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PRIVACY POLICY

(A)    This Policy

 

This Policy is issued by each of the  Controller entities listed in Section (Q) below (together, “Gestech Ltd”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, or recipients of any of our other products, services, personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained in Section (X) below.

 

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, Personal Information or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

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Intended Audience: Our Sites, products, or services are not directed to children under the age of 18. As a result, our Sites, products, or services do not request or knowingly collect personal information from individuals under the age of 18. If you are 18 and under, you should not visit or use our  Sites, products, or services .

 

This Policy was last updated on SEPTEMBER 2022

 

(B)   Collection of Personal Data

 

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

  • Data provided to us: We obtain Personal Data when those data are provided to us (e.g., when you register an account with us; where you contact us  via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).

  • Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you).

  • Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including  via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).

  • Site data: We collect or obtain Personal Data when you visit any of our Sites or use any  features  or  resources  available  on or through  a Site.

  • Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, products, or services.

  • Content and advertising information: If you interact with any third party content or advertising on  our Site(including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.

  • Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

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(C)   Creation of Personal Data

 

 

When you conduct a transaction on our website, as part of the process, we collect personal information you give us such as your name, address and email address.

Your personal information will be used for the specific reasons stated above only.

 

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, products or services, including where those data are collected from different devices.

 

(D)   Categories of Personal Data we Process

 

We Process the following categories of Personal Data about you:

  • Personal details: given name(s); preferred name; and photograph.

  • Demographic information: gender; date of birth / age; nationality/district; and language preferences.

  • Contact details: address; shipping address; telephone number; email address; online messaging details; and social media details.

  • Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).

  • Purchase details: records of purchases and prices; consignee name; address; contact telephone number; email address; details of returns; warranty details;

  • Payment details: invoice records; payment records; billing address; payment method; last four digits of bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date.

  • Data relating to our Sites: Internet Protocol (IP) address; internet service provider; referring/exit pages; language settings; dates and times of connecting to a Site.

  • Server logs: records of events on our servers, including search queries; IP addresses; hardware settings; browser type; browser language; the date and time of request; referral URL; and certain cookies that identify your browser or Account.

  • Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part).

  • Views and opinions: any comments, views and opinions that you choose to send to us, or publicly post about us on social media platforms.

  • Cookie data: personal data collected via cookies and other similar technologies – please see our [Cookie Policy] for more details

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(E)    Disclosure of Personal Data to third parties

 

We disclose Personal Data to other entities within the Gestech Ltd, for legitimate business purposes and the operation of our Sites  to you, in accordance with applicable law. In addition, we disclose Personal Data to:

  • you and, where appropriate, your appointed representatives;

  • legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

  • accountants, auditors, consultants, lawyers and other outside professional advisors to Gestech Ltd, subject to binding contractual obligations of confidentiality;

  • third party Processors (such as email service providers; marketing/advertising service providers; venue operators; payment services providers; shipping companies; postal carriers; etc.), located anywhere in the world, subject to the requirements noted below in this  Section (G);

  • any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;

  • any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

  • any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

  • any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

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(F)   Data security

 

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

 

Because the internet is an open system, the transmission of information  via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

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(G)  Terms and Conditions

 

All use of  our  Sites or services is subject to our                                                            We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

 

(H)   Direct marketing

 

We Process Personal Data to contact you  via email, telephone, direct mail or other communication formats to provide you with information regarding Sites  that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, Apps, products, or services. If we provide Sites to you, we may send or display information to you regarding our Sites, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

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