Privacy Policy
Updated: 4th June 2023
1. Data we collect about you
Personal data, or personal information, refers to any information about an individual from which that person can be identified. This Privacy Policy outlines the types of personal data we collect, use, and disclose as a data controller. It applies to the information provided by you or collected by us through our Website ( or when using our Services.
By using our Website, Services, or any related products, you signify your acceptance of this Privacy Policy. Please review this Privacy Policy before using the Website or Services and before submitting any information to us. If you do not agree with the terms, do not access or use our Services, Website, or any other aspect of our business.
The following categories of personal data may be collected, used, stored, and transferred by us:
2. Methods of data collection
We employ various methods to collect data from and about you, including:
If we are required by law or under an agreement with you to collect personal data and you fail to provide such data when requested, we may not be able to fulfill our obligations under the agreement, including providing you with the Services. In such cases, we may have to cancel the Services, but we will notify you if this is necessary.
3. Use of your personal data
We will only use your personal data when permitted by law. The most common circumstances in which we use your personal data include:
When relying on legitimate interests as the legal basis for processing your personal data, we ensure that we take into account your rights and any potential impact on you. We do not rely on consent as the primary legal basis for processing your personal data, except for sending third-party direct marketing communications via email or text message. You have the right to withdraw your consent for marketing communications at any time by contacting us.
In the table below, we provide a description of how we plan to use your personal data and the legal bases on which we rely. We also indicate our legitimate interests where applicable. Please note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we use your data.
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Purpose or Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as our client and decide whether and on what terms to provide the Services Identity, Contact and Financial Performance of an agreement with you
To process and deliver the Services including, to (a) provide customer support and communicate with you, (b) manage payments and fees and verify transactions, (c) collect and recover fees owed to us, and (d) resolve disputes and enforce agreements entered between us Identity, Contact, Financial, Transaction, Marketing and Communications Performance of an agreement with you;
Necessary for our legitimate interests To prevent and investigate prohibited or illegal activities or fraud, including, prevent money laundering and terrorist financing Identity, Contact, Financial, Transaction
Performance of an agreement with you; Necessary for our legitimate interests To manage our relationship with you, including: (a) notifying you about changes to our Services, Website, general terms or this Privacy Policy and (b) asking you to leave a review or take a survey
Identity, Contact, Profile, Marketing and Communications Performance of an agreement with you; Necessary to comply with a legal obligation;
Necessary for our legitimate interests (to keep our records updated and to study how you use our Services) To enable you to partake in a competition or complete a survey Identity, Contact, Profile, Usage, Marketing and Communications
Performance of an agreement with you; Necessary for our legitimate interests (to study how you use our Services, to develop them and grow our business) To administer, customize, update, maintain, protect and improve the Website and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity, Contact, Technical and Usage Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation); Necessary to comply with a legal obligation
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Identity, Contact, Profile, Technical, Usage, Marketing and Communications Necessary for our legitimate interests (to study how you use our Services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, Services, marketing, customer relationships and experiences Technical and Usage Necessary for our legitimate interests (to define types of clients for our Services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about Services that may be of interest to you Identity, Contact, Technical and Usage, Profile Necessary for our legitimate interests (to develop our Services and grow our business)
We may use your identity, contact, profile, technical and usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us or purchased Services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contact us at any time.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
4. Cookies and similar technologies
Like most Internet sites, our Website may use cookies and similar technologies to enhance your user experience and provide customization and useful features to our Website and Services. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
5. Disclosure of your personal data
Except as outlined in this Privacy Policy, your personal data will never be sold or disclosed with other companies or organizations for commercial purposes or otherwise.
We reserve the right at all times to disclose any personal data that we have collected when: (a) permitted or required by law; or, (b) trying to protect against, prevent, investigate actual or potential fraud, security issues, technical issues, unauthorized transactions or other violations; or (c) trying to enforce the applicable terms of service or other agreements; or (d) protecting against violations to the rights, property or safety of us, our users or the public as required or permitted by applicable laws; or (e) you have given your consent to do so. Finally, we may transfer personal data to a successor entity in connection with a corporate merger, consolidation, partial or total sale of assets, bankruptcy, or other corporate change.
We may disclose your personal data to our contractors (who may be located outside of the European Economic Area (“EEA”) to process it for us, for the purposes of processing transactions, collecting fees, identifying you, but also for improving your user experience, performing business support functions or other related tasks, based on our instructions and in compliance with the Privacy Policy and any other applicable confidentiality and security requirements. In addition, transfers to our contractors are covered by the service agreements with such contractors.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
6. Data security
We adhere to the generally accepted industry standards to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Only our authorized employees, agents and contractors (who have agreed to keep personal data secure and confidential) have access to the personal data on a need to know basis.
We store and process data, including personal data, in the EEA and possibly in other countries through third parties that we use to operate and manage the Services. When you access or use our Websites or the Services, or otherwise provide personal data to us, you are consenting, on behalf of you and your authorized agents, (and representing that you have the authority to provide such consent) to the processing and transfer of personal data in and to the other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.
Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
You agree and acknowledge that the Internet may be subject to breaches of security and that the submission of data over the Internet may not be secure. We strive to use acceptable means to protect any personal data you share with us, however we cannot guarantee its absolute security.
Depending on the nature of the risks presented by the proposed processing of your personal data, we will have in place the following appropriate security measures:
We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a breach where we are legally required to do so.
If you want to know more about our security practice, please visit this link.
7. Data retention
We will retain your personal data only for so long as it is required for the purposes for which it was collected. This period may extend beyond the end of your relationship with us, but only for so long as is reasonably necessary for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations (e.g. taxation purposes), resolve disputes and enforce our agreements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
When your personal data is no longer required, we will destroy, delete or convert it into an anonymous form.
8. Third-party links
The privacy practices set forth in this Privacy Policy apply to the Website and Services only. If you link to other web sites (including sites that offer or use the Services or are promoted by us) or use the services of other service providers, please review the privacy policies posted at those web sites or by the relevant service providers.
9. Age limitations
We do not allow use of our Services and the Website by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
10. Your rights
Under certain circumstances, you have following rights under data protection laws in relation to your personal data:
  1. right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
  2. right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
  3. right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
  4. right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
  5. right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
  6. right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform an agreement with you; and
  7. right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Changes to this Privacy Policy
We may change this Privacy Policy unilaterally and without prior notice, but any changes will be posted on the Website. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should stop using our Services, the Website or any other aspect of our business. Your continued use of the Website or our Services constitutes your agreement to all such changes.
This version was last updated on 04.06.2023 and historic versions can be obtained by contacting us.
12. Contact and complains
For further information regarding the Privacy Policy and related practices or in case of any suspected infringement of your privacy, please contact us at
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