ENGLISH

Naralimon Privacy Notice

Who we are

Naralimon S.C. Calle Tamarindos 7 Mijas Costa 29651 (Málaga) Spain

We manage various web domains including, but not limited to, naralimon.com, naralimon.biz, naralimon.es, naralimon.online, therefore our policy refers to all the domains we manage.

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/.

After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

We use Google Analytics with anonymization function.

Who we share your data with

We do not cede or sell your personal data.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Our contact information

Sienda ltd, Third Floor 207 Regent Street, W1B 3HH London, UK (hub@siendaweblines.com)

Additional information

How we protect your data

We comply with the UK Data Protection Act 2018 and the EU Reg. 2016/679 GDPR

What data breach procedures we have in place

We have in place all mandatory procedures in compliance with the GDPR

What third parties we receive data from

No third parties data at the moment

What automated decision making and/or profiling we do with user data

No automated decisions are making at this website at the moment.

Industry regulatory disclosure requirements

The user registration platforms, digital marketing services, and data processing platforms, are managed by Sienda ltd, based in London, of which we operate in partnership. Sienda ltd is a company registered with ICO (UK Privacy Commissioner). As required by the GDPR, specific agreements are in place for the processing of data between Naralimon S.C. and Sienda ltd, which operates in all these cases as Data Processor. For any request on privacy and personal data protection rights, you can send your requests to: Naralimon s.c. privacy@naralimon.com - Calle Tamarindos 7 - Mijas Costa 29651 (Malaga) Spain.

Please read here our complete Privacy Policy, Terms of Use, and Legal Terms by Sienda ltd

Updated 23/10/2020

Sienda ltd Privacy Notice

Affiliate Links

This website contains affiliate links. When you click on an affiliate link and complete a purchase, we get a small part of your purchase at no extra cost for you.

PRIVACY NOTICE

This privacy notice tells you about the information we collect from you when you subscribe one of our websites, web or mobile applications (collectively the Service). In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.

Who are we? (Data Controller)

Sienda Ltd, Third Floor, 207 Regent Street, London W1B 3HH, United Kingdom – Company No. 08194971 – Tel. +44 20 32399375 – info(at)siendamedia.com, siendamedia.com

We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.

Data Processor

This policy is also valid when we act as Data Processors. Please, send all enquiries about your privacy rights to the above address

Purchase or Subscription to Our Digital Services

What personal data do we collect?

When you subscribe and or purchase services from us, we ask you for your name and email, in addition, you might need to provide business name, address, contact telephone number, and other relevant information to finalize your subscription/purchase, e.g. government IDs, VAT code if applicable, etc.

Why do we collect this information?

We will use your information to comply with the law (invoice, tax, etc.), to verify your identity, process your order and to deliver the service you have subscribed or purchased. This policy, in fact, applies to both free and paid services. We will also send you a receipt via email and we may use your telephone number or email to contact you regarding your service/order, since we have to fulfil our contract with you.

What do we do with your information?

Your information is stored in our systems based in the EU. We also use servers located in the USA. We only use services by providers that are certified to the EU-US Privacy Shield (which requires effective safeguards for your information) and we resort to providers that comply with the GDPR.

We use Paypal as a third-party payment processor for our online services. We do not require, nor do we store, nor do we know, any of your payment information (credit cards, etc.) for our online services. However, we may let you pay some of our services through wire transference (bank) or credit card directly to us but this must be previously agreed.

Under certain circumstances, we might as well need to use a third-party partner to deliver your services and thus we share with them your name, address and telephone number and or email in order to complete the delivery. In this case, we will let you know the partner company beforehand.

We do not use the information you provide to make any automated decisions that might affect you.

We ask for your consent to deliver the service to you, and we will only deliver the service for as long as you continue to consent.

How long do we keep your information?

Unless you create an account with us, we keep your order information for one year after purchase. Your personal information associated with the order will then be removed.

Newsletter and Blog Subscriptions

What personal data do we collect?

When you subscribe to our newsletter, we ask you for your name and your email address, but we might only ask your email.

Why do we collect this information?

We will use your information to send you our newsletter, which contains information about our services and often includes special offers, to send you notifications of new posts on our blog, or to inform you about a certain service you did subscribe. If you subscribe to blog post notifications, you will only receive emails when new posts are published, no other marketing email will be sent.

We ask for your consent to do this, and we will only send you our newsletter/blog notification, for as long as you continue to consent.

What do we do with your information?

Your information is stored in our database and is not shared with any third parties. We will not use the information to make any automated decisions that might affect you.

How long do we keep your information?

Your information is kept for as long as you continue to consent to receive our newsletter/blog notification.

How to withdraw your consent (Services/Newsletter/Blog subscriptions)

You can withdraw the consent you are giving at any time. You can do this by writing to us or emailing us at the above addresses or by clicking on the unsubscribe link at the bottom of emails you receive. You can also delete your account with us at any time by means of the functions into your profile page or contact us for help.

Your rights over your information

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate.

You can also ask us to give you a copy of the information and to stop using your information for a period of time if you believe we are not doing so lawfully.

To submit a request by email or post, please use the contact information provided above.

Your right to complain

If you have a complaint about our use of your information, you can contact the Information Commissioner’s Office via their website at https://ico.org.uk/concerns/ or write to them at:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, UK

Updated on 23/10/2020

Privacy Policy

AGREEMENT (User Agreement)

This policy governs all of the websites, web and mobile applications, platforms and software (collectively the “Service”) provided by Sienda ltd, a company registered in England and Wales No. 08194971, registered office Third Floor 207 W1B 3HH London, UK, (“Sienda,” “We,” “our,” “us,” the “Company”).

This agreement, also called user agreement (AGREEMENT), includes all of the policies subsequently published here and so it constitutes the entire agreement between You (the user/visitor) and the Company in relation to your use of the Service, and supersedes all previous agreements in respect of your use of the Service.

Publications, products, web and mobile apps, content or services referenced herein or on the Service are the exclusive trademarks or servicemarks of the Company. Other products and company names mentioned in the Service may be the trademarks of their respective owners.

By using the Service, you are requested to read, understand, and accept these terms provided by this AGREEMENT. If you disagree, please, abandon the service.

PRIVACY NOTICE

Who are we? (Data Controller)

Sienda Ltd, Third Floor, 207 Regent Street, London W1B 3HH, United Kingdom – Company No. 08194971 – Tel. +44 20 32399375 – info(at)siendamedia.com, siendamedia.com

We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.

Purchase or Subscription to Our Digital Services

What personal data do we collect?

Why do we collect this information?

What do we do with your information?

Your information is stored in our systems based in the EU. We only use services by providers that guarantee high level of data protection (which requires effective safeguards for your information) and we resort to providers that comply with the GDPR.

We do not use the information you provide to make any automated decisions that might affect you.

We ask for your consent to deliver the service to you, and we will only deliver the service for as long as you continue to consent.

How long do we keep your information?

Unless you create an account with us, we keep your order information for one year after purchase. Your personal information associated with the order will then be removed.

Newsletter and Blog Subscriptions

What personal data do we collect?

When you subscribe to our newsletter, we ask you for your name and your email address, but we might only ask your email.

Why do we collect this information?

We ask for your consent to do this, and we will only send you our newsletter/blog notification, for as long as you continue to consent.

What do we do with your information?

Your information is stored in our database and is not shared with any third parties. We will not use the information to make any automated decisions that might affect you.

How long do we keep your information?

Your information is kept for as long as you continue to consent to receive our newsletter/blog notification.

How to withdraw your consent (Services/Newsletter/Blog subscriptions)

Your rights over your information

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate.

You can also ask us to give you a copy of the information and to stop using your information for a period of time if you believe we are not doing so lawfully.

To submit a request by email or post, please use the contact information provided above.

Your right to complain

If you have a complaint about our use of your information, you can contact the Information Commissioner’s Office via their website at https://ico.org.uk/concerns/ or write to them at:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, UK

PRIVACY POLICY

Website owner, Data Controller and Processor

Sienda Ltd, Third Floor, 207 Regent Street, London W1B 3HH, United Kingdom – Company Number 08194971 – Tel. +44 20 32399375 – info(at)siendamedia.com, siendamedia.com

DPO, please contact: hub(at)siendaweblines.com

Sienda ltd cares about your privacy. For this reason, we collect and use personal data only as it might be needed for us to deliver to you our products or services, websites and mobile applications (collectively, our “Services”). Your personal data includes information such as:

Name

Address

Telephone number

Date of birth

Email address

Other data collected that could, directly or indirectly, identify you.

Our Privacy Policy is intended to describe to you how and what data we collect, and how and why we use your personal data. It also describes options we provide for you to access, update or otherwise take control of your personal data that we process.

If at any time you have questions about our practices or any of your rights described below, you may reach us at the details above (Data Controller). We manage the inbox aforementioned so that you can get an experience you can confidently trust.

Relevant legislation.

Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation concerning data protection and user privacy:

UK Data Protection Act 2018 (DPA)

EU General Data Protection Regulation 2018 Reg. EU 2016/679 GDPR

This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation, you should contact for explanation, please, see above “Website owner, Data Controller and Processor.”

What information do we collect?

We collect information so that we can provide the best possible experience when you use our Services. Much of what you likely consider personal data is collected directly from you when you:

(1) Create an account or purchase any of our Services (such as billing information, including name, address, VAT Code or other type of government identification if needed and other relevant data in order to deliver the service). We do not store your financial information (credit card, etc.) as we use Paypal as gateway for payments and so all of your transactions are safe and your data secure with Paypal;

(2) Request assistance from our support team (such as email or phone number). Check our contact page for support requests;

(3) Complete contact forms or request newsletters or other information from us (such as email); or

(4) Participate in contests and surveys, apply for a job, or otherwise participate in activities we promote that might require information about you.

However, we also collect additional information when delivering our Services to you to ensure necessary and optimal performance. These methods of collection may not be as obvious to you, so we wanted to highlight and explain below a bit more about what these might be (as they vary from time to time) and how they work. Keep reading, please.

Account related information is collected in association with your use of our Services, such as account number, purchases, when products renew or expire, information requests, and customer service requests and notes or details explaining what you asked for and how we responded.

Cookies and similar technologies on our websites and our mobile applications allow us to track your browsing behavior, links clicked, items purchased, your device type, and to collect various data, including analytics, about how you use and interact with our Services. This allows us to provide you with more relevant product offerings, a better experience on our sites and mobile applications, and to collect, analyze and improve the performance of our Services. We may also collect your location (IP address) so that we can personalize our Services. For additional information, and to learn how to manage the technologies we operate, please visit our Cookie Policy hereinafter.

Data about Usage of Services is automatically collected when you use and interact with our Services, including metadata, log files, cookie/device IDs and location information. This information includes specific data about your interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data, and some of this data collected might be capable of and be used to approximate your location.

Supplemented Data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyze the accuracy of our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Blogs

We also build and manage blogs of ours.

When you add a comment to any posts we publish on our blog (blogs), the name and email address you enter with your comment will be saved to the blog’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors detailed below. Only your name will be shown on the public-facing website although if the supplied email address is linked to a Gravatar account, your Gravatar photo will also be displayed.

Your comment and its associated personal data will remain on the blog site until we see fit to either 1.) remove the comment or 2.) remove the blog post. Should you wish to have the comment and its associated personal data deleted, please email us via our Contact Page using the email address that you commented with. Please, be specific about which comment or comments you want us to delete.

If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog. See below our statement about Child Protection 5.3.

TAKE NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.

Contact forms and email links

Should you choose to contact us using the contact form on our Contact Page or an email link, none of the data that you supply will be stored by this website (or other our websites) or passed to / be processed by any of the third party data processors. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.

Email newsletter

If you choose to join our email newsletter, the email address that you submit to us will be forwarded to our email service managed by Google (Google Apps). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.

Your email address will remain within Google’s database for as long as we continue to use these services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.

While your email address remains within a database of one of the services abovementioned, you will receive periodic (approximately three times a year) newsletter-style emails from us, unless you subscribe to one of our blogs, in which case you may receive emails informing you of new publications every time a new post is published. . The new blog post notification emails are sent through our automated subscription to blog system.

How we use information.

We strongly believe in both minimizing the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the Services you purchase or interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes. These uses include:

Delivering, improving, updating and enhancing the Services we provide to you. We collect various information relating to your purchase, use and/or interactions with our Services. We utilize this information to:

Improve and optimize the operation and performance of our Services (again, including our websites and mobile applications)

Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services

Detect and prevent fraud and abuse of our Services and systems

Collecting aggregate statistics about use of the Services

Understand and analyze how you use our Services and what products and services are most relevant to you.

Often, much of the data collected is aggregated or statistical data about how individuals use our Services, and is not linked to any personal data, but to the extent it is itself personal data, or is linked or linkable to personal data, we treat it accordingly.

Sharing with trusted third parties. We may share your personal data with affiliated companies within our corporate family, with third parties with which we have partnered to allow you to integrate their services into our own Services, and with trusted third party service providers as necessary for them to perform services on our behalf, such as:

Processing payments (Paypal)

Serving advertisements

Conducting contests or surveys

Performing analysis of our Services and customers demographics

Communicating with you, such as by way email or survey delivery

Customer relationship management.

We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from using, sharing or retaining your personal data for any other purpose than as they have been specifically contracted for (or without your consent).

Communicating with you. We may contact you directly or through a third party service provider regarding products or services you have signed up or purchased from us, such as necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you will find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:

Text (SMS) messages / Messengers

Telephone calls (we use phone calls only if necessary and we never call you over the phone to sell you products)

Automated phone calls or text messages (for securing services and ascertain your identity).

You may also update your subscription preferences with respect to receiving communications from us and/or our partners by signing into your account and visiting “Account Settings” or “Profile” page.

If we collect information from you in connection with a co-branded offer, it will be clear at the point of collection who is collecting the information and whose privacy policy applies. In addition, it will describe any choice options you have in regards to the use and/or sharing of your personal data with a co-branded partner, as well as how to exercise those options.

If you make use of a service that allows you to import contacts (such us using email marketing services to send emails on your behalf), we will only use the contacts and any other personal information for the requested service. If you believe that anyone has provided us with your personal information and you would like to request that it be removed from our database, please contact us via the addresses aforementioned (Data Controller).

Website analytics.

We use web analytics tools provided by service partners such as Google Analytics, to collect information about how you interact with our website or mobile applications, including what pages you visit, what site you visited prior to visiting our website, how much time you spend on each page, what operating system and web browser you use and network and IP information. We use the information provided by these tools to improve our Services. These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our website. Each cookie cannot be used by anyone other than the service provider (such as Google for Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. Though information collected does not include personal data such as name, address, billing information, etc., the information collected is used and shared by these service providers in accordance with their individual privacy policies. You can control the technologies we use by managing your settings through our Cookie Policy or the ‘cookie banners” that may be presented (depending on URL of website visited) when you first visit our webpages, or by utilizing settings in your browser or third party tools, such as Disconnect (https://disconnect.me/disconnect) or Ghostery (https://www.ghostery.com/) and others.

Targeted advertisements.

Targeted ads or interest-based offers may be presented to you based on your activities on our webpages, and other websites, and based on the products you currently own. These offers will display as varying product banners presented to you while browsing. We also partner with third parties to manage our advertising on our webpages and other websites. Our third party partners may use technologies such as cookies to gather information such activities in order to provide you with advertising based upon your browsing activities and interests, and to measure advertising effectiveness. If you wish to opt out of interest-based advertising, for EU citizens use this service http://www.youronlinechoices.eu/

US and other countries use this service http://preferences-mgr.truste.com/

Please, be informed that you will continue receiving generic ads.

Transfer of personal data abroad.

If you make use of our Services from a country other than the country where our servers are located, your communications with us may result in transferring your personal data across international borders. Also, when you call us or initiate a chat, we may provide you with support from one of our global locations outside your country of origin. In these cases, your personal data is handled according to this Privacy Policy. We use hosting services located in the EU and the US. When we use services from US companies, we resort to businesses that guarantee high level of data protection and which comply with the GDPR.

Compliance with legal, regulatory and law enforcement requests. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.

Please, see below Chapter "EEA and UK users - Privacy Shield Notice"

Third-party websites.

Our Service(s) (websites and mobile applications) contain links to third-party websites. We are not responsible for the privacy practices or the content of third-party sites. Please read the privacy policy of any website you visit.

EEA and UK users - Privacy Shield Notice

The section below will apply only to users in the European Economic Area, or other jurisdictions where the Standard Contractual Clauses apply.

STANDARD CONTRACTUAL CLAUSES (Controllers)

Data transfer agreement between

You, the user who is registering for an account at our Site and [the user being] based in the European Economic Area

hereinafter “data exporter”

and

Sienda ltd, Third Floor 207 Regent Street, London W1B 3HH, UK

hereinafter “data importer”

each a “party”; together “the parties”.

Definitions

For the purposes of the clauses: “personal data”, “special categories of data/sensitive data”, “process/processing”, “controller”, “processor”, “data subject” and “supervisory authority/authority” shall have the same meaning as in Directive 95/46/EC of 24 October 1995 (whereby “the authority” shall mean the competent data protection authority in the territory in which the data exporter is established); it is here specified that art. 94 of the GDPR (Reg. EU 2016/679) repeals “the Directive 95/46/EC is repealed with effect from 25 May 2018” - The current legislation in force is EU Regulation 679 14 April 2016 General Data Protection Regulation also spelled EU 2016/679 GDPR or simply GDPR.

THE GDPR (General Data Protection Regulation) is a regulation in EU law on data protection and privacy in the European Union and the European Economic Area. It also addresses the transfer of personal data outside the EU and EEA areas. The GDPR Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (Data Protection Directive)

Our policy complies with the EU Reg. GDPR

“the data exporter” shall mean the controller who transfers the personal data;

“the data importer” shall mean the controller who agrees to receive from the data exporter personal data for further processing in accordance with the terms of these clauses and who is not subject to a third country’s system ensuring adequate protection;

“clauses” shall mean these contractual clauses, which are a free-standing document that does not incorporate commercial business terms established by the parties under separate commercial arrangements.

The details of the transfer (as well as the personal data covered) are specified in Annex B, which forms an integral part of the clauses.

Clause I

Obligations of the data exporter

The data exporter warrants and undertakes that:

The personal data have been collected, processed, and transferred in accordance with the laws applicable to the data exporter.

It has used reasonable efforts to determine that the data importer is able to satisfy its legal obligations under these clauses.

It will provide the data importer, when so requested, with copies of relevant data protection laws or references to them (where relevant, and not including legal advice) of the country in which the data exporter is established.

It will respond to enquiries from data subjects and the authority concerning processing of the personal data by the data importer, unless the parties have agreed that the data importer will so respond, in which case the data exporter will still respond to the extent reasonably possible and with the information reasonably available to it if the data importer is unwilling or unable to respond. Responses will be made within a reasonable time.

It will make available, upon request, a copy of the clauses to data subjects who are third party beneficiaries under clause III, unless the clauses contain confidential information, in which case it may remove such information. Where information is removed, the data exporter shall inform data subjects in writing of the reason for removal and of their right to draw the removal to the attention of the authority. However, the data exporter shall abide by a decision of the authority regarding access to the full text of the clauses by data subjects, as long as data subjects have agreed to respect the confidentiality of the confidential information removed. The data exporter shall also provide a copy of the clauses to the authority where required.

Clause II

Obligations of the data importer

The data importer warrants and undertakes that:

It will have in place appropriate technical and organisational measures to protect the personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, and which provide a level of security appropriate to the risk represented by the processing and the nature of the data to be protected.

It will have in place procedures so that any third party it authorises to have access to the personal data, including processors, will respect and maintain the confidentiality and security of the personal data. Any person acting under the authority of the data importer, including a data processor, shall be obligated to process the personal data only on instructions from the data importer. This provision does not apply to persons authorised or required by law or regulation to have access to the personal data.

It has no reason to believe, at the time of entering into these clauses, in the existence of any local laws that would have a substantial adverse effect on the guarantees provided for under these clauses, and it will inform the data exporter (which will pass such notification on to the authority where required) if it becomes aware of any such laws.

It will process the personal data for purposes described in Annex B and has the legal authority to give the warranties and fulfil the undertakings set out in these clauses.

It will identify to the data exporter a contact point within its organisation authorised to respond to enquiries concerning processing of the personal data, and will cooperate in good faith with the data exporter, the data subject and the authority concerning all such enquiries within a reasonable time. In case of legal dissolution of the data exporter, or if the parties have so agreed, the data importer will assume responsibility for compliance with the provisions of clause I(e).

At the request of the data exporter, it will provide the data exporter with evidence of financial resources sufficient to fulfil its responsibilities under clause III (which may include insurance coverage).

Upon reasonable request of the data exporter, it will submit its data processing facilities, data files and documentation needed for processing to reviewing, auditing and/or certifying by the data exporter (or any independent or impartial inspection agents or auditors, selected by the data exporter and not reasonably objected to by the data importer) to ascertain compliance with the warranties and undertakings in these clauses, with reasonable notice and during regular business hours. The request will be subject to any necessary consent or approval from a regulatory or supervisory authority within the country of the data importer, which consent or approval the data importer will attempt to obtain in a timely fashion.

It will process the personal data, at its option, in accordance with: the data protection laws of the country in which the data exporter is established, or the relevant provisions of any Commission decision pursuant to GDPR Article 25(6), where the data importer complies with the relevant provisions of such an authorisation or decision and is based in a country to which such an authorisation or decision pertains, but is not covered by such authorisation or decision for the purposes of the transfer(s) of the personal data, or the data processing principles set forth in Annex A. Data importer to indicate which option it selects: The data protections laws of the region where the exporter is based, namely, the General Data Protection Regulation (GDPR).

It will not disclose or transfer the personal data to a third party data controller located outside the European Economic Area (EEA) unless it notifies the data exporter about the transfer and the third party data controller processes the personal data in accordance with a Commission decision finding that a third country provides adequate protection, or the third party data controller becomes a signatory to these clauses or another data transfer agreement approved by a competent authority in the EU, or data subjects have been given the opportunity to object, after having been informed of the purposes of the transfer, the categories of recipients and the fact that the countries to which data is exported may have different data protection standards, or with regard to onward transfers of sensitive data, data subjects have given their unambiguous consent to the onward transfer.

Clause III

Liability and third party rights

Each party shall be liable to the other parties for damages it causes by any breach of these clauses. Liability as between the parties is limited to actual damage suffered. Punitive damages (i.e. damages intended to punish a party for its outrageous conduct) are specifically excluded. Each party shall be liable to data subjects for damages it causes by any breach of third party rights under these clauses. This does not affect the liability of the data exporter under its data protection law.

The parties agree that a data subject shall have the right to enforce as a third party beneficiary this clause and clauses I(b), I(d), I(e), II(a), II(c), II(d), II(e), II(h), II(i), III(a), V, VI(d) and VII against the data importer or the data exporter, for their respective breach of their contractual obligations, with regard to his personal data, and accept jurisdiction for this purpose in the data exporter’s country of establishment. In cases involving allegations of breach by the data importer, the data subject must first request the data exporter to take appropriate action to enforce his rights against the data importer; if the data exporter does not take such action within a reasonable period (which under normal circumstances would be one month), the data subject may then enforce his rights against the data importer directly. A data subject is entitled to proceed directly against a data exporter that has failed to use reasonable efforts to determine that the data importer is able to satisfy its legal obligations under these clauses (the data exporter shall have the burden to prove that it took reasonable efforts).

Clause IV

Law applicable to the clauses

These clauses shall be governed by the law of the country in which the data exporter is established, with the exception of the laws and regulations relating to processing of the personal data by the data importer under clause II(h), which shall apply only if so selected by the data importer under that clause.

Clause V

Resolution of disputes with data subjects or the authority

In the event of a dispute or claim brought by a data subject or the authority concerning the processing of the personal data against either or both of the parties, the parties will inform each other about any such disputes or claims, and will cooperate with a view to settling them amicably in a timely fashion.

The parties agree to respond to any generally available non-binding mediation procedure initiated by a data subject or by the authority. If they do participate in the proceedings, the parties may elect to do so remotely (such as by telephone or other electronic means). The parties also agree to consider participating in any other arbitration, mediation or other dispute resolution proceedings developed for data protection disputes.

Each party shall abide by a decision of a competent court of the data exporter’s country of establishment or of the authority which is final and against which no further appeal is possible.

Clause VI

Termination

In the event that the data importer is in breach of its obligations under these clauses, then the data exporter may temporarily suspend the transfer of personal data to the data importer until the breach is repaired or the contract is terminated.

In the event that: the transfer of personal data to the data importer has been temporarily suspended by the data exporter for longer than one month pursuant to paragraph (a); compliance by the data importer with these clauses would put it in breach of its legal or regulatory obligations in the country of import; the data importer is in substantial or persistent breach of any warranties or undertakings given by it under these clauses; a final decision against which no further appeal is possible of a competent court of the data exporter’s country of establishment or of the authority rules that there has been a breach of the clauses by the data importer or the data exporter; or a petition is presented for the administration or winding up of the data importer, whether in its personal or business capacity, which petition is not dismissed within the applicable period for such dismissal under applicable law; a winding up order is made; a receiver is appointed over any of its assets; a trustee in bankruptcy is appointed, if the data importer is an individual; a company voluntary arrangement is commenced by it; or any equivalent event in any jurisdiction occurs then the data exporter, without prejudice to any other rights which it may have against the data importer, shall be entitled to terminate these clauses, in which case the authority shall be informed where required. In cases covered by (i), (ii), or (iv) above the data importer may also terminate these clauses.

Either party may terminate these clauses if (i) any Commission positive adequacy decision under Article 25(6) of Directive 95/46/EC (or any superseding text) is issued in relation to the country (or a sector thereof) to which the data is transferred and processed by the data importer, or (ii) Directive 95/46/EC (or any superseding text) becomes directly applicable in such country.

The parties agree that the termination of these clauses at any time, in any circumstances and for whatever reason (except for termination under clause VI(c)) does not exempt them from the obligations and/or conditions under the clauses as regards the processing of the personal data transferred.

Clause VII

Variation of these clauses

The parties may not modify these clauses except to update any information in Annex B, in which case they will inform the authority where required. This does not preclude the parties from adding additional commercial clauses where required.

Clause VIII

Description of the Transfer

The details of the transfer and of the personal data are specified in Annex B. The parties agree that Annex B may contain confidential business information which they will not disclose to third parties, except as required by law or in response to a competent regulatory or government agency, or as required under clause I(e). The parties may execute additional annexes to cover additional transfers, which will be submitted to the authority where required. Annex B may, in the alternative, be drafted to cover multiple transfers.

ANNEX A

DATA PROCESSING PRINCIPLES

Purpose limitation: Personal data may be processed and subsequently used or further communicated only for purposes described in Annex B or subsequently authorised by the data subject.

Data quality and proportionality: Personal data must be accurate and, where necessary, kept up to date. The personal data must be adequate, relevant and not excessive in relation to the purposes for which they are transferred and further processed.

Transparency: Data subjects must be provided with information necessary to ensure fair processing (such as information about the purposes of processing and about the transfer), unless such information has already been given by the data exporter.

Security and confidentiality: Technical and organisational security measures must be taken by the data controller that are appropriate to the risks, such as against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, presented by the processing. Any person acting under the authority of the data controller, including a processor, must not process the data except on instructions from the data controller.

Rights of access, rectification, deletion and objection: As provided in Article 12 of Directive 95/46/EC, data subjects must, whether directly or via a third party, be provided with the personal information about them that an organisation holds, except for requests which are manifestly abusive, based on unreasonable intervals or their number or repetitive or systematic nature, or for which access need not be granted under the law of the country of the data exporter. Provided that the authority has given its prior approval, access need also not be granted when doing so would be likely to seriously harm the interests of the data importer or other organisations dealing with the data importer and such interests are not overridden by the interests for fundamental rights and freedoms of the data subject. The sources of the personal data need not be identified when this is not possible by reasonable efforts, or where the rights of persons other than the individual would be violated. Data subjects must be able to have the personal information about them rectified, amended, or deleted where it is inaccurate or processed against these principles. If there are compelling grounds to doubt the legitimacy of the request, the organisation may require further justifications before proceeding to rectification, amendment or deletion. Notification of any rectification, amendment or deletion to third parties to whom the data have been disclosed need not be made when this involves a disproportionate effort. A data subject must also be able to object to the processing of the personal data relating to him if there are compelling legitimate grounds relating to his particular situation. The burden of proof for any refusal rests on the data importer, and the data subject may always challenge a refusal before the authority.

Sensitive data: The data importer shall take such additional measures (e.g. relating to security) as are necessary to protect such sensitive data in accordance with its obligations under clause II.

Data used for marketing purposes: Where data are processed for the purposes of direct marketing, effective procedures should exist allowing the data subject at any time to “opt-out” from having his data used for such purposes.

Automated decisions: For purposes hereof “automated decision” shall mean a decision by the data exporter or the data importer which produces legal effects concerning a data subject or significantly affects a data subject and which is based solely on automated processing of personal data intended to evaluate certain personal aspects relating to him, such as his performance at work, creditworthiness, reliability, conduct, etc. The data importer shall not make any automated decisions concerning data subjects, except when: a) i. such decisions are made by the data importer in entering into or performing a contract with the data subject, and ii. the data subject is given an opportunity to discuss the results of a relevant automated decision with a representative of the parties making such decision or otherwise to make representations to that parties. or b) where otherwise provided by the law of the data exporter.

ANNEX B

DESCRIPTION OF THE TRANSFER

Data subjects -- The personal data transferred concern the following categories of data subjects: You, the user registering for a Coursera account

Purposes of the transfer(s) -- The transfer is made for the following purposes: Coursera needs certain personal data to provide our services and ensure functionality of our platform. Your name is used to personalize content, put on any certificates you earn, and verify your identity as needed for certain content. Your email address is used as your account login credential and for communication. Your IP address is used to personalize content such as currency and time zone. More information on the data we collect and the purposes for which we collect it can be found in our Privacy Notice.

Categories of data -- The personal data transferred concern the following categories of data: Name, email address, IP address, other data as described in the Privacy Notice

Recipients -- The personal data transferred may be disclosed only to the following recipients or categories of recipients: Coursera, Inc. and its affiliates, vendors, and partners.

Sensitive data (if appropriate) -- The personal data transferred concern the following categories of sensitive data: None.

Data protection registration information of data exporter (where applicable) -- Not applicable.

Additional useful information (storage limits and other relevant information) -- You can delete your account, and thereby remove your personal data from our systems, at any time once your account is created. The ‘Delete Account’ functionality can be found on your ‘Account Settings’ page towards the bottom.

Contact points for data protection enquiries

Data importer

Sienda ltd, 207 Regent Street W1B 3HH London, UK

Attn: Legal and Compliance (Privacy)

or email: privacy@sienda.co.uk

Privacy Shield Notice

Effective as of January 1, 2020.

Cookie Policy

COOKIE POLICY

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about webpage traffic and improve our Website(s) in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better Website(s) by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Our advertisers may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on advertisements on our Website(s)/Service.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website(s).

You can adjust the settings on your computer to decline any cookies if you wish. This can be done within the “settings” section of your computer. For more information, please, read the advice at About Cookies Org https://www.aboutcookies.org/ and here at Cookies & You https://cookies.insites.com/

What Are Cookies

As is common practice with almost all professional Websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.

For more general information on cookies see the Wikipedia article on Cookies… at http://en.wikipedia.org/wiki/HTTP_cookie

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately is most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other Websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies. For more information please read the advice at AboutCookies.org, click here to go

Forms and subscriptions

This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.

From time to time we offer user surveys and questionnaires to provide you with interesting insights, helpful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already taken part in a survey or to provide you with accurate results after you change pages.

When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.

For more information on Google Analytics cookies, see the official Google Analytics page at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.

From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.

As we sell products it’s important for us to understand statistics about how many of the visitors to our site actually make a purchase and as such this is the kind of data that these cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible price.

The Google AdSense service we use to serve advertising uses a DoubleClick cookie to serve more relevant ads across the web and limit the number of times that a given ad is shown to you.

For more information on Google AdSense see the official Google AdSense privacy FAQ at http://www.google.co.uk/policies/technologies/ads/

We use adverts to offset the costs of running this site and provide funding for further development. The behavioral advertising cookies used by this site are designed to ensure that we provide you with the most relevant adverts where possible by anonymously tracking your interests and presenting similar things that may be of interest.

In some cases we may provide you with custom content based on what you tell us about yourself either directly or indirectly by linking a social media account. These types of cookies simply allow us to provide you with content that we feel may be of interest to you.

Several partners advertise on our behalf and affiliate tracking cookies simply allow us to see if our customers have come to the site through one of our partner sites so that we can credit them appropriately and where applicable allow our affiliate partners to provide any bonus that they may provide you for making a purchase.

We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; facebook, twitter, tumblr, google+, wordpress, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

Updated 23/10/2020

GDPR RIGHTS

GDPR RIGHTS

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

Whenever you are asked to fill in a form on the Website(s), Apps (the Service), look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes. However, we will provide separate forms for newsletters that include marketing purposes. For example, our blog subscription forms are only meant to notify of new posts published on our blog(s) and so we will never use that data to send you email marketing messages. Other forms, will state if they are made for marketing purposes and if you consent to subscribe accepting to receive email-marketing messages. Nonetheless, we do not believe in email marketing, and it is a practice we have never massively used. We might use it only under certain circumstances but it is not our goal. We prefer other methods, less harassing and more beneficial for both our users and us.

Nonetheless, If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us.

Lawful basis and rights.

Lawful basis for processing data.

In relation to Article 6 of the GDPR the Company makes clear that the lawful basis for processing data are:

Consent: the individual has given clear consent for us to process their personal data for a specific purpose. We specify that the individual has the right to: 1) erasure; 2) portability; 3) no right to object but the right to withdraw consent.

Contract: the processing is necessary for a contract we have with the individual, or because they have asked us to take specific steps before entering into a contract. We specify that the individual has the right to: 1) erasure; 2) portability; 3) no right to object.

Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations). We specify that the individual has no right to erasure, portability, object.

Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. We specify that the individual has: 1) the right to erasure; 2) no right to portability; 3) right to object.

With the purpose of explaining our procedures we declare the following:

We have reviewed the purposes of our processing activities, and selected the most appropriate lawful or bases for each activity.

We have checked that the processing is necessary for the relevant purpose, and are satisfied that there is no other reasonable way to achieve that purpose.

We have documented our decision on which lawful basis applies to help us demonstrate compliance.

We have included information about both the purposes of the processing and the lawful basis for the processing here in our Privacy Policy.

Where we process special category data, we have also identified a condition for processing special category data, and have documented this.

We do NOT process criminal offence data.

Consent.

Consent means offering individuals real choice and control. Genuine consent should put individuals in charge, build customer trust and engagement, and enhance our reputation.

We have checked that consent is the most appropriate lawful basis for processing.

We have made the request for consent prominent and separate from our terms and conditions.

We ask people to positively opt in (on modules on our websites and web pages, our platforms, software, apps).

We don’t use pre-ticked boxes or any other type of default consent.

We use clear, plain language that is easy to understand.

We specify why we want the data and what we’re going to do with it.

We give individual (‘granular’) options to consent separately to different purposes and types of processing.

We name our organization and any third party controllers who will be relying on the consent.

We tell individuals they can withdraw their consent. Please, write or email us if you want to withdraw your consent.

We ensure that individuals can refuse to consent without detriment.

We avoid making consent a precondition of a service.

If we offer online services directly to children, we only seek consent if we have age-verification measures (and parental-consent measures for younger children) in place. However, we specify that we do NOT offer services to children and, on the contrary, we have stated on this Privacy Policy, that the website (our websites, apps, and platforms) are not suitable for children even though we do not use to publish obscene content.

Recording consent.

We keep a record of when and how we got consent from the individual.

We keep a record of exactly what they were told at the time.

Managing consent.

We regularly review consents to check that the relationship, the processing and the purposes have not changed.

We have processes in place to refresh consent at appropriate intervals, including any parental consents.

We consider using privacy dashboards or other preference-management tools as a matter of good practice.

We make it easy for individuals to withdraw their consent at any time, and publicize how to do so. A speed method is to connect with us via our Contact page and ask for your rights.

We act on withdrawals of consent as soon as we can.

We don’t penalize individuals who wish to withdraw consent.

Individual rights.

The GDPR provides the following rights for individuals:

The right to be informed

The right of access

The right to rectification

The right to erase

The right to restrict processing

The right to data portability

The right to object

Rights in relation to automated decision making and profiling.

Right to be informed.

We inform individuals about the use of their personal data.

Right of access.

Under the GDPR, individuals have the right to obtain: Confirmation that their data is being processed;

Access to their personal data; and other supplementary information as provided in this Privacy Policy (see Article 15). You, the individual, can request access at any time. Please, contact us.

If requests are manifestly unfounded or excessive, in particular because they are repetitive, a reasonable fee may be charged taking into account the administrative costs of providing the information or refuse to respond.

Normally, we provide information immediately and at the latest within one month of receipt.

We reserve to extend the period of compliance by a further two months where requests are complex or numerous. In this case, we will inform the individual within one month of the receipt of the request and explain why the extension is necessary. This also applies to the subsequent cases.

Individuals are informed that where we process a large quantity of information about an individual, the GDPR allows us to ask the individual to specify the information the request relates to (Recital 63).

If we refuse to respond to a request, we will explain why to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month. This also applies to the subsequent cases.

Right to rectification.

Individuals are entitled to have personal data rectified if it is inaccurate or incomplete.

We comply with a request for rectification within one month. However, the period can be extended by two months where the request for rectification is complex

Where we are not taking action in response to a request for rectification, we will explain why to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy.

Right to erasure, aka the right to be forgotten.

As an individual you have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing.

The right to erasure does not provide an absolute ‘right to be forgotten’. Individuals have a right to have personal data erased and to prevent processing in specific circumstances:

Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.

When the individual withdraws consent.

When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.

The personal data was unlawfully processed (ie otherwise in breach of the GDPR).

The personal data has to be erased in order to comply with a legal obligation.

The personal data is processed in relation to the offer of information society services to a child.

Under the GDPR, this right is not limited to processing that causes unwarranted and substantial damage or distress. However, if the processing does cause damage or distress, this is likely to make the case for erasure stronger.

There are some specific circumstances where the right to erasure does not apply and we can refuse to deal with a request:

To exercise the right of freedom of expression and information;

To comply with a legal obligation for the performance of a public interest task or exercise of official authority.

For public health purposes in the public interest;

Archiving purposes in the public interest, scientific research historical research or statistical purposes; or the exercise or defense of legal claims.

If we have disclosed the personal data in question to third parties, we must inform them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so. This also applies to the subsequent cases.

Right to restrict processing.

Individuals have a right to ‘block’ or suppress processing of personal data.

When processing is restricted, we are permitted to store the personal data, but not further process it.

We can retain just enough information about the individual to ensure that the restriction is respected in future.

We are required to restrict the processing of personal data in the following circumstances:

Where an individual contests the accuracy of the personal data, we have to restrict the processing until we have verified the accuracy of the personal data.

Where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our organization’s legitimate grounds override those of the individual.

When processing is unlawful and the individual opposes erasure and requests restriction instead.

If we no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim.

We must inform individuals when we decide to lift a restriction on processing.

Right to data portability.

The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services.

It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.

It enables consumers to take advantage of applications and services which can use this data to find them a better deal, or help them understand their spending habits.

The right to data portability only applies:

To personal data an individual has provided to a controller;

Where the processing is based on the individual’s consent or for the performance of a contract; and

When processing is carried out by automated means.

The information is provided free of charge in machine-readable form. Open formats include CSV files.

Right to object.

Individuals have the right to object to:

processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);

direct marketing (including profiling); and

processing for purposes of scientific/historical research and statistics.

We will stop processing the personal data unless:

we are able to demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or

the processing is for the establishment, exercise or defense of legal claims.

You can exercise this and all of your rights as provided by the GDPR by contacting us at our Contact Page.

Rights related to automated decision-making including profiling.

We inform you that the GDPR has provisions on:

automated individual decision-making (making a decision solely by automated means without any human involvement);and

profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.

The GDPR applies to all automated individual decision-making and profiling.

According to Article 22 of the GDPR, when we are carrying out solely automated decision-making that has legal or similarly significant effects on them, we only carry out this type of decision-making where the decision is:

necessary for the entry into or performance of a contract; or

authorized by Union or Member state law applicable to the controller; or

based on the individual’s explicit consent.

We identify whether any of our processing falls under Article 22 and, if so, we make sure that we:

give individuals information about the processing;

introduce simple ways for them to request human intervention or challenge a decision;

carry out regular checks to make sure that our systems are working as intended.

Therefore, in order to comply with the GDPR:

We have a lawful basis to carry out profiling and/or automated decision-making and document this in our data protection policy.

We send individuals a link to our privacy statement when we have obtained their personal data indirectly.

We explain how people can access details of the information we used to create their profile.

We tell people who provide us with their personal data how they can object to profiling, including profiling for marketing purposes.

We have procedures for customers to access the personal data input into the profiles so they can review and edit for any accuracy issues.

We have additional checks in place for our profiling/automated decision-making systems to protect any vulnerable groups (including children).

We only collect the minimum amount of data needed and have a clear retention policy for the profiles we create.

AGAIN

We carry out a DPIA to identify the risks to individuals, show how we are going to deal with them and what measures we have in place to meet GDPR requirements.

We carry out processing under Article 22(1) for contractual purposes and we can demonstrate why it’s necessary.

We carry out processing under Article 22(1) because we have the individual’s explicit consent recorded. We can show when and how we obtained consent. We tell individuals how they can withdraw consent and have a simple way for them to do this.

We carry out processing under Article 22(1) because we are authorized or required to do so. This is the most appropriate way to achieve our aims.

We don’t use special category data in our automated decision-making systems unless we have a lawful basis to do so, and we can demonstrate what that basis is. We delete any special category data accidentally created.

We explain that we use automated decision-making processes, including profiling. We explain what information we use, why we use it and what the effects might be.

We have a simple way for people to ask us to reconsider an automated decision.

We have identified staff in our organization who are authorized to carry out reviews and change decisions.

We regularly check our systems for accuracy and bias and feed any changes back into the design process.

As a model of best practice, we use visuals to explain what information we collect/use and why this is relevant to the process.

We abide by a set of ethical principles to build trust with our customers. This is available on our website and on paper.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

We usually host our websites at providers using Green Enterprise-class Servers, which typically include:

24/7 monitoring of server including all services running (Web, E-mail, Database, Control Panel, DNS, RAID/drives performance, etc). The staff will be immediately notified in the event of a system/service failure which will result in escalation of the issue through the provider’s support channel.

Daily vulnerability scans of server.

Applying patches & software updates of any operating system, and server services, as such become available.

Running system performance checks to ensure that the hardware and software are functioning properly.

Immediate hardware replacement of any defective/failed server components.

Scheduled server/software upgrades with an early notice sent to customers, as well as instant tracking via Server Status notification system.

Only authorized security cleared staff are allowed into the facility.

Servers are located in USA, UK, and more places using a CDN service, content distribution network, a geographically distributed network of proxy servers and their data centers.

All traffic (transferal of files) between this website and your browser is encrypted and delivered over HTTPS. We use SSL SHA256RSA certificates. These certificates are End-to-end encryption (E2EE) that is, a system of communication where only the communicating users can read the messages. The systems are designed to defeat any attempts at surveillance or tampering because no third parties can decipher the data being communicated or stored. We resort to US providers who comply with the EU-US Privacy shield https://www.privacyshield.gov

Geolocation privacy

We may use Maps API Implementation (Google Maps API) to collect information from the user or the user’s device. Our Maps API Implementation does not obtain or cache any user’s location in any manner except with the user’s prior consent. Our Maps API Implementation lets the user revoke the user’s consent at any time. When our Maps API Implementation provides Google with geolocation data, that geolocation data does not enable Google to identify an individual user. (Example, if our Maps API Implementation sends Google our Content, and our Content includes geolocation data, our Content does not also include unique device identifiers associated with individual users). We disclose to the user that we may use services in order to obtain the user’s location and use it with any other data provider’s data. We notify users that we are using the Maps API(s) and incorporate by reference Google’s Privacy Policy by including a link to Google’s then-current Privacy Policy (at http://www.google.com/policies/privacy).

Cookies. As noted in the Documentation, certain Maps API(s) store and access cookies and other information on end users’ devices. By using any of these cookie-enabled Maps API(s) in our Maps API Implementation, then for end users in the European Union, we comply with the EU User Consent Policy. We explicitly state in our applications Terms of Use that by using our application, users are bound by Google’s Terms of Service. We notify users that you are using the Google Maps API(s) and incorporate by reference the Google Privacy Policy.

DISCLAIMERS

DISCLAIMER, SUBMISSIONS, AND LINKS

Affiliate Links

Some of our websites and digital platforms and services may contain affiliate links. When you click on an affiliate link and complete a purchase, we get a small part of your purchase at no extra cost for you.

Website(s)/Service disclaimer

The information contained in the Website(s) is for general information purposes only. The information is provided by Sienda ltd. and while we endeavor to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the Website(s) or the information, products, services, or related graphics contained on the Website(s) for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of the Service.

Through the Service you are able to link to other Websites which are not under the control of Sienda ltd. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.

User Submissions that you post to the Service.

Communications between you and Sienda ltd. For example, Sienda ltd may send you emails related to the Service (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of these e-mails.

Sienda ltd may offer certain services that are available via a mobile device or app, including (i) the ability to upload User Submissions to the Website(s) via a mobile device, (ii) the ability to browse the Website(s) from a mobile device and (iii) the ability to access certain features through an application downloaded and installed on a mobile device (collectively, the ”Mobile Services“). If you use the Mobile Services, Sienda ltd may store information regarding your mobile device, including your device type and operating system, the advertising ID of your mobile device, location services (if you grant permission), or in other applications as permitted by the functionality of such mobile device. In addition, Sienda ltd may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Sienda ltd. A device identifier may deliver information to Sienda ltd or to a third party partner about how you browse and use the Website(s) and may help Sienda ltd or others provide reports or personalized content and ads. Some features of the Website(s) may not function properly if use or availability of device identifiers is impaired or disabled.

Links to other Websites

Our Website(s) may contain links to other Websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other Website(s). Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the Website(s) in question.

All trademarks belong to their lawful owners.

TOS (TERMS OF SERVICE)

TOS (TERMS OF SERVICE)

If you require any more information or have any questions about our Terms of Service, please feel free to contact us, see above Website owner, Data Controller and Processor.

These terms of service, also called terms of use or TOS, govern all of the Service.

On Geolocation privacy

We explicitly state in our applications Terms of Use that by using our application, users are bound by Google’s Terms of Service. See above Geolocation privacy.

Introduction

These terms and conditions govern your use of the Website(s) and our Mobile Apps (collectively the “Service”); by using the Service, you accept these terms and conditions in full and without reservation. If you disagree with these terms and conditions or any part of these terms and conditions, you must not use the Service.

You must be at least 18 [eighteen] years of age to use the Service. By using the Service and by agreeing to these terms and conditions, you warrant and represent that you are at least 18 years of age.

We encourage users/viewers to share and re-blog all of the material on our Service. You all are welcome to spread and re-post the content wherever you like so long as you give credit and link back the Service. Nonetheless, be careful about copyrighted material, particularly when it belongs to third party Authors and/or Bodies. You must then apply for Author’s permission, and in general, comply with the following requirements provided by the law.

License to use the Service

Unless otherwise stated, the Service and/or its licensors own the intellectual property rights published on the Service and materials used on Service. Subject to the license below, all these intellectual property rights are reserved. Hereinafter, the word Website(s) and/or Service is also used to mean the owner/licensor as well of the Website(s)/Service.

You may view, download for caching purposes only, and print pages, files or other content from the Service for your own personal use, subject to the restrictions set out below and elsewhere in these terms and conditions.

You must not:

Republish material from the Service in neither print nor digital media or documents (including republication on another Website(s)) without author’s permission;

Sell, rent or sub-license material from the Service;

Show any material from the Service in public without author’s permission;

Reproduce, duplicate, copy or otherwise exploit material on the Service for a commercial purpose;

Edit or otherwise modify any material on the Service;

Redistribute material from the Service – except for content specifically and expressly made available for redistribution; or

Republish or reproduce any part of the Service through the use of iframes or screenscrapers.

Where content is specifically made available for redistribution, it may only be redistributed within your organization.

Acceptable use

You must not use the Service in any way that causes, or may cause, damage to the Service or impairment of the availability or accessibility of Service or in any way which is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity.

You must not use the Service to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit or other malicious computer software.

You must not conduct any systematic or automated data collection activities on or in relation to the Service without Service’s owners express written consent.

This includes:

Scraping

Data mining

Data extraction

Data harvesting

‘Framing’ (iframes)

Article ‘Spinning’

You must not use the Service or any part of it to transmit or send unsolicited commercial communications. You are allowed to use the Service for purposes related to marketing if it is meant to be a digital marketing application; however, you must not take possession of someone else’s content without their express written consent.

Restricted access

Access to certain areas of the Service is restricted. The owner/licensor of the Service reserves the right to restrict access to certain areas of the Service, or at our discretion, this entire Service. The owner of the Service may change or modify this policy without notice.

If the Service provides you with a user ID and password to enable you to access restricted areas of the Service or other content or services, you must ensure that the user ID and password are kept confidential. You alone are responsible for your password and user ID security.

The owner of the Service may disable your user ID and password at Service’s owner sole discretion without notice or explanation.

User content (THIS DOES NOT APPLY TO AUTHORS, see Copyright & Authors Policy)

In these terms and conditions, “your user content” means material (including without limitation text, images, audio material, video material and audio-visual material) that you submit to the Service, for whatever purpose.

You grant to the owner of the Service a worldwide, irrevocable, non-exclusive, royalty-free license to use, reproduce, adapt, publish, translate and distribute your user content in any existing or future media. You also grant to the owner of the Service the right to sub-license these rights, and the right to bring an action for infringement of these rights.

Your user content must not be illegal or unlawful, must not infringe any third party’s legal rights, and must not be capable of giving rise to legal action whether against you or the Service or a third party (in each case under any applicable law).

You must not submit any user content to the Service that is or has ever been the subject of any threatened or actual legal proceedings or other similar complaint.

The Service reserves the right to edit or remove any material submitted to the Service, or stored on the servers of the Service, or hosted or published upon the Service.

Service’s rights under these terms and conditions in relation to user content, the Service does not undertake to monitor the submission of such content to, or the publication of such content on, the Service.

Publishing Policy

This policy is valid for all of our platforms, websites mobile applications and services (Service) provided by us. We take legal and ethical requirements very seriously and do not permit to fail to observer these rules. Read this carefully as your account and services, no matter free or paid, will be categorically terminated and you will not be eligible for refund if you do not stick to these rules.

Binding Publishing Rules

DO NOT USE THE SERVICE IF YOU DO NOT COMPLY WITH OUR TERMS AND ENTIRE AGREEMENT, AND/OR YOUR BUSINESS IS INVOLVED IN THE ACTIVITIES MENTIONED HEREINAFTER.

You agree that we do NOT accept content about: erotica, porn, violent, swearwords, drug/alcohol/tobacco-related inciting to use these substances, dating services, non-ethical finance, gambling, illegal content of any type, products/services/practices which harm human life as well as environment and animal wellbeing, illegal products/services/practices, violent, racist, medical products/services/practices which are not recognized and permitted by law, products/services/practices which violate human dignity, as we do not accept any sort of treatment offensive to human life and people’s liberties.

Moreover, we do NOT accept content about any kind of treatments to enhance sexual performance, anabolic steroids and more drugs and pills to alter psychic state, to enhance physical strength and particularly all those treatments that are frequently used in doping in sports.

We do not support racism, and no other content that advocates and/or stir up hatred against individuals, groups or organizations, religions, politics. Satire, in whatever form, when intelligently and proficiently done, does never support vulgarity, hatred, and/or other violent messages. Finally yet importantly, you are strongly recommended not to use material which contains copyright infringement!

As a consequence, it is strictly forbidden to use the Service for posting and/or redirecting to the following content:

Text or images/videos that infringe on any intellectual property rights including, but not limited to copyrights, trademarks and rights of privacy/publicity;

Text or images/videos that result into scams (e.g. Get-rich quick, Phishing email scams, Bank loan or credit card scam, Surfing the web scam, Lottery scam, Romance scams, Fake antivirus software, Hijacked profile scam, Travel scams, Delivery scams, Fake news scam, Stock market and all financial scams, Job offer scams, Smishing etc.);

Text or images/videos that promote untested, unverified, and/or illegal medical therapies and treatments;

Text or images/videos that promote untested, unverified, and/or illegal body and beauty treatments

Text or images/videos that promote products that are injurious to the health (see below our policy for alcohol products etc.);

Text or images/videos of obscenity, pornography or nudity that is not artistic in nature and does not represent an offence against decency and does not damage human dignity and reputation;

Text or images/videos that encourage or glorify drug use/abuse;

Text or images/videos that incite to violence;

All kind of content that is libelous or defamatory;

All kind of content that can reasonably be viewed as harassing, threatening, or otherwise harmful;

All kind of content that results into hate speech;

All kind of content that can reasonably be viewed as discriminatory based upon race, ethnicity, national origin, sexual orientation, or disability;

All kind of content that violates or encourages anyone else to violate any law.

Important notice to all industries in the alcohol business.

We do accept that you publish ads/content about wines, spirits and other alcoholic drinks but you are required to specify that you agree with sensible drinking policies, that alcohol is prohibited to people under the age of 18, and that is strongly unadvisable to make abuse of it.

Important notice for businesses in the financial and health sector.

We do only accept Financial Services (banking, insurance, financial in general) which comply with ethical finance. Before submitting your content in whatever way the Service provides, please make sure your company/services meet this requirement, otherwise it might be deleted and you are not entitled for reimbursement.

Important notice for businesses in the health/beauty/fitness sector.

Health and Medical treatments, Medicaments and Remedies, Beauty and Sport centers, must comply with the law and you are well informed we do NOT accept content that urges to use anabolic steroids, products to enhance sexual performance, doping, etc. If your company/product/service does not meet this requirement, we may delete your submission and you are not entitled for reimbursement. If you do not qualify for the advice you deliver, e.g. you deliver medical advice and you are not a physician, please, forebear, you are not the kind of people we love, and it is filthy unethical and a criminal offence in many countries too.

Important notice to all industries about the publication of photos and videos.

When publishing photos and/or videos on our Service, or by means of our Service, you acknowledge that you have all the rights and permissions to publish those photos and/or videos. By doing so, you state that you have permission to publish the image of people appearing on those photos and/or videos, as well as permission to publish the images of private properties appearing on those photos and/or videos. We cannot be held responsible for your photos and/or videos. Therefore, you are responsible for a model release where personality rights or privacy rights would otherwise be infringed, as well as where the proprietor’s release is needed in case of private properties.

Without limiting any of those representations or warranties, We have the right (though not the obligation) to (i) refuse or remove any content that, in our reasonable opinion, violates any policy or is in any way harmful or objectionable, or (ii) terminate or deny access to and use of the Service to any individual or entity for any reason, in our sole discretion. We will have no obligation to provide a refund of any amounts previously paid under these circumstances.

Responsibility of Website/Service visitors.

By operating the Website/Service, we do not represent or imply that we endorse any or all of the contributed content, or that we believe such material to be accurate, useful or non-harmful. You are responsible for taking precautions as necessary to protect yourself and your computer systems from viruses, worms, trojan horses, and other harmful or destructive content.

Refund Policy (No Refund)

Due to the nature of the digital service provided by the Service no refund is granted. All paid featured are sold “as is.” You assume the responsibility for your purchase, and no refunds will be issued.

However, we realize that exceptional circumstances can take place with regard to the character of the product, Service, we supply/deliver.

Therefore, we DO honor requests for the refund on the following reasons:

a) Major defects: although our system is thoroughly tested, unexpected errors may occur. Such issues must be submitted for our Technical Support Team’s approval. We keep the right to rectify the error or defect within 120 hours. If any deficiency is approved and we fail to correct it within 120 hours from the date of the initial complaint letter or any other notification provided by a Customer, the refund will be issued to the customer in full without any compensations or reimbursements.
b) Product-service not-as-described: such issues should be reported to our Technical Support Department within 7 days from the date of the purchase. Clear evidence must be provided proving that the purchased product-service is not as it is described on the Website/Service. Complaints which are based merely on the customer’s false expectations or wishes are not honored.

Please note that we do not bear any responsibility and therefore we do not satisfy any refund/return/exchange requests based on incompatibility of our products with some third-party software (plug-ins, add-ons, modules, search engines, scripts, extensions etc.) other than those which are specified as compatible on our Website. We don’t guarantee that our product-service are fully compatible with any third-party programs and we do not provide support for third-party applications.

Our Technical Support Team is always eager to assist you and deliver highly professional support in a timely manner. Thank you for relying on our services.

No refund for unfair conduct.

We are not responsible for campaigns and whichever advertising messages made and published by advertisers using our Service. Possible failed promises, disappointment and more dissatisfaction caused by advertisers using the Service can NEVER be attributable to us. Please, check with the advertiser if you think they did not comply with their promises and/or guarantees, as we do NOT take part in such a controversy in any case. However, we urge advertisers to enact fair trading policies to assure customers’/consumers’ rights as we preserve the right to close their account in case of manifest unfairness, not to mention the case of breaking the laws. No refund and no compensation is given. We do NOT accept content that infringes local, state, federal, international laws. At the same time we do NOT accept content that can be considered unethical. If a user publishes content that infringes any law and/or is reasonably considered unethical, we preserve the right to close their account and no refund and no compensation is given in any case. On the contrary, we preserve the right to convene and sue for damages the transgressor.

No warranties

This Service is provided “as is” without any representations or warranties, express or implied. The Service makes no representations or warranties in relation to the Service or the information and materials provided on the Service.

Without prejudice to the generality of the foregoing paragraph, the Service does not warrant that: the Service will be constantly available, or available at all; or the information on the Service is complete, true, accurate or non-misleading.

Nothing on the Service constitutes, or is meant to constitute, advice of any kind. If you require advice in relation to any legal, financial or medical matter you should consult an appropriate professional.

Limitations of liability

The Service will not be liable to you (whether under the law of contact, the law of torts or otherwise) in relation to the contents of, or use of, or otherwise in connection with, the Service:

To the extent that the Service is provided free-of-charge, for any direct loss;

For any indirect, special or consequential loss; or

For any business losses, loss of revenue, income, profits or anticipated savings, loss of contracts or business relationships, loss of reputation or goodwill, or loss or corruption of information or data.

These limitations of liability apply even if the Service has been expressly advised of the potential loss.

Exceptions

Nothing in the Service disclaimer will exclude or limit any warranty implied by law that it would be unlawful to exclude or limit; and nothing in the Service disclaimer will exclude or limit the liability of Sienda Ltd in respect of any:

Death or personal injury caused by the negligence of the Service or its agents, employees or shareholders/owners;

Fraud or fraudulent misrepresentation on the part of the Service; or

Matter which it would be illegal or unlawful for the Service to exclude or limit, or to attempt or purport to exclude or limit, its liability.

Reasonableness

By using the Service, you agree that the exclusions and limitations of liability set out in the Service disclaimer are reasonable.

If you do not think they are reasonable, you must not use the Service.

Other parties

You accept that, as a limited liability entity, the Service has an interest in limiting the personal liability of its officers and employees. You agree that you will not bring any claim personally against the Service’s officers or employees in respect of any losses you suffer in connection with the Service.

Without prejudice to the foregoing paragraph, you agree that the limitations of warranties and liability set out in the Service disclaimer will protect the Service provider officers, employees, agents, subsidiaries, successors, assigns and sub-contractors as well as the Service.

Unenforceable provisions

If any provision of the Service disclaimer is, or is found to be, unenforceable under applicable law, that will not affect the enforceability of the other provisions of the Service disclaimer.

Indemnity

You hereby indemnify the Service and undertake to keep the Service indemnified against any losses, damages, costs, liabilities and expenses (including without limitation legal expenses and any amounts paid by the Service to a third party in settlement of a claim or dispute on the advice of the Service ’s legal advisers) incurred or suffered by the Service arising out of any breach by you of any provision of these terms and conditions, or arising out of any claim that you have breached any provision of these terms and conditions.

Breaches of these terms and conditions

Without prejudice to the Service ’s other rights under these terms and conditions, if you breach these terms and conditions in any way, the Service may take such action as the Service deems appropriate to deal with the breach, including suspending your access to the Service, prohibiting you from accessing the Service, blocking computers using your IP address from accessing the Service, contacting your internet service provider to request that they block your access to the Service and/or bringing court proceedings against you.

Variation

We may revise these terms and conditions from time-to-time. Revised terms and conditions will apply to the use of the Service from the date of the publication of the revised terms and conditions on the Service. Please check this page regularly to ensure you are familiar with the current version.

Assignment

We may transfer, sub-contract or otherwise deal with the Service ’s rights and/or obligations under these terms and conditions without notifying you or obtaining your consent.

You may not transfer, sub-contract or otherwise deal with your rights and/or obligations under these terms and conditions.

Severability

If a provision of these terms and conditions is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. If any unlawful and/or unenforceable provision would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.

Trademarks

Publications, products, content or services referenced herein or on the Service are the exclusive trademarks or servicemarks of the onwer. Other products and company names mentioned in the Service may be the trademarks of their respective owners.

Miscellaneous

This Agreement shall all be governed and construed in accordance with the laws of The United Kingdom applicable to agreements made and to be performed in The United Kingdom. You agree that any legal action or proceeding between the Service and you for any purpose concerning this Agreement or the parties’ obligations hereunder shall be brought exclusively in a federal or state court of competent jurisdiction sitting in The United Kingdom . Any cause of action or claim you may have with respect to the Service must be commenced within one (1) year after the claim or cause of action arises or such claim or cause of action is barred. Our failure to insist upon or enforce strict performance of any provision of this Agreement shall not be construed as a waiver of any provision or right. Neither the course of conduct between the parties nor trade practice shall act to modify any provision of this Agreement. We may assign our rights and duties under this Agreement to any party at any time without notice to you.

Any rights not expressly granted herein are reserved.

Entire agreement

These terms and conditions, together with the Service’s AGREEMENT constitute the entire agreement between you and us in relation to your use of the Service, and supersede all previous agreements in respect of your use of the Service.

Law and jurisdiction

These terms and conditions will be governed by and construed in accordance with the laws of the UNITED KINGDOM, and any disputes relating to these terms and conditions will be subject to the exclusive jurisdiction of the courts of the UNITED KINGDOM.

About these Service Terms of Service

The Service is a trademark by Sienda Ltd, London, UK.

The Owner Service/Website(s)’s details

Please, see above Website owner, Data Controller and Processor

EULA – End User License Agreement

This policy governs all of the Service (website, mobile apps, etc.), so this EULA is considered valid for all of the applications, web and mobile, developed and managed by us and available at this domain (domains and subdomains) and online app stores.

Please read this End-User License Agreement (EULA) carefully before registering/clicking the “I Agree” button, downloading or using the Service (“Application”).

Our applications and platforms (web and mobile) may contain ads.

By registering/clicking the “I Agree” button, downloading or using the Application, you are agreeing to be bound by the terms and conditions of this Agreement.

This Agreement is a legal agreement between you (either an individual or a single entity) and us and it governs your use of the Application made available to you by Sienda ltd.

If you do not agree to the terms of this Agreement, do not register/click on the “I Agree” button and do not download or use the Application.

The Application is licensed, not sold, to you for use strictly in accordance with the terms of this Agreement and the entire User Agreement (AGREEMENT).

Users are not permitted to sell, transmit, host or otherwise commercially exploit the Application;

Copy or use the Application for any other purposes except for those expressed in the User Agreement (AGREEMENT);

Modify, decrypt, reverse compile or reverse engineer the Application.

The Application, its contents, and its trademarks are Sienda ltd’s exclusive intellectual property.

We may regularly update the application with new features, bug fixes etc. as needed.

You are warned that we may collect certain personal information from users, e.g. name, email, address, location, etc.

The Application is provided on an “AS IS” and “AS AVAILABLE” basis

License

We grant you a revocable, non-exclusive, non-transferable, limited license to download, install and use the Application solely for your personal, non-commercial purposes strictly in accordance with the terms of this Agreement.

Third-Party Services

The Application may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services (“Third-Party Services”).

You acknowledge and agree that the Application shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. We do not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.

Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties’ terms and conditions.

Term and Termination

This Agreement shall remain in effect until terminated by you or Sienda ltd.

Sienda ltd may, in its sole discretion, at any time and for any or no reason, suspend or terminate this Agreement with or without prior notice.

This Agreement will terminate immediately, without prior notice from us, in the event that you fail to comply with any provision of this Agreement. You may also terminate this Agreement by deleting the Application and all copies thereof from your mobile device or from your computer.

Upon termination of this Agreement, you shall cease all use of the Application and delete all copies of the Application from your mobile device or from your computer.

Termination of this Agreement will not limit any of our rights or remedies at law or in equity in case of breach by you (during the term of this Agreement) of any of your obligations under the present Agreement.

Amendments to this Agreement

Sienda ltd reserves the right, at its sole discretion, to modify or replace this Agreement at any time. If a revision is material, we will provide at least 15 days’ notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.

By continuing to access or use our Application after any revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, you are no longer authorized to use the Application.

Governing Law

The laws of United Kingdom, excluding its conflicts of law rules, shall govern this Agreement and your use of the Application. Your use of the Application may also be subject to other local, state, national, or international laws.

Contact Information

If you have any questions about this Agreement, please contact us. See above “Website owner, Data Controller and Processor”

Entire Agreement

This EULA is part of the User Agreement (AGREEMENT) that constitutes the entire agreement between you and Sienda ltd regarding your use of the Application and supersedes all prior and contemporaneous written or oral agreements between you and Sienda ltd.

You may be subject to additional terms and conditions that apply when you use or purchase other Sienda ltd’s services, which we will provide to you at the time of such use or purchase.

COPYRIGHT POLICY

This document is part of the User Agreement (AGREEMENT) that includes all of the rules for this Service. If you keep navigating and/or using the Service, you are accepting our AGREEMENT. So, read carefully, as you are requested to confirm you know and agree with these Policies when using this platform and its related applications and websites. Since you are definitely free to disagree, please, abandon this website and disconnect from all of its applications.

Applicable Law

Copyright infringement and Copyright Policy (Digital Economy Act 2010 and related legislation (Copyright, Designs and Patents Act 1988, Communications Act 2003, Video Recordings Act 1984)

As we ask others to respect our intellectual property rights, we respect the intellectual property rights of others. If you believe that material located on or linked to by the Service violates your copyright, you are encouraged to notify us in accordance with common DEA2010 policies. We will respond to all such notices, including as required or appropriate by removing the infringing material or disabling all links to the infringing material. In the case of a user who may infringe or repeatedly infringes the copyrights or other intellectual property rights of us or others, Sienda ltd may, in its discretion, terminate or deny access to and use of the Website. In the case of such termination, Sienda ltd will have no obligation to provide a refund of any amounts previously paid to us.

Content Protection.

All images/content on the Service are: 1) created by our team; 2) submitted by users; 3) submitted by companies/businesses from our network and/or our customers; 4) Authors registered on Website(s)/Service; 5) readily available in various places on the Internet and believed to be in public domain.

When we publish copyrighted material on the Service, we indicate sources and links if possible; thus, for all copyright issues, get in touch with us, please see above “Website owner, Data Controller and Processor.”

All content posted at the Service is property of their own lawful proprietors.

About Authors.

Authors are those who are registered at the Service and can create, edit, publish, and delete their own posts, as well as upload files and images. Authors are held responsible for what they upload, post and publish on the Service. Publishers and Advertisers that use our Service to create and publish their ad campaigns are considered Authors.

We are not responsible for infringements by Authors/Publishers/Advertisers. However, we are committed to avoiding these practices and we do our best to delete improper material.

Content submitted at the Service by Authors registered at our websites/applications, remains exclusive property of the Authors and/or creators and/or lawful proprietors. In no case, Sienda ltd, publisher of the Service, is considered proprietor of the content submitted by Authors as above explained.

Content posted is believed to be posted within our rights according to the U.K. Copyright Act. Here’s details for further information

Fact sheet P-27: Using copyright works fact sheet from the UK Copyright Service.

So then, if you believe that any content appearing on WEBSITE infringes on your copyright, please let us know. Contact us for copyright issues, please, see above “Website owner, Data Controller and Processor.” Email the following information to us and the infringing material will be removed as soon as possible:

(a) Your name, address, telephone number, and e-mail address;

(b) A description of the copyrighted work that you claim has been infringed;

(d) A statement by you that you have a good faith belief that the disputed use has not been authorized by you, your agent, or the law;

(e) Your electronic or physical signature or the electronic or physical signature of the person authorized to act on your behalf; and

(f) A statement by you made under penalty of perjury, that the information in your notice is accurate, that you are the copyright owner or authorized to act on the copyright owner’s behalf

Please, be informed that according to the Copyright Act any person who knowingly materially misrepresents that material or activity is infringing may be subject to liability.

NO-SPAM POLICY

Spam is any commercial email sent without the recipient’s permission. Commercial email is defined as any electronic mail message whose primary purpose is the commercial advertisement or promotion of a product or service. The Service is intended to be used for the sole and exclusive purpose of sending messages to recipients who have agreed and confirmed to receive such messages from you. This is called Permission-based (Email) Marketing. No other use is acceptable and permitted at this Service.

We do not spam, so you will never receive harassment from us.

The emails we send are intended for improving your performance at our Service and in order to communicate important news about changes and enhancements. We may send e-mail advertising to inform about new products and services of ours or from our business partners; however, you, the receiver, can unsubscribe at any time.

We also send emails when you register to the Service, request a password change, etc.

Likewise, we send emails to inform you about developments, legal terms, contracts, newsletters (e.g., as a subscriber of one of our blogs or other services) and everything we consider important in order to improve our Service, make your experience better, and comply with legal requirements.

You are informed about your rights and the way we process your information. See above Privacy Notice and Policy.

Recommendations, rules, and restrictions.

You may never send SPAM by using the Service.

Your account may be immediately suspended or terminated if you send SPAM. We are fully committed to the suppression of SPAM. You are not eligible for reimbursement if your account is suspended and/or terminated for SPAM practices, as you are not for breaching other rules of our User Agreement (AGREEMENT).

We recommend our users to always act ethically and never violate the law.

Although many of these practices cannot be done by using the Service, as we do our best to prevent such unethical and illicit behavior, we like our customers to be correct and fair, and so we invite you not to:

a) Harvest emails from web sites
b) Purchase or rent lists (whether they are opt-in or not)
c) Perform email appending
d) Send messages that are unrelated to what subscribers signed up to receive from you
e) Add an email address into a list without the subscriber’s permission
f) Email someone who has requested to be removed from your list
g) Send messages that violate Anti-SPAM Laws

Conversely, an appropriate conduct is to:

Send a commercial message to a recipient who has double opted-in (or confirmed opted-in) to receive it.

Send a commercial message to a recipient who has single opted-in to receive it, although we strongly discourage the use of single opt-in, strongly encourage the use of double opt-in (confirmed opt-in).

Send any other communication that has been specifically requested by those who receive it, or that is transactional in nature, such as a password reminder or an order confirmation.

No refunds

In the event that your account is terminated due to violation of this Anti Spam Policy, you will not be refunded any amounts that have been paid towards the use of the Service.

Reporting SPAM

If you are a recipient of SPAM, and believe that such SPAM is being sent through the Service, do not hesitate to contact us, see above Website owner, Data Controller and Processor.

Please copy the sender of the message in your compliant. You may describe the incident by simply attaching or forwarding the message at issue, including the message header.

Applicable Law.

In compliance with UK 2008 No. 1276 – The Business Protection from Misleading Marketing Regulations 2008, the Data Protection Act 2018 up to date with all changes, and other National and International applicable laws.

Moreover, as a user of our Service, you are informed that Your use of the Marketing Tools provided by the Service must comply with all applicable domestic and international laws. This includes the laws applicable to you and also laws applicable to Sienda ltd and all recipients/audience to whom you intend to send advertisements and promotional messages through the web including emails (each a “Recipient”). Examples of applicable laws include laws relating to spam or unsolicited commercial email (hereinafter “Spam” or “UCE”), privacy, security, obscenity, defamation, intellectual property, pornography, terrorism, homeland security, gambling, child protection, and other applicable laws. It is your responsibility to know and understand the laws applicable to your use of the services provided by Sienda ltd, (the Service) and the ads/landing pages/emails/etc. you generate and send through our Service. Your use of the Service must also comply with our entire agreement (AGREEMENT). You are advised to read the Privacy Policy and this entire AGREEMENT, and to use the information it contains to help you make informed decisions.

Please, remember that:

You are solely responsible for your products and services and any other promotion and Content contained in or referred to in your promotions/advertisements/landing pages and messages sent through and/or shown through the Service. You agree to use the Service in a lawful, safe, and professional manner, consistent with industry best practices, including keeping reliable records. You are solely responsible for any and all statements you make and for all user assistance, warranty and support of your products and services.

AD DISCLOSURE

Affiliate links.

Our websites and applications (Service) may contain affiliate links. This means that we receive compensations from some companies whose products and services we review. Not all the products and services we review are from affiliates, but some are. We test products and services thoroughly and give high marks to only the very best. We are independently owned and the opinions expressed in our websites and applications are our own. When you click on an affiliate link and complete a purchase, we get a small part of your purchase at no extra cost for you.

Ads

This Service is a sponsored Service created or supported by a company, organization or group of organizations. For questions about the Service, please contact us, see above “Website owner, Data Controller and Processor.”

This Service accepts forms of cash advertising, sponsorship, paid insertions or other forms of compensation.

The compensation received will never influence the content, topics or posts made in the Service. All advertising is in the form of advertisements generated by a third party ad network. Those advertisements will be identified as paid advertisements.

We also provide opinion on products, services, websites, apps and various other topics without compensation. The views and opinions expressed on this Service are purely ours. If we claim or appear to be experts on a certain topic or product or service area, we will only endorse products or services that we believe, based on our expertise, are worthy of such endorsement. Any product claim, statistic, quote or other representation about a product or service should be verified with the manufacturer or provider.

This Service can contain content which might present a conflict of interest. This content may not always be identified.

FORUM GUIDELINES

This Policy applies to the comments on the page and forums managed by Sienda ltd at our blogs, websites, applications and more services, including social platforms, e.g. Facebook and others.

Keep it civil aka don’t be a jerk.

We’re going to get into the thick of a lot of heated discussions and that’s okay. However, in order for discussions to thrive here, we need to remember to criticize ideas, not people.

So, remember to avoid:

name-calling

ad hominem attacks

Responding to a post’s tone instead of its actual content.

knee-jerk contradiction

Comments that we find to be hateful, inflammatory, or harassing may be removed. If you don’t have something nice to say about another user, don’t say it. Treat others the way you’d like to be treated.

Always strive to add value to every interaction and discussion you participate in.

If you are not sure your post adds to the conversation, think over what you want to say and try again later.

Keep it tidy

Help make moderators’ lives easier by taking a moment to ensure that what you’re about to post is in the right place. That means:

don’t post off-topic comments or discussions: check other websites to find the appropriate channel for your topic

don’t cross-post the same thing multiple times;

review any specific posting guidelines for the community;

check if another active discussion on your topic has already been posted;

If you see something, say something.

Moderators are at the forefront of combatting spam, mediating disputes and enforcing community guidelines and, so are you.

If you see an issue, contact the moderators if possible or flag any comments for review. If you believe someone has violated the Basic Rules, report it to us.

Stay On-topic

Be sure your topic matches the theme of this website and the post you are commenting.

No Self-promotion

A discussion or comment that contains only a link to your blog, a product, or your article on another site will almost always be removed.

Choose Your (Curse) Words Wisely

Comments that contain profanity are automatically held for moderator review before being posted. Depending on the context of the comment, it may be removed. Profanity used to insult, antagonize, or inflame will always be removed.

Don’t Copy and Paste

If you didn’t write it, or haven’t properly cited the article you’re quoting, don’t post it.

English Only

We currently only support English-only discussions. Non-English comments and discussions will be removed.

Last updated October 23, 2020