PRIVACY POLICY STATEMENT
Who we are
We are the Creators and Designers of Noggin Clontith, a fictional character with full Copyright and Performing Rights Society protection.
About this document
This Privacy Statement informs you of our privacy practices and of the choices you can make about the way we collect and use information about you, including information that may be collected from your online activity, use of devices, and information provided to [Company name] for purposes of recruitment or employment consideration and your rights under the local data protection law and the EU General Data Protection Regulation (GDPR).
For the purposes of this statement, personal data shall mean any information relating to you which identifies or may identify you and which includes, for example, your name, address, identification number.
This Privacy Statement does not apply to third-party applications, products, services, websites or social media features that may be accessed through links we provide on our services for your convenience and information. Accessing those links will cause you to leave from our services and may result in the collection or sharing of information about you by a third-party.
We do not control, endorse or make any representations about those third-party websites or their privacy practices, which may differ from ours. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your personal data.
Our privacy principles
We are committed to the following principles, which are based on internationally recognized frameworks and principles of privacy and data protection:
Lawfulness, fairness & transparency.
We process personal data in accordance with EU and UK law and with transparency and fairness to you. Our data processing activities are conducted:
- With your consent.
- In order to fulfill our obligations to you.
- For the legitimate purposes of operating our business, advancing innovation and providing a positive customer experience.
- Otherwise in accordance with EU and UK law.
Notice and choice of data use.
We are transparent and provide clear notice and choice to you about the types of personal data collected and the purposes for which it is collected and processed. We will not use personal data for purposes other than stated in this policy.
Data access.
We provide you with reasonable access along with the ability to review, correct, amend or delete the personal data you have shared with us.
Data integrity & purpose limitation.
We only use personal data for the purposes described at the time of collection or for additional compatible purposes in accordance with law. We take reasonable steps to ensure that personal data is accurate, complete and current.
Data security.
To protect personal data against unauthorized use or disclosure we implement information security controls and data security protection.
Accountability for onward transfer.
We acknowledge our potential liability for transfers of personal data (i.e. e-shop) among our entities or to third parties. Personal data will only be shared when third parties provide equivalent levels of protection.
Recourse, oversight and enforcement.
We are committed to resolving any concerns regarding your personal data.
How we use data
We collect and use personal data to manage your relationship with our company and better serve you by personalizing your experience and interaction with us. Examples of how we may use your data include:
Customer experience.
Providing you with a positive customer experience by maintaining accurate contact and registration data, delivering comprehensive customer support, offering products, services and features that may interest you.
We also use your data to deliver a tailored experience, personalize our services and communications you receive and create recommendations based your use of our services.
Transaction support.
Assisting you in completing transactions and orders of our products or services, administering your account, processing payments, arranging shipments and deliveries and facilitating repairs and returns.
Product support and improvement.
Improving the performance and operation of our products, solutions, services and support, including support and timely software updates and alerts to ensure the continued operation of our service.
Administrative communications.
Communicating with you about our services. Examples of administrative communications may include responses to your inquiries or requests, service completion or product-related communications, safety recall notifications, or applicable corporate updates related to mergers, acquisitions or divestitures.
Security.
Maintaining the integrity and security of our website, products, features and services and preventing and detecting security threats, fraud or other criminal or malicious activity that might compromise your information.
When you interact with us, we will also take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data.
Business operations.
Conducting ordinary business operations, including recruiting, verifying your identity, conducting business research and analytics, corporate reporting and management, staff training and quality assurance purposes (which may include monitoring or recording calls to our customer support) and outreach.
Research and innovation.
Innovating new products, features and services using research and development tools and incorporating data analysis activities.
Advertising.
Providing personalized promotional offers (in accordance with your Privacy Preferences) on our services and other selected partner websites (for example, you might see an advertisement for a product on a partner site that you have recently viewed on an our website). This may involve the use of Automatic Data Collection Tools.
We might also share some of your information with marketing service providers and digital marketing networks to present advertisements that might interest you.
Compliance with law.
We are in compliance with applicable laws and regulations, to operate our services and offer products properly and to protect ourselves, our users and our customers and to solve any customer disputes.
What data we collect
Personal data is any information that personally identifies you or from which you could be identified either directly or indirectly. We may collect your personal data through your use of our Company’s services or during conversations or correspondence with our employees or representatives.
The personal data we collect from you depends on the nature of your interaction with us or on the services you use in our website, but may include the following:
Information you provide directly:
Contact data. We may collect personal and/or business contact data including your first name, last name, mailing address, telephone number, fax number, email address and other similar contact information.
Payment data. We collect data necessary for processing payments and fraud prevention, security code numbers and other related billing information.
Account data. We collect information such as how you purchased or signed up in our website, your transaction, billing and support history and anything else relating to the account you create.
Location data. We may collect geo-location data when you enable location-based services or when you choose to provide location-related information during product registration.
Security credentials data. We collect user IDs, passwords, password hints, and similar security information required for authentication and access to website accounts.
Demographic data
We may collect, or obtain from third parties, certain demographic data including country, gender, age, preferred language, general educational and employment background, and general job interest data.
Preferences
We collect information about your preferences and interests as they relate to our products, services (both when you tell us what they are or when we deduce them from what we know about you) and how you prefer to receive communications from us.
Social media data
We may provide social media features that enable you to share information with your social networks and to interact with us on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites you use to make sure you understand the information that may be collected, used, and shared by those sites.
Other unique identifying information
Examples of other unique information that we may collect from you include product serial numbers, information you provide when you interact in person, online or by phone or mail with customer support channels or additional information you have provided to us to facilitate delivery of our services and to respond to your inquiries.
You are not required to provide the personal data that we may request, however, if you choose not to provide information requested, in some cases we may not be able to provide you some of our website services, certain specialized features or be able to effectively respond to any queries you may have.
Information automatically collected about your use of our services:
Device data
We collect information about your computer, device such as operating system, amount of memory, region, language, time zone, browser version, computer manufacturer, connection port, unique device identifiers, advertising identifiers and additional technical information that varies by product.
Application data
We collect information related to our applications such as location, language, software versions, data sharing choices and update details.
Website browsing data
We collect information about your visits to and your activity on our website or applications including the content (and any ads) that you view and interact with, the address of the website from which you arrived and other clickstream behaviour (such as the pages you view, the links you click or which items you’ve added to your shopping basket).
Anonymous or aggregated data
We may collect anonymous answers to surveys or anonymous and aggregated information about how our services are used.
How we keep your data secure
To prevent unauthorized access or disclosure and to ensure the appropriate use of your information, we utilize reasonable and appropriate physical, technical, and administrative procedures to safeguard the information we collect and process. We retain data as required or permitted by law and while the data continues to have a legitimate business purpose.
When collecting, transferring or storing sensitive information such as financial information we use a variety of additional security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. When we transmit highly-confidential information (such as password) over the internet, we protect it through the use of encryption, such as later versions of the Transport Layer Security (“TLS”) protocol.
How we share data
We will only share your personal data as follows:
Sharing with our company.
By accessing our website, registering a product or for service, creating an account, or otherwise providing us with your personal data, you consent to the transfer of your personal data throughout the global network of entities on the basis of the General Data Protection Regulation program.
Sharing with service providers.
We retain service providers to manage or support certain aspects of our business operations on our behalf. These service providers may provide services such as credit card processing and fraud management services, customer support, order fulfilment, product delivery, content personalization, advertising and marketing activities (including digital and personalized advertising), IT services, email service providers, data hosting, live-help, debt collection and management or support of our website.
Our service providers are required by contract to safeguard any personal data they receive from us and are prohibited from using the personal data for any purpose other than to perform the services as instructed by our company. We also take steps to provide adequate protection for any transfers of your personal data in accordance with applicable law.
Corporate transactions.
Circumstances may arise where, whether for strategic or other business reasons, we decide to sell, buy, merge or otherwise reorganize businesses. In such transactions, we may disclose or transfer your personal data to prospective or actual purchasers or receive personal data from sellers. Our practice is to seek appropriate protection for your personal data in these types of transactions.
Compliance with law.
We may also share your personal data when we believe, in good faith that we have an obligation to:
- Respond to duly authorized information requests of law enforcement agencies, regulators, courts and other public authorities, including to meet national security or other law enforcement requirements.
- Comply with any law, regulation, subpoena, or court order.
- Investigate and help prevent security threats, fraud or other criminal or malicious activity.
- Enforce/protect the rights and properties of our company or its subsidiaries.
- Protect the rights or personal safety of our company, our employees, and third parties on or using our property when allowed and in line with the requirements of applicable law.
Sharing with other third parties.
We may also share your personal data with:
- Credit reference and fraud prevention agencies.
- Debt collection agencies (for outstanding debts with us).
- Insurance providers if you have purchased an insurance policy through us.
- Other third parties, such as our channel partners, with the appropriate notice and consent. If you choose to provide personal data to the other companies, that personal data will be handled according to the privacy policy of those companies, which may differ from our policies and practices.
For how long we keep your personal information
We will keep your personal data for as long as we have business relationship with you. Once our business relationship with you has ended, we may keep your data for up to ten (10) years in accordance with the directive of the Cyprus Data Protection Commissioner.
We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.
Choosing your privacy preferences
You have the option of subscribing to communications from us related to specific services. You can also choose to receive general communications and you can select how those communications are delivered – e.g., via postal mail, email, telephone, fax, mobile device or online.
You can make or change your choices about receiving either subscription or general communications at the data collection point or by using other methods, which are described in the following sections. These options do not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings, or other administrative and transactional notices where the primary purpose of these communications is not promotional in nature.
Subscription communications.
Subscription communications include email newsletters, etc. that may be expressly requested by you or which you consented to receive. After you request such communications, you may opt out of receiving them by using one of the following methods:
- Select the email’s “Unsubscribe” link, or follow the instructions included in each email subscription communication.
- Return to the website(s) where you originally registered your preferences and follow the instructions to opt out.
- Contact us. Be sure to provide your name, contact information, and specific relevant information about the subscriptions or marketing that you no longer wish to receive.
General communications.
Our general communications provide information about products, services, and/or support. This may include new product or services information, special offers, personalized content, targeted advertising or invitations to participate in market research or compliance reviews.
Our use of cookies
Cookies are text files containing small amounts of information which are downloaded to your device, or more technically, to the browser that you use on that device, when you visit a site. The entity that places cookies on your browser can then read the information on that cookie that it set. Cookies are typically classified as either “session cookies” which do not stay on your device after you close your browser or “persistent cookies” which will usually remain on your device until you delete them or they expire.
Different cookies are used to perform different functions which we explain below:
We use cookies that are essential.
Some cookies are essential in order to enable you to move around our websites and use their features, such as accessing secure areas of the website. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
We use cookies to remember your selections.
These cookies allow us to remember choices you make on our websites (such as your preferred language or the region you are in) and provide enhanced, more personalized features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
We use cookies to personalize your experience.
We also use cookies to change the way our websites behave or look in order to personalize your experience from information we infer from your behaviour on our websites or information we may already know about you because, for example, you are a registered customer.
These cookies may be used to tailor the services you receive from us or the content, look and feel delivered to you on subsequent sessions to our websites. For example, if you personalize webpages, or register for products or services, a cookie helps our webpage server recall your specific information. When you next visit our websites, the information you previously provided can be retrieved, so you can easily use the website features that you previously chose. If you use more than one device or computer on a regular basis, we may link cookies together so you will still receive a personalized online experience.
We can also personalize the information you see based on what we already know about you, so that you spend less time looking for things. With the use of cookies, each visitor to our site can have a web experience which is unique to them.
We use cookies for performance and analytics purposes.
We use our own cookies and/or third-party cookies and other identifiers to see how you use our websites and services in order to enhance their performance and develop them according to the preferences of our customers and visitors.
For example, cookies and web beacons may be used to: test different designs and to ensure that we maintain a consistent look and feel across our websites; track and provide trend analysis on how our users interact with our websites and communications; track errors and measure the effectiveness of our promotional campaigns. We use Google Analytics, run by Google Inc., for example, to track website usage and activity.
The data collected will generally be aggregated to provide trends and usage patterns for business analysis, site/platform improvement and performance metrics. Our cookies or the resulting analysis may be also shared with our business partners. The type of information we collect includes how many visitors visit our websites, how many customers log in, when they visited, for how long and which areas of our websites and services but is generally not used to identify you individually. We may also receive similar information about visitors to our partner websites.
We use cookies for targeted advertising purposes.
We also allow data providers to use cookies to help us deliver our own content and advertising, and measure the effectiveness of our advertising campaigns. These cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us (e.g. your email address) that we may share with data providers solely in hashed, non-human readable form.
If you are a registered user, the information collected from our websites is not anonymous and we may use this information along with other information we know or infer about you including your preferences to tailor content, services, advertising and offers for you.
Third party advertising cookies and social media cookies
We do not allow advertisers and other third parties to place cookies on our websites.
Sharing other information with advertisers
We do not share any information with any other advertisers.
Cookies.
If you don’t want to allow cookies at all, or only want to allow use of certain cookies, please refer to your browser settings. You can also use your browser settings to withdraw your consent to our use of cookies at any time and delete cookies that have already been set.
Your browser help menu or the website “allaboutcookies.org” contains comprehensive information about the process of opting out on different browsers.
Note that by disabling certain categories of cookies, you may be prevented from accessing some features of our site or certain content or functionality may not be available.
Some newer web browsers incorporate “Do Not Track” features. Currently, no industry standard exists for handling “Do Not Track” requests, therefore at this time, our websites may not respond to “Do Not Track” requests or headers from these browsers.
Exercising your rights
You have the right to access any personal data that you have provided to us or that we maintain about you. In addition, you have the right to withdraw any consent previously granted or to request correction, amendment, restriction, anonymization or deletion of your personal data and to request an explanation about the processing.
In certain cases, your request may be denied on the basis of a legitimate exception such as where making information available would reveal personal data about another person or where we are legally prevented from disclosing such information.
Contacting us
We value your feedback. If you have any questions or concerns about our Privacy Statement, our collection and use of your data or a possible breach of local privacy laws, you can contact us via email or write to us at the appropriate address. You can find our Contact Details in Contact Us Section in our website.
All communications will be treated confidentially. Upon receipt of your communication, our representative will contact you within a reasonable time to respond to your questions or concerns. We aim to ensure that your concerns are resolved in a timely and appropriate manner.
If we are unable to resolve your concerns, you have the right to contact your local data privacy supervisory authority or seek a remedy through the courts if you believe your rights have been breached.
Changes to our privacy statement
If we make significant changes to our Privacy Statement that materially alter our privacy practices, we may notify you via email.
What actions you should take?
If you haven’t taken any actions in order to comply with GDPR, and your website collects data from EU/UK citizens, we recommend that you review your privacy policy statement and security practices in order to fulfil your responsibilities.
We offer hosting services of various types in our infrastructure but the data stored and their security is responsibility of the site owners. We do not access your data in any way.
Every business, according to their activities needs to comply with this new regulations. For this reason is highly recommended to work with a legal advisor in order to identify how this may affect you and your business.
– This Privacy Statement was last updated on August 2018