We are committed to safeguarding the privacy of the personal data that we process in the course of our business, including the personal information we receive from you. This Privacy Policy describes how and why we collect, store and use personal information, and provides information about the rights of the individuals to whom such personal information relates.

This Privacy Policy addresses both users who actively choose to use our services, as described below and also to individuals whose personal data we may process as part of our operation.

The types of information we collect:
  • Non-personal information that is un-identified or non-identifiable which is generated by user's activity. Such non-personal information may include (without limitation) the following: browser type, web pages, time spent, access times and dates.
  • Personal information is information that identifies you or may identify you. The Personal Information we collect and retain includes your IP address, your name and email address, identifying documents, office/home address, screen name, payment and billing information or other information we may ask from time to time as will be required for the on-boarding process and services provisioning.
  • Any other information relating to you which you may provide to us.

The purposes for which we process your personal data are as follows:
  • Providing Services to you;
  • Communicating with you in respect of the promotion of our business, advertising and other marketing campaign and materials;
  • Managing our business relationship with you (or your organisation), whether in connection with the provision of our services, including processing payments, accounting, auditing, billing and collection and related support services;
  • Complying with our obligations, including with respect to legal and regulatory considerations (e.g. anti-money laundering and sanctions checks, audits, enquiries by regulatory authorities);
  • Managing and securing access to our premises and information technology systems, and monitoring the technology side of our operations;
  • Keeping your contact details accurate and current using information provided by you, or information publically available;
  • For any purpose related and/or ancillary to any of the above or any other purposes for which your personal data was provided to us.

Do we share your personal data?
We do not rent or sell your personal data to anyone. We may share and disclose information (including personal data) about you in the following limited circumstances:
  • We may share your information with third party vendors, consultants and other service providers who we employ to perform tasks on our behalf. These companies include (for example) our payment processing providers, website analytics companies (e.g., Google Analytics), email service providers, and others.
  • We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal data could be one of the assets transferred to or acquired by a third party.
  • We may also share your personal data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Policy.
  • We reserve the right to access, read, preserve, and disclose any information as necessary to comply with law or court order; enforce or apply our agreements with you and other agreements; or protect our rights, property, or safety, our employees, our contractors, our users, or others.
  • Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
  • We may use your personal data for our internal business purposes for conducting analytics and improving our services and performance.

The level of personal data protection in the various jurisdictions in which we operate varies, and in some instances may not provide an adequate level of protection from an international perspective. To address this, we have procedures and safeguards in place to ensure the protection of personal data. These procedures include contractual obligations to ensure that all such entities safeguard your personal information and use it only for the purposes that we have specified and communicated to you. When we transfer your information to other countries, we will use, share and safeguard that information as described in this Privacy Policy.

How long do we keep your information?
We will retain your personal data for the length of time needed to fulfil the purposes for which it was collected, unless we specifically agree a longer retention period with you, or a longer retention period is required or permitted by law.

Your Rights
Various rights may be available to you, depending on the circumstances and the applicable law. We summarise key rights likely to be available to most data subjects:
  • Withdraw consent: When personal information is processed on the basis of consent, you may withdraw consent at any time, although such withdrawal will not affect the lawfulness of processing occurring prior to such withdrawal;
  • Access and rectification, etc.:You may request access to and rectification or erasure of personal data, or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;
  • Objecting and restricting: You may object, on legitimate grounds, to the processing of your personal data, or request that processing be restricted; and
  • Complaints: If you believe that your data protection rights may have been breached, you may lodge a complaint with the relevant data protection authority.
If you would like to exercise any of the above rights, or any other rights available to you pursuant to applicable law, please contact us using the contact details set out below.

Cookies are small files that are sent to a computer’s hard drive by a web server, enabling a website to remember who you are. Information from cookies may include information relating to your use of our websites, information about your computer (such as IP address and browser type), and demographic data. We use cookies to improve our website.
We use the products to track unique visitors to our website and app (storing a unique visitor ID, the date and time of first visit, the time their current visit started and the total number of visits they have made); to register session details (so as to attribute visit information, including conversions and transactions to a traffic source); and to register that a website visit has ended and the browser closed. Most internet browsers have a mechanism notifying you when you receive a new cookie, and telling you how to reject new cookies or disable cookies altogether (if you wish to do so).

Information Security
We have implemented reasonable administrative, technical and physical measures to protect your personal data against loss, misuse and alteration.

Changes to this Privacy Policy
We may from time to time make changes to this Privacy Policy. Where these are likely to be material, we will communicate these in advance. Otherwise, these will become effective once the amended Privacy Policy is posted on our website. Please check back regularly to keep informed of updates to this Privacy Policy.

Contact Details
Limited Liability Partnership V & Garnet,