Effective Date: December 1st, 2017
To review material modifications and their effective dates scroll to the bottom of the page.1Introduction
1.1We hold the privacy of our visitors as a subject of the highest importance, and are committed to safeguarding that privacy at all times.
1.2This policy applies to our role as a Data Controller with regard to the personal data of visitors to this website. The role of a Data Controller is to determine the purposes and means of processing of that personal data.
1.3By continuing to use this website you agree to our use of cookies and other tracking technologies.
2How We Use Your Personal Data
2.1In this section we describe:
a) The general categories of data that we process or plan to process.
b) The category and source of any data not collected directly from you.
c) The purposes for which we may process your personal data.
d) The legal basis for the processing of personal data.
2.2We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3We may process your account data ("account data"). The account data may include your name, email address, postal address and telephone number. The account data is sourced from companies affiliated or partnered with us, should you purchase a product from them on our recommendation. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, targeting our promotional messages, and communicating with you. The legal basis for this processing is your consent: before linking you to any offer that we recommend we require your active consent to the processing of your account data.
2.4We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and any other data associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.5Please do not supply the personal data of any other person to us, unless we request you to do so.
3Providing your personal data to other organizations
3.1Your account data may be passed in hashed (unreadable) form to marketing organizations including, but not limited to, Google, Facebook, and Yahoo DSP Platforms, where it will be matched with other users to ensure that our promotional messages are delivered only to those people with whom they are most likely to resonate.
3.2In addition to the specific disclosures of personal data set out in this Section we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, or in an administrative or out-of-court procedure.
4International transfers of your personal data
4.1This section provides information about the circumstances in which your personal data may be transferred to countries outside the United States of America (USA) and outside of the European Economic Area (EEA).
4.2The marketing and tracking facilities for our website are situated in countries outside the USA and the EEA. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
4.3You acknowledge that personal data that you submit to us or our partners may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5Retaining and deleting personal data
5.1This section sets out our data retention policies and procedures, which are designed to ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3Notwithstanding the other provisions of this Section we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6Amendments
6.1We may update this policy from time to time by publishing a new version on this website.
6.2You are encouraged to check this page occasionally to ensure you are abreast of any changes to this policy.
7Your rights
7.1This section summarizes the rights that you have under data protection law. Some of the rights are complex, and not all of the details are included here. Accordingly, you are advised to read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2Your principal rights under data protection law are:
(a) the right to access
(b) the right to rectification
(c) the right to erasure
(d) the right to restrict processing
(e) the right to object to processing
(f) the right to data portability
(g) the right to complain to a supervisory authority
(h) the right to withdraw consent
7.3You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a fee.
7.4You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw previous given consent to processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data was unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
7.6In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
7.8You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9To the extent that the legal basis for our processing of your personal data is either:
(a) consent
or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.10If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the country of your habitual residence, your place of work or the place of the alleged infringement.
7.11To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8Cookies
8.1A cookie is a small file containing an identifier (a string of letters and numbers) that is sent by a web server to your browser and is stored by your browser. The identifier is then sent back to the web server each time your browser requests a page from the web server.
8.2Cookies 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.
8.3Cookies 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.
9Cookies that we use
9.1We reserve the right to use cookies for the following purposes:
(a) authentication - we may use cookies to identify you when you visit our website and as you navigate our website;
(b) status - we may use cookies to help us to determine if you are logged into our website;
(c) personalization - we may use cookies to store information about your preferences and to personalize the website for you;
(d) security - we may use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(e) advertising - we may use cookies to help us to display advertisements that will be relevant to you;
(f) analysis - we may use cookies to help us to analyze the use and performance of our website and services; and
(g) cookie consent - we may use cookies to store your preferences in relation to the use of cookies more generally.
10Cookies used by our service providers
10.1Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
10.2We use Google Analytics to analyze the use of our website, including promotional campaigns. Google Analytics gathers information about website use by means of cookies, web beacons, and other storage technologies. The information gathered from this website and elsewhere on the internet is used to create reports about the use of our website and to target our promotional messages. Google's privacy policy is available at: https://policies.google.com/privacy.
10.3We use Facebook to analyze the use of our website, including promotional campaigns. Facebook gathers information about website use by means of cookies, web beacons, and other storage technologies. The information gathered from this website and elsewhere on the internet is used to create reports about the use of our website and to target our promotional messages. Facebook's privacy policy is available at: https://www.facebook.com/privacy/explanation
10.4We use Yahoo DSP Platforms to analyze the use of our website, including promotional campaigns. Yahoo DSP Platforms gathers information about website use by means of cookies, web beacons, and other storage technologies. The information gathered from this website and elsewhere on the internet is used to create reports about the use of our website and to target our promotional messages. The Yahoo DSP Platforms privacy policy is available at: https://legal.yahoo.com/us/en/yahoo/privacy/index.html
11Managing cookies
11.1Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) Chrome: https://support.google.com/chrome/answer/95647?hl=en
(b) Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(c) Opera: https://help.opera.com/en/latest/web-preferences/#cookies
(d) Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(e) Safari: https://support.apple.com/en-us/HT201265
(f) Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
11.2Blocking all cookies will have a negative impact upon the usability of many websites.
11.3If you block cookies you will not be able to use all the features on our website.
11.4Further information about online behavioral advertising and online privacy, and how to exercise your rights to opt-out of the collection and use of information for ad targeting, can be found at these links:
http://www.youronlinechoices.eu/
http://optout.aboutads.info/
12Our details
12.1This website is owned by and operated under the supervision of Martin Levi.
12.2You can contact us by email at [email protected]
13Data protection officer
13.1Our data protection officer's contact details are same as those of the site owner.
14Material Modifications since December 1st, 2017
02/18/2019Amended section 3.1 to include reference to Oath DSP Platforms.
02/18/2019Added section 10.4: Use of Cookies provided by Oath DSP Platforms.
01/01/2022Amended section 3.1 to reference Yahoo DSP.
01/01/2022Amended section 10.4 to reference Yahoo DSP.