1.1 We are committed to safeguarding the privacy of our website visitors. Contact us if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Our website incorporates privacy controls which affect how we will process your personal data.
1.5 In this policy, “we”, “us” and “our” refer to Networks Training (www.networkstraining.com). For more information about us, see Section 15.
1.6 The processing of personal data, such as e-mail address, IP address etc of a data subject shall always be in line with the General Data Protection Regulation (GDPR).
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. What data we may process and 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 (anonymized), 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 our analytics tracking system which is Google Analytics. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
3.3 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). We gather only your e-mail address, IP address and date/time when you subscribed. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters and also to send you useful information related to our website and niche.
We use a third-party provider, ElasticEmail, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see ElasticEmail privacy notice. You can unsubscribe to general mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of our emails or by contacting us here. The legal basis for this processing is your consent.
3.4 We may process information contained in or relating to any communication that you send to us (“correspondence data“) via the website contact forms or our commenting system. The correspondence data may include the communication content and metadata associated with the communication (such as your IP address, email, your pseudonym you chose to contact us etc). Our website will generate the metadata associated with communications made using the website contact forms or the commenting system of our website. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website and business and communications with users.
3.5 We may process information contained in any enquiry you submit to us (through email or contact forms) regarding our 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 to properly answer your enquiry and offer you the best service possible.
3.6 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 email, and information contained in communications between us and you. 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.
3.7 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.
3.8 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3.9 As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
4. Providing your personal data to others
4.1 We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share your data with:
Our Processing Partners:
- TMZ Hosting – TMZHosting LLC
- Cloudflare – Cloudflare Inc
- DPD (Digital Product Delivery) – Portal Labs, LLC
- Paypal – PayPal (Europe) S.à.r.l. & Cie. S.C.A
- Ezoic – Ezoic Inc
4.2 Financial transactions relating to our products and services are handled by our payment services providers, namely Paypal. 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. You can find information about the payment services providers’ privacy policies and practices at https://www.paypal.com/en/webapps/mpp/ua/privacy-full
4.3 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 The hosting facilities for our website are situated in the United States of America (USA). Transfers to this country will be protected by appropriate safeguards, namely using encrypted communication of HTTPs using TLS and secure servers using security protection software.
5.3 Information you submit to us when you sign up for our newsletter (your email address) maybe transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is ElasticEmail.
Country of storage: Although data centers are mostly hosted in the EU, it may be possible that email data would be transferred outside of the EU (Canada) for up to 48 hours for attempted delivery.
Safeguard(s) used: Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) requirements are quite similar to the GDPR and with Elastic Email being a Canadian Corporation they already have a number of well-defined data management policies in place.
6. Retaining and deleting personal data
6.1 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.
6.2 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.
6.3 We will retain your personal data as follows:
(a) “usage data” will be retained for a maximum period of 38 months following May 25, 2018.
(b) “notification data”: we retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our newsletter service, whichever occurs first.
(c) “correspondence data” : when you make an enquiry or contact us via our contact form or commenting system, we will retain your information for as long as it takes to respond to and resolve your enquiry.
(d) “enquiry data” : when you make an enquiry or contact us via email or our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry.
(e) “customer relationship data” will be retained for as long as you remain our customer in order to support you and answer any questions you may have about our products.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of “usage data” will be determined based on how long our website is operational and provided that the data subject has not asked for data deletion.
(b) the period of retention of “notification data” will be determined based on how long our email newsletter is operational and provided that the data subject has not asked for data deletion or to unsubscribe.
(c) the period of retention of “correspondence data” will be determined based on how long we need to keep it according to our legitimate interests, namely the proper administration of our website and business and communications with users.
(d) the period of retention of “enquiry data” will be determined based on how long we need to keep it according to our legitimate interests, namely the proper service to our customers.
(e) the period of retention of “customer relationship data” will be determined based on how long you remain our customer in order to support you about our products and answer any questions you may have.
6.5 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.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.
8. Your rights
8.1 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.
8.2 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.
8.3 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.
8.4 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.
8.5 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 defence of legal claims.
8.6 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.
8.7 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.
8.8 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.
8.9 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.
8.10 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.
8.11 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.
8.12 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.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us OR by using the Contact Page on this website.
9. About cookies
9.1 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.
9.2 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.
9.3 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.
10. Cookies that we use
11. Cookies used by our service providers
11.2 We use Google Analytics to analyse the use of our website. 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. We have enabled the IP Anonymization feature in Google Analytics and also we are not using the User ID feature.
If you want to opt-out from Google Analytics visit this page: https://tools.google.com/dlpage/gaoptout
Moreover, if you want to know how Google manages data in its ads products please visit this page here.
You can opt-out of Facebook retargeting and customize your ad preferences in Facebook here (you may need to log in first): https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
Moreover, this link shows how Ezoic handles and uses your data when you visit our website and also provides an option to manage or withdraw your cookie consents: https://g.ezoic.net/privacy/networkstraining.com
12. Managing cookies
12.1 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:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
12.4 At the link here: http://optout.aboutads.info you can opt-out of interest-based advertising from all companies.
13. How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks. Also we have implemented security software to automatically defend against attacks and help to secure your Personal Data.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
15. Our details
15.1 This website is owned and operated by Epic Home Ideas.
15.2 Our principal place of business is at Nicosia, Cyprus.
15.4 You can contact us:
(a) using our website contact form;
(b) by email, using the email address published on our website from time to time.
16. Payment Processor Details
This section is about the Data protection provisions about the use of PayPal as a payment processor.
On this website, the controller has integrated components of PayPal. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts.
PayPal is also able to process virtual payments through credit cards when a user does not have a PayPal account. A PayPal account is managed via an e-mail address, which is why there are no classic account numbers.
PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also accepts trustee functions and offers buyer protection services.
The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.
If the data subject chooses “PayPal” as the payment option in the online shop during the ordering process, we automatically transmit the data of the data subject to PayPal (we Do Not Store any of the Data to our website).
By selecting this payment option, the data subject agrees to the transfer of personal data required for payment processing.
The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order.
The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to PayPal, in particular, if a legitimate interest in the transmission is given.
The personal data exchanged between PayPal and the controller for the processing of the data will be transmitted by PayPal to economic credit agencies. This transmission is intended for identity and creditworthiness checks.
PayPal will, if necessary, pass on personal data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfill contractual obligations or for data to be processed in the order.
The data subject has the possibility to revoke consent for the handling of personal data at any time from PayPal. A revocation shall not have any effect on personal data which must be processed, used or transmitted in accordance with (contractual) payment processing.
The applicable data protection provisions of PayPal may be retrieved under https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
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