1.
Introduction
1.1 We are committed to safeguarding the privacy
of our visitors and service users.
1.2 This policy applies where we are acting as a
data controller with respect to the personal data of grantbestoffer.com
visitors and service users; in other words, where we determine the purposes and means of the processing
of that personal
data.
1.3 We use cookies on our website. Insofar as
those cookies are not strictly necessary for the provision
of our website and services, we will ask you to consent to our use of cookies when you first visit our
website.
1.4 Our website incorporates privacy controls
which affect how we will process your personal data. By using
the privacy controls, you can choose whether to provide any personal details such as name, email and
phone number or
to avoid signing up on our database.
1.5 In this policy, “we”, “us” and “our” refer to
grantbestoffer.com. [For more information about us, see
Section 13.]
2.
Credit
3.
How we use your personal data
3.1 In this Section 3 we have set out:
(a) The general categories of personal data that
we may process;
(b) In the case of personal data that we did not
obtain directly from you, the source and specific categories
of that data;
(c) The purposes for which we may process personal
data; and
(d) The legal bases of the processing.
3.2 We may process data about your use of our
website and services (”
usage data“). The usage data may include your IP address, geographical location,
browser type and version, operating
system, referral source, length of visit, page views and website navigation paths, as well as
information about the timing,
frequency and pattern of your service use. The source of the usage data is Facebook, GetClicky,
SendPulse, PushCrew,
Aweber or Google Analytics. This usage data may be processed for the purposes of analysing the use of
the website and
services. The legal basis for this processing is our legitimate interests, namely monitoring and
improving our website
and services.
3.3 We may process your account data (”
account data“). The account data may include your name, phone number and email address.
The source of the account
data is you. The account data may be processed for the purposes of operating our website, providing our
services, ensuring
the security of our website and services, maintaining back-ups of our databases and communicating with
you. The legal
basis for this processing is our legitimate interests, namely the proper administration of our website
and business.
3.4 We may process your information included in
your personal profile on our website (”
profile data“). The profile data may include your name, address, telephone number,
email address, profile pictures,
gender and date of birth. The profile data may be processed for the purposes of enabling and monitoring
your use of our
website and services. The legal basis for this processing is our legitimate interests, namely the proper
administration
of our website and business.
3.5 We may process your personal data that are
provided in the course of the use of our services (”
service data“). The service data may include your name, address, telephone number,
email address, profile pictures,
gender and date of birth .The source of the service data is you. The service data may be processed for
the purposes of
operating our website, providing our services, ensuring the security of our website and services,
maintaining back-ups
of our databases and communicating with you. The legal basis for this processing is our legitimate
interests, namely
the proper administration of our website and business.
3.6 We may process information that you post for
publication on our website or through our services (”
publication data“). The publication data may be processed for the purposes of enabling
such publication and
administering our website and services. The legal basis for this processing is our legitimate interests,
namely the proper
administration of our website and business.
3.7 We may process information contained in any
enquiry you submit to us regarding goods and/or services
(”
enquiry data“). The enquiry data may be processed for the purposes of offering,
marketing and selling relevant
goods and/or services to you. The legal basis for this processing is our legitimate interests, namely
the proper administration
of our website and business. .
3.8 We may process information relating to our
customer relationships, including customer contact information
(”
customer relationship data“). The customer relationship data may include your name,
your contact details, and
information contained in communications between us. The source of the customer relationship data is you.
The customer
relationship data may be processed for the purposes of managing our relationships with customers,
communicating with
customers, keeping records of those communications and promoting our products and services to customers.
The legal basis
for this processing is our legitimate interests, namely the proper management of our customer
relationships.
3.9 We may process information relating to
transactions, including purchases of goods and services, that
you enter into with us and/or through our website (”
transaction data“). The transaction data may include your name, your contact details
and the transaction details.
The transaction data may be processed for the purpose of supplying the purchased goods and services and
keeping proper
records of those transactions. The legal basis for this processing is the performance of a contract
between you and us
and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely
the proper administration
of our website and business.
3.10 We may process information that you provide to us for the
purpose of subscribing to our email notifications and/or
newsletters (”
notification data“). The notification data may be processed for the purposes of sending
you the relevant notifications
and/or newsletters. The legal basis for this processing is consent.
3.11 We may process information contained in or relating to
any communication that you send to us (”
correspondence data“). The correspondence data may include the communication content
and metadata associated
with the communication. Our website will generate the metadata associated with communications made using
the website
contact forms. The correspondence data may be processed for the purposes of communicating with you and
record-keeping.
The legal basis for this processing is our legitimate interests, namely the proper administration of our
website and
business and communications with users.
3.12 We may process any of your personal data identified in
this policy where necessary for the establishment, exercise
or defence of legal claims, whether in court proceedings or in an administrative or out-of-court
procedure. The legal
basis for this processing is our legitimate interests, namely the protection and assertion of our legal
rights, your
legal rights and the legal rights of others.
3.14 We may process any of your personal data identified in
this policy where necessary for the purposes of obtaining
or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for
this processing
is our legitimate interests, namely the proper protection of our business against risks.
3.15 In addition to the specific purposes for which we may
process your personal data set out in this Section 3, we
may also process any of your personal data where such processing is necessary for compliance with a
legal obligation
to which we are subject, or in order to protect your vital interests or the vital interests of another
natural person.
3.16 Please do not supply any other person’s personal data to
us, unless we prompt you to do so.
4.
Providing your personal data to
others
4.1 We may disclose your personal data to our
insurers and/or professional advisers insofar as reasonably
necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining
professional advice,
or the establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court
procedure.
4.2 We may disclose your personal data to our
suppliers or subcontractors insofar as reasonably necessary
for the proper administration of our website and business.
4.4 Financial transactions relating to our website
and services are handled by our payment services providers
– Paypal and CoinPayments. We will share transaction data with our payment services providers only to
the extent
necessary for the purposes of processing your payments, refunding such payments and dealing with
complaints and queries
relating to such payments and refunds.
4.5 We may disclose your enquiry data to one or
more of those selected third party suppliers of goods and
services identified on our website for the purpose of enabling them to contact you so that they can
offer, market and
sell to you relevant goods and/or services. Each such third party will act as a data controller in
relation to the enquiry
data that we supply to it; and upon contacting you, each such third party will supply to you a copy of
its own privacy
policy, which will govern that third party’s use of your personal data.
4.6 In addition to the specific disclosures of personal data set
out in this Section 4, we may
disclose your personal data where such disclosure is necessary for compliance with a legal obligation to
which we are
subject, or in order to protect your vital interests or the vital interests of another natural person.
We may also disclose
your personal data where such disclosure is necessary for the establishment, exercise or defence of
legal claims, whether
in court proceedings or in an administrative or out-of-court procedure.
5.
International transfers of your
personal data
5.1 In this Section 5, we provide information
about the circumstances in which your personal data may be
transferred to countries outside the European Economic Area (EEA).
5.2 We and our other group companies have offices and facilities
in Israel and Bulgaria. The
European Commission has made an “adequacy decision” with respect to the data protection laws of each of
these countries.
Transfers to each of these countries will be protected by appropriate safeguards, namely the use of
standard data protection
clauses adopted or approved by the European Commission
5.3 The hosting facilities for our website are situated in
Ireland. The European Commission has made an “adequacy decision” with respect to the data
protection laws of each
of these countries. Transfers to each of these countries will be protected by appropriate safeguards,
namely the use
of standard data protection clauses adopted or approved by the European Commission.
5.4 You acknowledge that personal data that you
submit for publication through our website or services
may be available, via the internet, around the world. We cannot prevent the use or misuse of such
personal data by others.
6.
Direct Marketing
6.1 We may share your full name, email address and phone number with certain broker(s)
(the “Broker”) in the event that you have granted permission to receive promotional materials from such
Broker at the time of registration. The Broker may periodically use your full name, email address and
phone number for the purpose of providing you with promotional materials if your permission was granted
at the time of registration and you have not unsubscribed at a later time in accordance with the
provisions hereof. At any time, you may request to discontinue receiving these offers or
grantbestoffer.com marketing emails by clicking on the unsubscribe link in the email’s footer . If you
unsubscribe we will remove your full name, email address and phone number from our marketing
distribution lists and from any future lists we may share with the Broker. However, you may need to also
separately unsubscribe from marketing offers sent by the Broker.Please note that in order to send you
promotional materials, the Broker may assign you with a username and password which will allow you
access to the Broker’s site through an account. You may contact the Broker at any time to remove the
account.
7.
Retaining and deleting personal
data
7.1 This Section 6 sets out our data retention
policies and procedure, which are designed to help ensure
that we comply with our legal obligations in relation to the retention and deletion of personal
data.
7.2 Personal data that we process for any purpose
or purposes shall not be kept for longer than is necessary
for that purpose or those purposes.
7.3 We will retain your personal data as
follows:
(a) Name, email, phone number, your personal
profile and statistics regarding opening our emails sent to
your email address will be retained for a minimum period of
6 months
following
sign up or purchase date, and for a maximum period of
3 year if you are not opening emails and/or interacting with the services we provide, or will be
retained without a maximum
period as long as you are an active subscriber or client.
(b) Your IP address is monitored by our data analytics
software as long as you keep visiting our websites.
(c) Your transaction data is retained for a minimal
time of 3 years for a maximum period of 10 years.
7.4 Notwithstanding the other provisions of this
Section 6, we may retain your personal data where such
retention is necessary for compliance with a legal obligation to which we are subject, or in order to
protect your vital
interests or the vital interests of another natural person.
8.
Amendments
8.1 We may update this policy from time to time by
publishing a new version on our website.
8.2 You should check this page occasionally to
ensure you are happy with any changes to this policy.
8.3 We may notify you of significant changes to
this policy by email or through the private messaging system
on our website.
9.
Your rights
9.1 In this Section 8, we have summarised the
rights that you have under data protection law. Some of the
rights are complex, and not all of the details have been included in our summaries. Accordingly, you
should read the
relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection
law are:
(a) The right to access;
(b) The right to rectification;
(c) The right to erasure;
(d) The right to restrict processing;
(e) The right to object to processing;
(f) The right to data portability;
(g) The right to complain to a supervisory
authority; and
(h) The right to withdraw consent.
9.3 You have the right to confirmation as to
whether or not we process your personal data and, where we
do, access to the personal data, together with certain additional information. That additional
information includes details
of the purposes of the processing, the categories of personal data concerned and the recipients of the
personal data.
Providing the rights and freedoms of others are not affected, we will supply to you a copy of your
personal data. The
first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
9.4 You have the right to have any inaccurate
personal data about you rectified and, taking into account
the purposes of the processing, to have any incomplete personal data about you completed.
9.5 In some circumstances you have the right to
the erasure of your personal data without undue delay.
Those circumstances include: the personal data are no longer necessary in relation to the purposes for
which they were
collected or otherwise processed; you withdraw consent to consent-based processing; you object to the
processing under
certain rules of applicable data protection law; the processing is for direct marketing purposes; and
the personal data
have been unlawfully processed. However, there are exclusions of the right to erasure. The general
exclusions include
where processing is necessary: for exercising the right of freedom of expression and information; for
compliance with
a legal obligation; or for the establishment, exercise or defense of legal claims.
9.6 In some circumstances you have the right to
restrict the processing of your personal data. Those circumstances
are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no
longer need
the personal data for the purposes of our processing, but you require personal data for the
establishment, exercise or
defence of legal claims; and you have objected to processing, pending the verification of that
objection. Where processing
has been restricted on this basis, we may continue to store your personal data. However, we will only
otherwise process
it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of
the rights of
another natural or legal person; or for reasons of important public interest.
9.7 You have the right to object to our processing
of your personal data on grounds relating to your particular
situation, but only to the extent that the legal basis for the processing is that the processing is
necessary for: the
performance of a task carried out in the public interest or in the exercise of any official authority
vested in us; or
the purposes of the legitimate interests pursued by us or by a third party. If you make such an
objection, we will cease
to process the personal information unless we can demonstrate compelling legitimate grounds for the
processing which
override your interests, rights and freedoms, or the processing is for the establishment, exercise or
defence of legal
claims.
9.8 You have the right to object to our processing
of your personal data for direct marketing purposes
(including profiling for direct marketing purposes). If you make such an objection, we will cease to
process your personal
data for this purpose.
9.9 You have the right to object to our processing
of your personal data for scientific or historical research
purposes or statistical purposes on grounds relating to your particular situation, unless the processing
is necessary
for the performance of a task carried out for reasons of public interest.
9.10 To the extent that the legal basis for our processing of
your personal data is:
(a) Consent; or
(b) That the processing is necessary for the
performance of a contract to which you are party or in order
to take steps at your request prior to entering into a contract,
and such processing is
carried out by automated means, you have the right to receive
your personal data from us in a structured, commonly used and machine-readable format. However, this
right does not apply
where it would adversely affect the rights and freedoms of others.
9.11 If you consider that our processing of your personal
information infringes data protection laws, you have a legal
right to lodge a complaint with a supervisory authority responsible for data protection. You may do so
in the EU member
state of your habitual residence, your place of work or the place of the alleged infringement.
9.12 To the extent that the legal basis for our processing of
your personal information is consent, you have the right
to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the
withdrawal.
9.13 You may exercise any of your rights in relation to your
personal data by written notice to us via email.
10.
About cookies
10.1 A cookie is a file containing an identifier (a
string of letters and numbers) that is sent by a web
server to a web browser and is stored by the browser. The identifier is then sent back to the server
each time the browser
requests a page from the server.
10.2 Cookies may be either “persistent” cookies or
“session” cookies: a persistent cookie will be stored
by a web browser and will remain valid until its set expiry date, unless deleted by the user before the
expiry date;
a session cookie, on the other hand, will expire at the end of the user session, when the web browser is
closed.
10.3 Cookies do not typically contain any
information that personally identifies a user, but personal information
that we store about you may be linked to the information stored in and obtained from cookies.
11.
Cookies that we use
11.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify
you when you visit our website and as you navigate our
website
(b) status – we use cookies to help us to
determine if you are logged into our website
(c) personalization – we use cookies to store
information about your preferences and to personalise the
website for you
(d) security – we use cookies as an element of the
security measures used to protect user accounts, including
preventing fraudulent use of login credentials, and to protect our website and services generally
(e) advertising – we use cookies to help us to
display advertisements that will be relevant to you
(f) analysis – we use cookies to help us to
analyse the use and performance of our website and services
(g) cookie consent – we use cookies to store your
preferences in relation to the use of cookies more generally
(h) tracking – we use cookies to store
marketing and advertising tracking
12.
Cookies used by our service providers
12.1 Our service providers use cookies and those cookies may
be stored on your computer when you visit our website.
12.2 We use Facebook, GetClicky and Google Analytics to analyse the use of our website. GetClicky
and Google Analytics gathers information about website use by means of cookies. The information gathered
relating to our website is used to create reports about the use of our website. Google’s privacy policy
is available at:
13.
Managing cookies
13.1 Most browsers allow you to refuse to accept cookies and
to delete cookies. The methods for doing so vary from
browser to browser, and from version to version. You can however obtain up-to-date information about
blocking and deleting
cookies via these links:
13.2 Blocking all cookies will have a negative impact upon the
usability of many websites.
13.3 If you block cookies, you will not be able to use all the
features on our website.
14.
Our details
14.4 You can contact us:
15.
Data protection officer
