Privacy Policy

Privacy Policy

Version: 2.0

Last update: 09.09.2020

  1. GENERAL

Your privacy and personal data are important to us and this Privacy Policy sets out what data we collect, how we use it and how to manage your privacy settings. Please also read our General Terms and Conditions which set out the terms governing the services we provide. In case you fail to provide us personal data when requested, we may not be able to deliver the services you have requested or perform their certain aspects.

When first-person pronouns are used in this Privacy Policy (us, we, our, ours, etc.) these provisions are referring to the Company. The capitalized term “Website” refers to this website - https://7partnersagency.com. When second-person pronouns are used in this Privacy Policy (you, your, etc.) these provisions are referring to the person using this Website.

  1. PERSONAL DATA CATEGORIES WE COLLECT
  1. 2.1.The Company directly collects, and processes below listed personal data categories. Please note, that list below is not exhaustive and upon necessity the Company may request, collect and process other required information, including information regarding personal data, according to Privacy Policy and relevant legal enactments.
  2. 2.2.Natural person’s identification data – including, but not limited to name, surname, tax identification number, date of birth, information from person’s identification document (e.g. passport);
  3. 2.3.Contact information – address, telephone number, e-mail address and other if relevant;
  4. 2.4.Financial information – account number, incoming/outgoing payments, transactions in financial instruments and other similar information;
  5. 2.5.Professional and information regarding your education and family – information regarding level of education, education institution, marital status, place of work and related information, membership and other;
  6. 2.6.Information relating to the use of services and their relation to your preferences, habits etc. – such as information on services used, personal settings, surveys, contests and campaigns in which you have participated and other.
  7. 2.7.The Company also collects from you the data that clearly identifies you and logs all your activity on our site against your personal account, email or live chat, unique identifiers. The data we collect includes:
  1. 2.7.1.unique identification numbers (Internet protocol (IP) address and device ID);
  2. 2.7.2.as applicable to your type of device, browser type and version, and browser plug-in types and versions, application release and version, device model, manufacturer (brand), operating system, operating system version, OS library version, time of last seen, Wi-Fi status, radio frequencies (EDGE, HSDPA, LTE, WCDMA, none), device screen (width, high, dpi), NFC, telecom operator, Bluetooth enable, Bluetooth version;
  3. 2.7.3.time zone setting, city, region, country and language;
  4. 2.7.4.operating system and platform; and
  1. 2.8.information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
  2. 2.9.All personal data provided by you will be used to create and manage your account, as well as for security and marketing.
  1. GROUNDS AND PURPOSES FOR THE PROCESSING OF PERSONAL DATA
  1. 3.1.We process personal data if one of the following applies:
  1. 3.1.1.processing of personal data is necessary to enter into and perform a contract;
  2. 3.1.2.to comply with our legal obligations;
  3. 3.1.3.to ensure our legitimate interests or legitimate interests of third party;
  4. 3.1.4.if we receive your consent.
  1. 3.2.We primarily process personal data for following purposes:
  1. 3.2.1.to provide services;
  2. 3.2.2.to send administrative information, including updates to policies and changes to agreement terms;
  3. 3.2.3.to send marketing information about services, products, educational materials, upcoming events and other related information that may be useful to you in relation to received services and for educational purposes, unless you have not explicitly objected receiving such information;
  4. 3.2.4.to assess and mitigate risks related to anti-money laundering and terrorism financing as well as transaction related risks;
  5. 3.2.5.to comply with legal obligations and/or government authority’s requests;
  6. 3.2.6.in relation to legal claims related to our legitimate interests;
  7. 3.2.7.to provide additional or supportive services.
  1. RETENTION PERIOD
  1. 4.1.Retention period of personal data depends on the purposes specified by the Company. In determining retention period, we take into account agreements with you and contractual obligations, our legitimate interest and relevant legal enactments (such as legal enactments concerning anti-money laundering and terrorism financing and others).
  1. PERSONAL DATA TRANSFERS OUTSIDE EU/ EEA
  1. 5.1.Your personal data is primarily stored and processed within the European Union (EU)/European Economic Area (EEA) or Swiss Confederation, however where it is necessary personal data may be transferred outside the EU/EEA:
  1. 5.1.1.in order to store it;
  2. 5.1.2.in order to fulfil Company’s contractual obligations to you with regards to concluded agreement;
  3. 5.1.3.in order to fulfil legal obligations;
  4. 5.1.4.in order to facilitate Company’s business where it is in our legitimate interests and they are not overridden by Clients rights.
  1. 5.2.All such transfers have appropriate legal grounds and implemented contractual protections with regards to third parties.
  1. YOUR RIGHTS
  1. 6.1.Pursuant to GDPR and national legislation, you have the following rights with respect to your personal data:
  1. 6.1.1.You have the right to access and receive upon your written request personal data that is processed by the Company. If such request is excessive as well as repetitive, the Company may refuse to provide you with a copy of your personal data or request a reasonable fee taking into account     the administrative costs of preparing such copy.
  2. 6.1.2.You have the right to request to correct any information you believe is incomplete or inaccurate.
  3. 6.1.3.You have the right to request that the Company restrict the processing of your personal data. Any such request shall be assessed by the Company whether such request does not contradict or could not contradict to other legal grounds of processing to which the Company is obliged.
  4. 6.1.4.You have the right to object to the Company processing of your personal data. You can in particular object to automated decision-making in case we decide to apply one.
  5. 6.1.5.You have the right to withdraw consent to process your personal data at any time by contacting us directly.
  6. 6.1.6.You have the right to request for personal data to be erased. However, such right does not apply if personal data requested to be erased is being processed on legal grounds, for example based on legal obligations to comply with relevant legal enactments.
  7. 6.1.7.You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you. You have the right to receive your personal data in structured, commonly used and machine-readable format, as well as to transmit it to another controller. We are not obliged to protect your personal data that you choose to store or transfer outside our systems.
  1. 6.2.All aforementioned rights shall be exercised in good faith and on written request.
  2. 6.3.The reasonable time period for handling your request or complaint is 1 month. Taking into account complexity and number of requests, we can extend this time for 2 additional months.
  3. 6.4.In case your request is manifestly unfounded or excessive, in particular because of their repetitive character, we may either:
  1. 6.4.1.charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
  2. 6.4.2.refuse to act on your request.
  1. DELETION OF INFORMATION
  1. 7.1.We allow deletion of your personal data only at the processing services where it is available, and if the functionality of services include the option to delete your personal data, and you wish to delete only certain personal data and the deleted data may not be recovered by you (for example, by clicking on the option to “restore” – then we will delete such personal data from its systems as reasonably as practicable, unless EU or EU Member State Law requires storage. In this case such right does not apply if personal data requested to be erased is being processed on legal grounds, for example based on legal obligations to comply with relevant legal enactments).
  2. 7.2.If processing system lacks the deletion functionality and you have a reasonable request to facilitate such deletion, at the extent as this is possible considering the nature and functionality of such services and unless EU or EU Member State law requires storage, we may charge a fee (based on our reasonable costs) for any data deletion in this case, we will inform the you of any applicable fee, and the basis of its calculation in advance of any such data deletion.
  1. THIRD PARTIES AND SHARING YOUR DATA
  1. 8.1.Our site could contain links to third parties’ resources. These third parties’ resources do not belong to the Company unless specifically indicated and we are not responsible for the privacy policies or practices of such resources. You should ensure that you have read and agreed to the privacy policies of all resources you visit.
  2. 8.2.We do not sell or make available your personal data to third parties that are unrelated to servicing you. All parties that receive personal data from us, receive it solely to fulfil their contractual obligations to us and/or ensure the operation of our system or provision of services.
  3. 8.3.The Company reserves the right and for specific purposes to transfer your personal data to selected third parties, including:
  1. 8.3.1.to our affiliated third parties, including all their subsidiaries, affiliates, branches and representative offices irrespective of their geographical location;
  2. 8.3.2.to selected and designated third parties that perform services on our behalf under written agreement, which ensures proper safeguards and limitations with regards to personal data processing. This may include companies providing IT services, identity verification and due diligence services, data analysis, marketing support services providers, cloud service providers and others;
  3. 8.3.3.to government, regulatory or other law enforcement agencies/authorities.
  1. COOKIES AND SIMILAR TECHNOLOGIES
  1. 9.1.When you use the Services, a cookie will be stored on your computer. Generally, cookies and similar technologies work by assigning to your browser or device a unique number that has no meaning outside of our site. Not accepting cookies may make certain features of the services unavailable to you. We could use the following types of cookies in a range of ways to improve your experience on our Website:
  2. 9.2.Strictly necessary cookies
  1. 9.2.1.Without these cookies the online services you have asked for, like shopping baskets or producing your bill at checkout, cannot be provided.
  2. 9.2.2.Consent is not required for strictly necessary cookies as they are required for us to provide the services requested by you.
  1. 9.3.Performance cookies
  1. 9.3.1.The information collected using our performance cookies is used only by us or for our benefit.
  2. 9.3.2.Our performance cookies collect information about which pages on this Website you visit most often, if you open or read the communications we send, which advertisements you view or interact with on this Website or other websites on which our advertisements appear, and if you receive any error messages.
  3. 9.3.3.Our performance cookies do not collect information that identifies you personally; however, if you have an account with us, the information collected by us using our performance cookies may be associated with your account.
  1. 9.4.Functionality cookies
  1. 9.4.1.These cookies are used to remember your choices (such as language preference, country location, or other online settings) and to provide online services to you, or to prevent online services from being offered to you if you previously indicated you did not want to receive such services.
  2. 9.4.2.If you delete these functionality cookies, any preferences or settings you selected will not be retained for later visits. We do not share information collected using our functionality cookies with our advertisers or other third parties.
  3. 9.4.3.Our functionality cookies collect anonymous information; however, if you have an account with us, the information collected by us using our functionality cookies may be associated with your account.
  1. 9.5.Targeting or advertising cookies
  2. 9.6.Third-Party Targeted Advertising
  1. 9.6.1.Third-party targeted advertising cookies may be placed on your device by third-party advertisers, ad networks, data exchanges, marketing analytics and other service providers in order to provide you with relevant advertisements on our Website and online services and the websites and online services of third parties.
  2. 9.6.2.The information collected using these cookies does not identify you personally.
  1. 9.7.Our Targeted Advertising
  1. 9.7.1.We use these cookies in connection with our content and advertisements that appear on our or third-party websites and online services to recognise that you have viewed or interacted with our content or advertisements and so we can show you advertisements for products that we believe will be of interest to you.
  2. 9.7.2.Our targeted advertising cookies collect anonymous information; however, if you have an account with us, the information collected by us using our targeted advertising cookies may be associated with your account.
  1. 9.8.Additionally, after you have entered your email address and password during a session on the services cookies assist in retaining that information, so you do not have to re-enter it repeatedly during that session. This can be extended, where you have agreed to do so, for future automatic logins.
  2. 9.9.We also collect information through similar technology and unique identifiers as envisaged in section “Personal data”. We use such information for the same purposes as the information collected through cookies, namely:
  1. 9.9.1.authentication;
  2. 9.9.2.security;
  3. 9.9.3.storing preferences and supporting additional features and functionalities;
  4. 9.9.4.performance, analytics and personalization;
  5. 9.9.5.marketing.
  6. 9.9.6.The time the Cookie will stay on your computer or mobile device depends on the type of the Cookies whether it is “persistent” or “session” Cookie: “session” cookies will only stay on your device until you stop browsing; “persistent” cookies stay on your computer or mobile device until they expire or are deleted.
  7. 9.9.7.To learn more about cookies, you can visit allaboutcookies.org.
  8. 9.9.8.To manage the collection of information through cookies or other equivalent technology you can use the settings on your browser or mobile device. Please note, that we do not recognize or respond to browser-initiated Do Not Track signals, as the internet industry has not fully developed Do Not Track standards, implementations and solutions. To learn more about Do Not Track signals, you can visit allaboutdnt.com.
  1. CUSTOMER’S SECURITY COMMITMENTS  
  1. 10.1.We take the best efforts to ensure the secure storage and processing of your data. However, no system is 100% secure and we do not guarantee or warrant the security of the data that you choose to store or transfer outside our systems or our sub-processors’ systems. You acknowledge and agree that the described security measures implemented and maintained by us to protect your personal data and other related data provide a level of security appropriate to the risk in respect of your personal data.
  2. 10.2.You agree that without prejudice to our security measures and data incidents you are responsible for the use of our services, namely for making appropriate use of our services to ensure a level of security appropriate to the risk in respect of your personal data and securing the account authorisation credentials, system and devices which you use to access your account. Please also change your authorization credentials from time to time.
  1. ADJUST NOTIFICATIONS AND EMAIL PREFERENCES
  1. 11.1.The Company provides for you a way to remove yourself from our marketing communications. The simplest way to do this is to follow the unsubscribe link at the bottom of every email in case you received an email. Alternatively, you can contact our customer services department or live chat.
  2. 11.2.Please note that any administrative or service-related emails (for example to advise you of an update to our Privacy Policy or Terms of Service) do not offer an option to unsubscribe and such option will be ineffective as they are necessary to provide the services you requested.
  1. PRIVACY POLICY INFORMATION
  1. 12.1.The Company reserves the right to modify this Privacy Policy at any time, so it is your obligation to review it occasionally. If we make changes to this Privacy Policy, the updated Privacy Policy will be posted on the Website in a timely manner and where we make material changes, we will also provide a prominent notice. If you object to any of these changes you should stop using the services and request for your account to be closed.
  2. 12.2.This Privacy Policy was written in English. To the extent a translated version conflicts with the English version, the English version prevails. Unless directly indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control.
  1. CONTACTS
  1. 13.1.Any questions or comments about this Privacy Policy can be submitted by mail to the address below or by email to hr@7partnersagency.com. You can use this email to contact our Data Protection Officer regarding privacy inquiries. To ensure the prompt response please type ‘ATTN: DPO’ in the subject line of the email. You can also contact your local Data Protection Authority or another appropriate authority.
  2. 13.2.If you have any legal complaints that cannot be or are not resolved by negotiating with us     , you have the right to lodge a complaint with the Data Protection Authorities. Such authorities will expect that you have raised your concerns directly with us to try and resolve in a reasonable time period before escalating the matter.