and
firewall-protected) servers.
8.3 All electronic
financial transactions entered into through our website will be protected by
encryption technology.
8.4 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.
8.5 You are
responsible for keeping the password you use for accessing our website
confidential; we will not ask you for your password (except when you log in to
our website).
9. Amendments
9.1 We may update
this policy from time to time by publishing a new version on our website.
9.2 You should check
this page occasionally to ensure you are happy with any changes to this policy.
9.3 We may notify you
of changes to this policy [by email or through the private messaging system on
our website].
10. Your rights
10.1 You may instruct
us to provide you with any personal information we hold about you; provision of
such information will be subject to:
(a) the payment
of a fee (currently fixed at Rs. 100); and
(b) the supply of
appropriate evidence of your identity [(for this purpose, we will usually
accept a photocopy of your passport certified by a solicitor or bank plus an
original copy of a utility bill showing your current address)].
10.2 We may withhold
personal information that you request to the extent permitted by law.
10.3 You may instruct
us at any time not to process your personal information for marketing purposes.
10.4 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.
11. Third party websites
11.1 Our website
includes hyperlinks to, and details of, third party websites.
11.2 We have no control
over, and are not responsible for, the privacy policies and practices of third
parties.
12. Updating information
12.1 Please let us know
if the personal information that we hold about you needs to be corrected or
updated.
13. Cookies
13.1 Our website uses
cookies.
13.2 A cookie is a file
containing an identifier (a string of letters and numbers) that is sent by a
web server to a web browser and is stored by the browser. The identifier is
then sent back to the server each time the browser requests a page from the
server.
13.3 Cookies may be
either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.
13.4 Cookies do not
typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.
13.5 We use [only
session cookies] OR [only persistent cookies] OR [both session and persistent
cookies] on our website.
13.6 The names of the
cookies that we use on our website, and the purposes for which they are used,
are set out below:
(a) we use [cookie
name] to [recognise a computer when a user visits our website] OR [track
users as they navigate the website] OR [enable the use of a shopping cart on
the website] OR [improve the website's usability] OR [administer the website] OR
[prevent fraud and improve the security of the website] OR [personalise the
website for each user] OR [target advertisements which may be of particular
interest to specific users] OR [validate authenticated users sessions] OR
[facilitate the use of our website search engine] OR [[specify purpose]].
13.7 Most browsers
allow you to refuse to accept cookies; for example:
(a) in Internet
Explorer (version 11) you can block cookies using the cookie handling override
settings available by clicking "Tools", "Internet Options",
"Privacy" and then "Advanced";
(b) in Firefox
(version 47) you can block all cookies by clicking "Tools",
"Options", "Privacy", selecting "Use custom settings
for history" from the drop-down menu, and unticking "Accept cookies
from sites"; and
(c) in Chrome
(version 52), you can block all cookies by accessing the "Customise and
control" menu, and clicking "Settings", "Show advanced
settings" and "Content settings", and then selecting "Block
sites from setting any data" under the "Cookies" heading.
13.8 Blocking all
cookies will have a negative impact upon the usability of many websites.
13.9 If you block
cookies, you will not be able to use all the features on our website.
13.10 You can delete
cookies already stored on your computer; for example:
(a) in Internet
Explorer (version 11), you must manually delete cookie files (you can find
instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox
(version 47), you can delete cookies by clicking "Tools",
"Options" and "Privacy", then selecting "Use custom
settings for history" from the drop-down menu, clicking "Show
Cookies", and then clicking "Remove All Cookies"; and
(c) in Chrome
(version 52), you can delete all cookies by accessing the "Customise and
control" menu, and clicking "Settings", "Show advanced
settings" and "Clear browsing data", and then selecting
"Cookies and other site and plug-in data" before clicking "Clear
browsing data".
13.11 Deleting cookies
will have a negative impact on the usability of many websites.