Privacy Policy

Privacy Policy

We are committed to protecting and respecting your privacy. This Policy sets out the basis on which any personal data we collect will be processed by us when you visit our website as well as our customer's ("Advertisers") websites; and how that information is collected and used by companies that display advertisements ("Partners" or “Publishers”). Please read this privacy policy (“the Privacy Policy”) carefully to understand our views and practices and your rights regarding your personal data. This Privacy Policy was created to help you make an informed decision as to whether to use or continue using the website. By visiting any of our websites (our sites) you are accepting and consenting to the practices described in this policy.

For the purpose of this Policy “Versanto” means Versanto Limited whose registered office is at 3 Lockhart Road, Wanchai 6492102, Hong-Kong.

 

Collection of Information

We will collect and process the following data about you:

• Information you provide us us. We collect only necessary information from you and other individuals who use the website (Advertisers and Partners) by means of online or offline surveys, order forms, registration pages, telephone or cell phone communication, and other similar means. This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, email or otherwise. The information you give us may include your name, address, email address and phone number and financial information. Please let us know if any of this information changes so we can keep our records up to date.


• Information we collect from your use of our site. With regard to each of your visits to our site we will automatically collect the following information:
  • technical information, such as the Internet protocol (IP) address used to connect your device to the Internet, whereabouts you connected to our service, your internet service provider (ISP), and what type of device you are using to access our service;
  • Information we collect throughout our relationship. This is information relating to products that you download.

Use of Information

We use this information in the following ways:
Information you give to us or which we receive from other sources. We use this information:

• in order to take steps necessary to assess whether we can enter into a contract with you and in order to perform our contract with you. This includes carrying out our obligations to you and providing you with our, or a third party’s products and services;
• for the purpose of improving our service to you, to ensure that content from our site is presented in the most effective manner for you and for your device;
• to deal with any legal queries relating to your use of our service;
• to provide you with service communications so that we can perform our obligations to you. These may be sent by email. These will include notifications about changes to our service, event details and information about products that you have signed up to;
• to provide you with marketing communications including, with your permission, information about other goods and services we offer that are similar to those that you have already purchased or enquired about; or
• in our or a third party’s legitimate interests of keeping customers up to date with goods and services, increase awareness of us and third parties within the market, making promotional offers and generating new business, building and maintaining loyalty or market share.

Information we collect from your use of the site. We will use this information for the following purposes:
 

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your device;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• Information we collect throughout our relationship. We will use this information to help us provide you with our services.

Duration of holding information

You agree that for the purposes set out in the section “Use of Information” above, we have the right to share your personal information with selected associated third parties, some of whom we appoint to provide services, including:

• business partners, subsidiaries, affiliates, suppliers and sub-contractors for the performance of any contract we enter into with you;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• Customer survey providers in order to receive feedback and improve our services.
• Any member of our group, which means our employees and/or subsidiaries.
• Any financial institutions which may request to receive supporting documentation in order to credit or debit company’s bank account.

Additionally, we will disclose your personal information to the relevant third party:
 

• in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If we are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our customers, our regulator, or others.

Security

At Versanto we take your safety and security seriously and we are committed to protecting your personal and financial information. All information kept by us is stored on our secure servers and we take many strict measures in order to protect our data from unauthorized access, unauthorized disclosure or destruction of data. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

If we need to transfer your data, we will only do so if adequate protection measures are in place in compliance with data protection legislation.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

General Data Protection Regulation

On May 25, 2018, the European Union’s General Data Protection Regulation (GDPR) becomes officially operative. General Data Protection Regulation (EU) 2016/679 is a European Union law governing privacy and data protection for all residents of the EU. The provisions of GDPR can be also applied to how data is processed and verified outside the European Union.

GDPR is intended to empower the citizens of the European Union to control their personal information. In accordance with the applicable laws, users are authorized to access and modify their own data held by the companies, which includes data collection, ad tracking, surveys, cookies, location data, and every other bit of a user’s “digital footprint”. Users are also entitled to transmit their personal details to other organizations. The GDPR also enforces companies to determine their in-house data security policies.

We maintain our commitment to protect the privacy of our users and abide by the legislation of all regions we operate in, including compliance with the GDPR.

Taking into account the above, personal data (if any) of our users is processed under the “purposes of legitimate interests” as outlined in GDPR Article 6(1)(f). Such an approach also helps us to fight against fraud and reimburse our contractors and agents. In accordance with the GDPR requirements, we will strive to, at any time,

• streamline the data handling controls,
• specify our relationships with data partners, and
• provide the data subjects with an understanding and direct management of the way their personal information is used.

GDPR measures

Controller Classification:

As a Processor by the classifications of GDPR, we cooperate with our partners (Data Controllers and other Data Processors) to make sure any kind of user data is handled under the agreed terms and in compliance with the pertinent regulations.

As a Controller by the classification of GDPR, we have the appropriate technical and organizational measures in place ensuring that data processing is performed in accordance with GDPR. Such measures will be reviewed and updated if necessary and in accordance with the specifics of the gathered data.

Sub-Processors: We will, to the best of our ability, make sure that our sub-processors operate in full accordance with GDPR requirements before starting cooperation with them and require such sub-processors to comply with this Privacy Policy and maintain appropriate security to protect user information from unauthorized access or processing, unless we have no ability to do so (for example, where we are sharing information with regulatory authorities or courts). Nevertheless, we cannot be held responsible or liable for the use of any information that a sub-processor may execute, or that is gathered by sub-processors. Whenever applicable, users should acquaint themselves with Privacy Policies of any of the involved sub-processors’ websites.

Data Retention: We will retain the gathered data for the period of the cooperation, but in no case longer than the maximum allowed by the existing legislation, unless you choose to withdraw it yourself.

Requests and removal of the Data

Where processing of your personal data is based on consent, you can withdraw that consent at any time.

You have the following rights. You can exercise these rights at any time by contacting us at the email [email protected] or through the “Contact Us” section of our Site.

You have the right:

• to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;
• To ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
• To ask us not to process your personal data for scientific or historical research purposes, where relevant, unless the processing is necessary in the public interest;
• to request from us access to personal information held about you;
• to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
• to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation or the data is children’s data and was collected in relation to an offer of information society services;
• to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing).

Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us by sending us an email at [email protected]. In the event that you are not satisfied with our processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority, which is the Information Commissioner’s Office (ICO) in the UK, at any time.
 

Changes to our privacy policy

This policy may be updated from time to time. Please check back frequently to see any updates or changes to our privacy policy.

Cookies

A cookie is a small amount of data stored on the hard drive of your computer that allows us to identify you with your corresponding data that resides in our database. Cookies do not reveal personal information. The only personal information a cookie can be linked to is information you supply yourself such as email address, or information on your actions and behavioural data while using our Website, such as purchases and preferences. Cookies cannot read data from your hard drive. If you want to delete cookies from your computer, please go to your browser settings and do it manually.

We use cookies to associate certain Internet-related information about you and other individuals who use the website (Advertisers and Partners) with information about you in our database. This helps us to provide you with a good experience when you use the Site and also allows us to improve the Site.

Contact us

Questions, comments and requests regarding this privacy policy are welcomed and can be emailed to us at [email protected].

General Representation and Warranty

You represent and warrant that (i) your use of the Website will be in strict accordance with this Agreement and with all applicable laws and regulations (including without limitation any local laws or regulations in your country, state, city, or other governmental area, regarding online conduct and acceptable content, and including all applicable laws regarding the transmission of technical data exported from the country in which you reside) and (ii) your use of the Website will not infringe or misappropriate the intellectual property rights of any third party.

Applicable Law and Jurisdiction

This agreement and any dispute or claim arising out of or in connection with it or its subject matter or formation (including non- contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales. Each party irrevocably agrees that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with this agreement or its subject matter or formation (including non-contractual disputes or claims).