The Policy describes the types of information we obtain about visitors of our Website (“You”, “Your”) and how we use said information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.
For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”), we will be the data controller responsible for any personal data we process.
1. Types of information we obtain
1.1. Non-personal Information:
1.2. Personal Information:
1.2 (a) We may obtain your personal data from the following sources:
i) from you directly (through the website or online forms); and/or
ii) from third parties, service providers that are assisting us in providing you with a service, or from your social networks accounts you used to sign in to our online services
1.2 (c) We may collect the following categories of personal data relating to our existing or prospective individual visitors:
а) Contact information;
b) Your IP address and unique mobile device identification numbers (such as your device ID, advertising ID, MAC address);
c) Data about your device, such as manufacturer, operating system, browser type and language;
d) Broad location data;
e) Precise geolocation data ;
f) Data we collect with cookies and similar technologies
g) Data we receive if you link a third party tool with the Service (such as Facebook, Google or Vkontakte);
h) Data for advertising and analytics purposes, so we can provide you a better Service;
i) Your messages to the Services (such as any feedback you submitted about your exp) browser type;
j) information on the use of our website (for example, pages visited, geographical location, time spent on the website, online transactions);
k) preferences regarding online marketing; and/or
l) Other data you choose to give us.
1.3. Additional Information:
1.3 (a) From time to time we reserve the right to obtain information about legal entities that visit our Website, through their representatives.
1.3 (b) We may obtain information about the website of a legal entity, the name of the legal entity, the contact information of the legal entity, including business e-mails, the country of incorporation, and the link to the ICO of the legal entity (if applicable).
1.4. We may use our web browser extension to obtain information described in this Policy. Our web browser extension can only access specific information that you have explicitly granted permission to access. We cannot and do not track your browsing history.
2. How we collect information?
2.1. We may collect personal identification information such as your email and name from you only if you voluntarily submit such information to us. You can always refuse to supply personal identification information. We may collect non-personal identification information about you whenever you interact with our Website.
3. How we use the information we obtain?
3.1. We use non-personal information for the following purposes:
(a) to prevent you from seeing unnecessary advertisements or requiring you to re-enter the Website more than is necessary;
(b) to calculate the aggregate number of people visiting our Website and which parts of the Website are most popular;
(c) to improve the content of our web pages and to customize the content and layout of our pages;
(d) to deliver the information you request from the Website, such as an article, news, review, analysis etc;
3.2. Areas in which we may use your personal information include, but are not limited to, providing you with email newsletters, feedback and especially the ability to comment on articles, interactive forms. If you provide us with your email address, you may receive periodic promotional emails from us and carefully selected partners with information regarding special offers or services in case you provide a concent for such actions from our side. You may also receive informational emails from us related to administrative notices regarding the operation of the Website. You may at any time withdraw your consent to receive electronic advertising emails by sending a withdrawal notice to Neverge or by pressing the dedicated button (“an unsubscribe button”) in any email from Neverge.
3.3. We may share your information with the following types of third parties:
a) technical support providers who assist with our website and infrastructure,
b) third party software providers, where the provider hosts the relevant personal data on our behalf;
c)professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers;
d) providers that help us generate and collate reviews in relation to our goods and services;
e) our advertising and promotional agencies carrying out our marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or
f) service providers that assist us in providing our services.
3.4. We may share your information with Law enforcement or government bodies.
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our agreements, or as required by law.
4.1. Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent to your browser from the Website and stored on your computer’s hard drive.
4.3. You can control and/or delete cookies if you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being stored therein. If you do this, however, some services and functionalities of our Website may not work.
5. Data retention
5.1. We will retain your information for as long as is needed to provide you services, or as required to fulfill our legal obligations. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
5.2. By contacting us at [email protected] you can at any time obtain confirmation of whether or not personal data concerning you is being processed.
5.3. You have the right to access and export your information at any time by sending a request to [email protected]
6. Privacy complaints
6.1. To the extent that our processing of your information is subject to the EU General Data Protection Regulation, we rely on our legitimate interests, described above, to process your data. You have a right to object to our use of your information for our own marketing purpose at any time by clicking on the special button and opting out from receiving all email. You may also object to processing by emailing [email protected]
7. How we protect personal Information
7.1. We maintain administrative, technical and physical safeguards designed to protect the personal information we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
7.2.We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data breach and will notify you and the competent regulator of a breach where we are legally required to do so.
8. How Long Do We Keep Your Personal Data?
8.1. We will keep your personal data only for as long as is necessary for the purposes for which it was collected in connection with your requests via our website or your use of our website.
9. Third-party links
9.1. Occasionally, at our discretion, we may include or offer third-party products or services on the Website. These third-party providers have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked services. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback about these services.
10.1. To determine how many persons visit our Website and to better understand the areas of greatest interest to our visitors, we reserve the right to have relationships with web analytics companies that compile this information for us. For further information, consult the privacy policies of the web analytics company we use: Google Inc. http://www.google.com/intl/en/privacy.html
12.1. We do not intend to solicit or collect Personal Information from anyone under the age of 16 or under the legal age of your country, if it is higher. If you are under 16 or are not of a legal age of your country, you shall not provide Personal Information on this Site.
13. Your Rights
13.1. You are entitled to obtain information from us on how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected or deleted from our systems. You can also limit, restrict or object to the processing of your data. We do not carry out any decision-making based solely on automated processing, including profiling.
If you gave us your consent to use your data, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdrew your consent.
You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so.
13.2. If you want to request that we no longer use and process your information to provide you services as well as withdraw your personal data please write us at [email protected] We will respond to your request within 30 (thirty) days.
14. Law And Harm
14.1. Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our visitors’ rights or property.
14.2. Neverge may share your personal information with law enforcement, data protection authorities, government officials, and other authorities when Neverge is legally bound to do so or to protect the safety of visitors and Neverge.
15. Contacting Us
16. Transfers Of Personal Data Outside The Eu/European Economic Area
We share your personal data with our affiliates in the EU and outside the EU. International transfers with Neverge affiliates outside the EEA, are governed by EU Commission-approved Standard Contractual Clauses for Controllers and, where relevant, for Processors.
We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organisations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
We may also disclose personal data to our advisers, consultants, law enforcement and other public authorities (such as tax and social security bodies), the police, prosecutors, courts and tribunals. All these recipients are themselves responsible to comply with the EU data protection rules.
17. Rights of use
In accessing and using the Website you agree that you may only download the content, including text, pictures, graphics, video, audio material, software or any other form, of the Website or any portion of it (“Content”), for your own personal non-commercial use.
Except as set out above, you are not permitted to copy, reproduce, duplicate, broadcast, download, store (in any medium), transmit, resell, show or play in public, adapt or modify in any way the Content for any other purpose whatsoever without the prior written permission of Neverge.
All intellectual property rights, including copyright in the Content accessible (or available for download) belong to Neverge. All rights are hereby reserved.