- Information collected and how it is used
- Direct marketing and how you can manage your preferences
- Cookies, similar sites and third-party services
- How we use Personal Information
- The legal basis for using your Personal Information
- Transfers of Personal Information
- How we protect and store your information
- Use by children
- Your rights
- How to contact us
1. INFORMATION COLLECTED AND HOW IT IS USED
1.1 Personal Information
We collect information that identifies an individual or may with reasonable effort allow the identification of an individual, or may be sensitive in nature (“Personal Information“) when you:
- register with or use our Website or one of our Products;
- use our free tools either to try our Products or consult with a member of our sales team; or
- commence direct communications with us either in relation to a query or complaint.
We will ask you to provide certain Personal Information if you choose to create a Chostner Ltd account or use our services. This may include your name, personal and work email, work or home address, employer, payment information, and phone number. We collect this information, only if voluntarily provided by you, in order to create and authenticate your account and provide you access to our Products and services. Where you try to consult with a member of our sales team, we will also collect Personal Information that you voluntarily provide about your work and your company.
We also collect Personal Information when you commence direct communications via our Website enquiry form, by telephone or writing to us. When you commence direct communications with us, we may retain such communications and the accompanying Personal Information in order to process your inquiries, respond to your requests and improve our services.
1.2 Web Server Information
2. DIRECT MARKETING AND HOW YOU CAN MANAGE YOUR PREFERENCES
We may use your Personal Information, voluntarily provided by you in the circumstances described herein, to let you know about our Products and services that we believe will be of interest to you. In all cases, we will respect your preferences for how you would like us to manage such marketing activity with you.
To protect privacy rights and to ensure you have control over how we manage marketing activities with you:
2.1 we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
2.2 you can ask us to stop direct marketing at any time – you can ask us to stop sending email marketing, by following the ‘unsubscribe’ link you will find on all the email marketing messages we send you. Alternatively, you can contact us at email@example.com Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g., email); and
2.3 you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below in the “Cookies, Similar Sites and Third-Party Services” section.
We recommend you routinely review the privacy policies and preference settings that are available to you on any social media platforms you use, as well as your preferences within your Chostner Ltd account.
3. COOKIES, SIMILAR SITES, AND THIRD-PARTY SERVICES
Our Website uses certain monitoring and tracking technologies (such as cookies, web beacons and pixels).
A cookie is a small text file that is stored in a web browser directory by a website or an advertisement related action. Our Website uses two types of cookies: session cookies and persistent cookies. Session cookies are created temporarily in your web browser directory while you are visiting a website and are deleted once you leave the website. Persistent cookies remain in your web browser and are activated again once you visit the website that created that specific cookie. A web beacon is a small file used by a website or an advertisement-related action to keep track of your navigation through a single website or a series of websites. A pixel is a small line of code which is used by a website or an advertisement-related action to assign online activities to a computer or browser.
We use these technologies in order to ensure proper operation of our Products and Website, collect information and ensure information security. Although our collection of such information is not used to personally identify users, we are still committed to giving you the opportunity to exercise your choice of opting out from our collection of such information. For removing cookies and other technologies used on our Website, please refer to the “Opt-Out Option” sub-section below.
We will not use the above technologies to collect Personal Information without obtaining your permission, unless where we are permitted to do so under applicable privacy laws.
3.2 Opt-Out Option
Please note that your browser enables you to disable all cookies (if you do not know how to do this, check out the “Help” file of your browser), however, this may interfere with your use of the Website or other internet websites.
If you would like to opt-out of the cookies that our Website may use (directly by us and not by third parties as referred to below), please email us at firstname.lastname@example.org.
If you use a new computer, upgrade or change web browsers or take any action which results in the deletion of the “opt out” cookie, you will need to perform this opt-out process again upon any such change.
For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org.
3.3 Third Party Websites and Services
Our Products may recommend third party websites which the Product determines may be of interest to you (“Similar Sites“). Additionally, there may be links on our Website to third party websites and services such as Google Analytics, KeenIO, and others (“Third-Party Services”). We do not have control over such Similar Sites or Third-Party Services, including their information collection and use practices. We are not responsible for their privacy practices or policies. We therefore recommend that you review the privacy policies of Similar Sites and Third-Party Services before providing them with your Personal Information. For more information about the Third-Party Services to which links are included in our Website, please contact us at email@example.com.
Chostner Ltd uses remarketing with Google Analytics to advertise online. Third party vendors, including Google, may show Chostner Ltd’s ads on sites across the Internet. By using the Ads Settings, visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.
4. HOW WE USE PERSONAL INFORMATION
Chostner Ltd will use Personal Information solely in order to provide you with our Products and services, process your inquiries, respond to your requests and improve our services.
In addition, we may share some or all of your Personal Information in the manner and for the purposes described below:
4.1 with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any Personal Information we share with them solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems;
4.2 with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order; and
4.3 we may collect and share Personal Information if required to do so as part of any legal proceedings conducted between you and Chostner Ltd.
5. THE LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION
We will only collect, use and share your Personal Information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
5.1 you have provided your consent to us using the Personal Information (e.g. where you provide us with marketing consents or opt-in to optional additional services or functionality);
5.2 our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. providing you with our Products, and services, creating your user account);
5.3 our use of your Personal Information is in our legitimate interest as a commercial organisation, subject to your interests and fundamental rights. In these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in “your rights” section below;
5.4 our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have (e.g. the disclosure of information to law enforcement or tax authorities).
If you would like to find out more about the legal basis for which we process Personal Information please contact us.
6. TRANSFERS OF PERSONAL INFORMATION
Please be aware that your Personal Information may be transferred, stored and processed in countries outside your country of residence from which the information was collected, including the United States, where our servers are located and our central database is operated. This means that your Personal Information will be subject to a different standard of data protection than that available in your country of residence. Chostner Ltd will take appropriate steps to ensure that transfers of Personal Information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end:
6.1 we ensure transfers within Chostner Ltd will be covered by an agreement entered into by members of Chostner Ltd (an intra-group agreement) which contractually obliges each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it is transferred within Chostner Ltd;
6.2 where we transfer your Personal Information outside Chostner Ltd or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your Personal Information. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Information transferred from within the EU to the United States or other countries; or
6.3 where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.
6.4 Subject to applicable laws, You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your Personal Information when it is transferred as mentioned above. See the “Your Rights” section below for more details.
7. HOW WE PROTECT AND STORE YOUR INFORMATION
7.2 Retention of your Personal Information
In specific circumstances we may store your Personal Information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
8. USE BY CHILDREN
We do not offer our products or services for use by children. If you are under 18, you may not use the Website, our Products or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.
9. YOUR RIGHTS
You may revise your Personal Information by editing your account details. You also have the right to ask Chostner Ltd to amend any Personal Information it holds about you if it is inaccurate or misleading by emailing our Data Protection Officer at firstname.lastname@example.org.
9.1 The following rights, which may be subject to certain exemptions, apply (in addition to the rights set forth above) to EU users:
9.1.1 You have a right to access information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
9.1.2 You have a right to restrict the processing of your Personal Information, for example in case we no longer need your Personal Information for the initial purposes for which it was collected but it is required by you for the establishment, exercise or defence of legal claims.
9.1.3 You have a right to object to processing which has our legitimate interests as its lawful basis. We will no longer process your Personal Information upon your request, unless we have compelling legitimate grounds for the continuation of the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You may also object to our use of your Personal Information for direct marketing purposes. See the “Direct Marketing” and “Cookies” sections for how to unsubscribe, manage your marketing preferences and opt out of cookies.
9.1.4 You have a right to obtain a portable copy of Personal Information which is processed on the basis of your consent, or which is necessary for the performance of a contract between us. You have a right to have such portable copy of Personal Information transferred to another data controller in a structured, commonly used and machine-readable format;
9.1.5 You also have a right to request details of the basis on which your Personal Information is transferred outside the European Economic Area but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
9.1.6 You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
10. HOW TO CONTACT US
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to contact our Data Protection Officer at email@example.com.
We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.