Last updated on April 9, 2019.<\/p>\n\n\n\n
1.1 We are\ncommitted to safeguarding the privacy of our website visitors.<\/p>\n\n\n\n
1.2 This policy\napplies where we are acting as a data controller with respect to the personal\ndata of our website visitors; in other words, where we determine the purposes\nand means of the processing of that personal data.<\/p>\n\n\n\n
1.4 In this\npolicy, “we”, “us” and “our” refer to Moderno\nStrategies.<\/p>\n\n\n\n
1.3 We use\ncookies on our website. Insofar as those cookies are not strictly necessary for\nthe provision of our website, we will ask you to consent to our use of cookies\nwhen you first visit our website.<\/p>\n\n\n\n
2.1 This document\nwas created using a template from SEQ Legal (https:\/\/www.contractology.com\/website-privacy-policy.html<\/a>).<\/p>\n\n\n\n 3.1 In this\nSection 3 we have set out:<\/p>\n\n\n\n (a) the general\ncategories of personal data that we may process;<\/p>\n\n\n\n (b) in the case\nof personal data that we did not obtain directly from you, the source and\nspecific categories of that data;<\/p>\n\n\n\n (c) the purposes\nfor which we may process personal data; and<\/p>\n\n\n\n (d) the legal\nbases of the processing.<\/p>\n\n\n\n 3.2 We may\nprocess data about your use of our website (“usage data<\/strong>“). The\nusage data may include your IP address, geographical location, browser type and\nversion, operating system, referral source, length of visit, page views and\nwebsite navigation paths, as well as information about the timing, frequency\nand pattern of your use. The source of the usage data is our analytics tracking\nsystems. This usage data may be processed for the purposes of analysing the use\nof the website. The legal basis for this processing is our legitimate\ninterests, namely monitoring and improving our website and services.<\/p>\n\n\n\n 3.3 We may\nprocess your account data (“account data<\/strong>“). The account data\nmay include your name and email address. The source of the account data is you.\nThe account data may be processed for the purposes of operating our website,\nproviding our services, ensuring the security of our website and services,\nmaintaining back-ups of our databases and communicating with you. The legal\nbasis for this processing is our legitimate interests, namely the proper\nadministration of our website and business.<\/p>\n\n\n\n 3.4 We may\nprocess your information included in your personal profile on our website\n(“profile data<\/strong>“). The profile data may include your name,\naddress, telephone number, email address, profile pictures, gender, date of\nbirth, relationship status, interests and hobbies, educational details and\nemployment details. The profile data may be processed for the purposes of\nenabling and monitoring your use of our website and services. The legal basis\nfor this processing is our legitimate interests, namely the proper\nadministration of our website and business.<\/p>\n\n\n\n 3.5 We may\nprocess information that you post for publication on our website or through our\nservices (“publication data<\/strong>“). The publication data may be\nprocessed for the purposes of enabling such publication and administering our\nwebsite and services. The legal basis for this processing is our legitimate\ninterests, namely the proper administration of our website and business.<\/p>\n\n\n\n 3.6 We may\nprocess information contained in any enquiry you submit to us regarding goods\nand\/or services (“enquiry data<\/strong>“). The enquiry data may be\nprocessed for the purposes of offering, marketing and selling relevant goods\nand\/or services to you. The legal basis for this processing is our legitimate\ninterests, namely the proper administration of our website and business.<\/p>\n\n\n\n 3.7 We may\nprocess information relating to our customer relationships, including customer\ncontact information (“customer relationship data<\/strong>“). The\ncustomer relationship data may include your name, your employer, your job title\nor role, your contact details, and information contained in communications\nbetween us and you or your employer. The source of the customer relationship\ndata is you or your employer. The customer relationship data may be processed for\nthe purposes of managing our relationships with customers, communicating with\ncustomers, keeping records of those communications and promoting our products\nand services to customers. The legal basis for this processing is our\nlegitimate interests, namely the proper management of our customer relationships.<\/p>\n\n\n\n 3.8 We may\nprocess information relating to transactions, including purchases of goods and\nservices, that you enter into with us and\/or through our website (“transaction\ndata<\/strong>“). The transaction data may include your contact details, your\ncard details and the transaction details. The source of the transaction data is\nyou and\/or our payment services provider. The transaction data may be processed\nfor the purpose of supplying the purchased goods and services and keeping\nproper records of those transactions. The legal basis for this processing is the\nperformance of a contract between you and us and\/or taking steps, at your\nrequest, to enter into such a contract and our legitimate interests, namely the\nproper administration of our website and business.<\/p>\n\n\n\n 3.9 We may\nprocess information that you provide to us for the purpose of subscribing to\nour email notifications and\/or newsletters (“notification data<\/strong>“).\nThe notification data may be processed for the purposes of sending you the\nrelevant notifications and\/or newsletters. The legal basis for this processing\nis our legitimate interests, namely the proper administration of our website\nand business.<\/p>\n\n\n\n 3.10 We may process\ninformation contained in or relating to any communication that you send to us\n(“correspondence data<\/strong>“). The correspondence data may include the\ncommunication content and metadata associated with the communication. Our\nwebsite will generate the metadata associated with communications made using\nthe website contact forms. The correspondence data may be processed for the\npurposes of communicating with you and record-keeping. The legal basis for this\nprocessing is our legitimate interests, namely the proper administration of our\nwebsite and business and communications with users.<\/p>\n\n\n\n 3.11 We may process\nwebsite activity data. This data may include your name, employer, contact\ninformation, pages visited, time on the website, resource downloads, and any\nother information you may provide. The source of this data is you and other\ndata service providers we work with. This data may be processed for determining\nwebsite effectiveness, your buyer stage, and the type of information you are\nviewing or inquiring. The legal basis for this processing is our legitimate\ninterests, namely the proper administration of our website and business and\ncommunications with users.<\/p>\n\n\n\n 3.12 We may process\nany of your personal data identified in this policy where necessary for the\nestablishment, exercise or defence of legal claims, whether in court\nproceedings or in an administrative or out-of-court procedure. The legal basis\nfor this processing is our legitimate interests, namely the protection and\nassertion of our legal rights, your legal rights and the legal rights of others.<\/p>\n\n\n\n 3.13 We may process\nany of your personal data identified in this policy where necessary for the\npurposes of obtaining or maintaining insurance coverage, managing risks, or\nobtaining professional advice. The legal basis for this processing is our\nlegitimate interests, namely the proper protection of our business against\nrisks.<\/p>\n\n\n\n 3.14 In addition to\nthe specific purposes for which we may process your personal data set out in\nthis Section 3, we may also process any of your personal data where such\nprocessing is necessary for compliance with a legal obligation to which we are\nsubject, or in order to protect your vital interests or the vital interests of\nanother natural person.<\/p>\n\n\n\n 3.15 Please do not\nsupply any other person’s personal data to us, unless we prompt you to do so.<\/p>\n\n\n\n 4.1 We may\ndisclose your personal data to our insurers and\/or professional advisers\ninsofar as reasonably necessary for the purposes of obtaining or maintaining\ninsurance coverage, managing risks, obtaining professional advice, or the\nestablishment, exercise or defence of legal claims, whether in court\nproceedings or in an administrative or out-of-court procedure.<\/p>\n\n\n\n 4.3 We may disclose\ncollected personal data to our suppliers or subcontractors, insofar as\nreasonably necessary for our legitimate interests, namely the proper\nadministration of our website and business and communications with users.<\/p>\n\n\n\n 4.4 Financial\ntransactions relating to our website and services may be handled by our payment\nservices providers. We will share transaction data with our payment services\nproviders only to the extent necessary for the purposes of processing your\npayments, refunding such payments and dealing with complaints and queries\nrelating to such payments and refunds..<\/p>\n\n\n\n 4.5 In addition\nto the specific disclosures of personal data set out in this Section 4, we may\ndisclose your personal data where such disclosure is necessary for compliance\nwith a legal obligation to which we are subject, or in order to protect your\nvital interests or the vital interests of another natural person. We may also\ndisclose your personal data where such disclosure is necessary for the\nestablishment, exercise or defence of legal claims, whether in court\nproceedings or in an administrative or out-of-court procedure.<\/p>\n\n\n\n 5.1 In this\nSection 5, we provide information about the circumstances in which your\npersonal data may be transferred to countries outside the United States of\nAmerica.<\/p>\n\n\n\n 5.2 We and our\nother group companies have offices and facilities in the United States of\nAmerica.<\/p>\n\n\n\n 5.3 The hosting\nfacilities for our website are situated in the United States of America.<\/p>\n\n\n\n 5.4 You\nacknowledge that personal data that you submit for publication through our\nwebsite or services may be available, via the internet, around the world. We\ncannot prevent the use (or misuse) of such personal data by others.<\/p>\n\n\n\n 6.1 This Section\n6 sets out our data retention policies and procedure, which are designed to\nhelp ensure that we comply with our legal obligations in relation to the\nretention and deletion of personal data.<\/p>\n\n\n\n 6.2 Personal data\nthat we process for any purpose or purposes shall not be kept for longer than\nis necessary for that purpose or those purposes.<\/p>\n\n\n\n 6.3 We may retain\nyour personal data while we are still an operating business.<\/p>\n\n\n\n 6.5 Notwithstanding\nthe other provisions of this Section 6, we may retain your personal data where\nsuch retention is necessary for compliance with a legal obligation to which we\nare subject, or in order to protect your vital interests or the vital interests\nof another natural person.<\/p>\n\n\n\n 7.1 We may update\nthis policy from time to time by publishing a new version on our website.<\/p>\n\n\n\n 7.2 You should\ncheck this page occasionally to ensure you are happy with any changes to this\npolicy.<\/p>\n\n\n\n 7.3 We may notify\nyou of significant changes to this policy by email or through the private\nmessaging system on our website.<\/p>\n\n\n\n 8.1 In this\nSection 8, we have summarised the rights that you have under data protection law.\nSome of the rights are complex, and not all of the details have been included\nin our summaries. Accordingly, you should read the relevant laws and guidance\nfrom the regulatory authorities for a full explanation of these rights.<\/p>\n\n\n\n 8.2 Your\nprincipal rights under data protection law are:<\/p>\n\n\n\n (a) the right to\naccess;<\/p>\n\n\n\n (b) the right to\nrectification;<\/p>\n\n\n\n (c) the right to\nerasure;<\/p>\n\n\n\n (d) the right to\nrestrict processing;<\/p>\n\n\n\n (e) the right to\nobject to processing;<\/p>\n\n\n\n (f) the right to\ndata portability;<\/p>\n\n\n\n (g) the right to\ncomplain to a supervisory authority; and<\/p>\n\n\n\n (h) the right to\nwithdraw consent.<\/p>\n\n\n\n 8.3 You have the\nright to confirmation as to whether or not we process your personal data and,\nwhere we do, access to the personal data, together with certain additional\ninformation. That additional information includes details of the purposes of\nthe processing, the categories of personal data concerned and the recipients of\nthe personal data. Providing the rights and freedoms of others are not\naffected, we will supply to you a copy of your personal data. The first copy\nwill be provided free of charge, but additional copies may be subject to a\nreasonable fee. You can request a report of your personal data by contacting\nthe data protection officer listed at the end of this policy.<\/p>\n\n\n\n 8.4 You have the\nright to have any inaccurate personal data about you rectified and, taking into\naccount the purposes of the processing, to have any incomplete personal data\nabout you completed.<\/p>\n\n\n\n 8.5 In some\ncircumstances you have the right to the erasure of your personal data without\nundue delay. Those circumstances include: the personal data are no longer\nnecessary in relation to the purposes for which they were collected or\notherwise processed; you withdraw consent to consent-based processing; you\nobject to the processing under certain rules of applicable data protection law;\nthe processing is for direct marketing purposes; and the personal data have\nbeen unlawfully processed. However, there are exclusions of the right to\nerasure. The general exclusions include where processing is necessary: for\nexercising the right of freedom of expression and information; for compliance\nwith a legal obligation; or for the establishment, exercise or defence of legal\nclaims.<\/p>\n\n\n\n 8.6 In some\ncircumstances you have the right to restrict the processing of your personal\ndata. Those circumstances are: you contest the accuracy of the personal data;\nprocessing is unlawful but you oppose erasure; we no longer need the personal\ndata for the purposes of our processing, but you require personal data for the\nestablishment, exercise or defence of legal claims; and you have objected to\nprocessing, pending the verification of that objection. Where processing has\nbeen restricted on this basis, we may continue to store your personal data.\nHowever, we will only otherwise process it: with your consent; for the\nestablishment, exercise or defence of legal claims; for the protection of the\nrights of another natural or legal person; or for reasons of important public\ninterest.<\/p>\n\n\n\n 8.7 You have the\nright to object to our processing of your personal data on grounds relating to\nyour particular situation, but only to the extent that the legal basis for the\nprocessing is that the processing is necessary for: the performance of a task\ncarried out in the public interest or in the exercise of any official authority\nvested in us; or the purposes of the legitimate interests pursued by us or by a\nthird party. If you make such an objection, we will cease to process the personal\ninformation unless we can demonstrate compelling legitimate grounds for the\nprocessing which override your interests, rights and freedoms, or the\nprocessing is for the establishment, exercise or defence of legal claims.<\/p>\n\n\n\n 8.8 You have the\nright to object to our processing of your personal data for direct marketing\npurposes (including profiling for direct marketing purposes). If you make such\nan objection, we will cease to process your personal data for this purpose.<\/p>\n\n\n\n 8.9 You have the\nright to object to our processing of your personal data for scientific or\nhistorical research purposes or statistical purposes on grounds relating to\nyour particular situation, unless the processing is necessary for the\nperformance of a task carried out for reasons of public interest.<\/p>\n\n\n\n 8.10 To the extent\nthat the legal basis for our processing of your personal data is:<\/p>\n\n\n\n (a) consent; or<\/p>\n\n\n\n (b) that the\nprocessing is necessary for the performance of a contract to which you are\nparty or in order to take steps at your request prior to entering into a\ncontract,<\/p>\n\n\n\n and such\nprocessing is carried out by automated means, you have the right to receive your\npersonal data from us in a structured, commonly used and machine-readable\nformat. However, this right does not apply where it would adversely affect the\nrights and freedoms of others.<\/p>\n\n\n\n 8.11 If you\nconsider that our processing of your personal information infringes data\nprotection laws, you have a legal right to lodge a complaint with a supervisory\nauthority responsible for data protection. You may do so in the EU member state\nof your habitual residence, your place of work or the place of the alleged infringement.<\/p>\n\n\n\n 8.12 To the extent\nthat the legal basis for our processing of your personal information is\nconsent, you have the right to withdraw that consent at any time. Withdrawal\nwill not affect the lawfulness of processing before the withdrawal.<\/p>\n\n\n\n 8.13 You may\nexercise any of your rights in relation to your personal data by written notice\nto us, in addition to the other methods specified in this Section 8.<\/p>\n\n\n\n 9.1 A cookie is a\nfile containing an identifier (a string of letters and numbers) that is sent by\na web server to a web browser and is stored by the browser. The identifier is\nthen sent back to the server each time the browser requests a page from the\nserver.<\/p>\n\n\n\n 9.2 Cookies may\nbe either “persistent” cookies or “session” cookies: a\npersistent cookie will be stored by a web browser and will remain valid until\nits set expiry date, unless deleted by the user before the expiry date; a\nsession cookie, on the other hand, will expire at the end of the user session,\nwhen the web browser is closed.<\/p>\n\n\n\n 9.3 Cookies do\nnot typically contain any information that personally identifies a user, but\npersonal information that we store about you may be linked to the information\nstored in and obtained from cookies.<\/p>\n\n\n\n 10.1 We use cookies\nfor the following purposes:<\/p>\n\n\n\n (a) authentication\n– we use cookies to identify you when you visit our website and as you navigate\nour website;<\/p>\n\n\n\n (b) status – we\nuse cookies to help us to determine if you are logged into our website;<\/p>\n\n\n\n (c) personalization\n– we use cookies to store information about your preferences and to personalize\nthe website for you;<\/p>\n\n\n\n (d) security – we\nuse cookies as an element of the security measures used to protect user\naccounts, including preventing fraudulent use of login credentials, and to\nprotect our website and services generally;<\/p>\n\n\n\n (e) advertising –\nwe use cookies to help us to display advertisements that will be relevant to\nyou;<\/p>\n\n\n\n (f) analysis –\nwe use cookies to help us to analyze the use and performance of our website;\nand<\/p>\n\n\n\n (g) cookie\nconsent – we use cookies to store your preferences in relation to the use of\ncookies more generally.<\/p>\n\n\n\n 11.1 Our service\nproviders use cookies and those cookies may be stored on your computer when you\nvisit our website.<\/p>\n\n\n\n 11.2 We use Google\nAnalytics to analyse the use of our website. Google Analytics gathers\ninformation about website use by means of cookies. The information gathered\nrelating to our website is used to create reports about the use of our website.\nGoogle’s privacy policy is available at: https:\/\/policies.google.com\/privacy<\/a>.<\/p>\n\n\n\n 12.1 Most browsers\nallow you to refuse to accept cookies and to delete cookies. The methods for\ndoing so vary from browser to browser, and from version to version. You can\nhowever obtain up-to-date information about blocking and deleting cookies via\nthese links:<\/p>\n\n\n\n (a) https:\/\/support.google.com\/chrome\/answer\/95647<\/a>\n(Chrome);<\/p>\n\n\n\n (b) https:\/\/support.mozilla.org\/en-US\/kb\/enable-and-disable-cookies-website-preferences<\/a>\n(Firefox);<\/p>\n\n\n\n (c) https:\/\/www.opera.com\/help\/tutorials\/security\/cookies\/<\/a>\n(Opera);<\/p>\n\n\n\n (d) https:\/\/support.microsoft.com\/en-gb\/help\/17442\/windows-internet-explorer-delete-manage-cookies<\/a>\n(Internet Explorer);<\/p>\n\n\n\n (e) https:\/\/support.apple.com\/kb\/PH21411<\/a>\n(Safari); and<\/p>\n\n\n\n3. How we use your personal data<\/h3>\n\n\n\n
4. Providing your personal data to others<\/h3>\n\n\n\n
5. International transfers of your personal data<\/h3>\n\n\n\n
6. Retaining and deleting personal data<\/h3>\n\n\n\n
7. Amendments<\/h3>\n\n\n\n
8. Your rights<\/h3>\n\n\n\n
9. About cookies<\/h3>\n\n\n\n
10. Cookies that we use<\/h3>\n\n\n\n
11. Cookies used by our service providers<\/h3>\n\n\n\n
12. Managing cookies<\/h3>\n\n\n\n