A. Introduction

This is a personal data policy that describes how we at SEO Group collect, use and protect your personal information. By using our website, you consent to our use of cookies in accordance with this policy. We collect various types of personal information about you, including information about your computer, your visits to our website and your use of our services. We use this information to administer our website, to customize it for you, and to enable you to use our services. We may also use your information to contact you and to send you emails and/or newsletters. You have the right to request access to and to rectify any inaccurate personal data that we hold about you. If you have any questions about our privacy policy, please contact us.

B. Explanation

1. The privacy of our website visitors is very important to us, and we are committed to protecting it. This policy explains what we do with your personal data.
2. By consenting to our use of cookies in accordance with the terms of this policy when you visit our website for the first time, you allow us to use cookies every time you visit our website.

C. Collection of your Personal Information

The following types of personal information may be collected, stored, and used:

1. information about your computer, including IP address, geographic location, browser type and version, and operating system;
2. information about your visits to and use of this website, including the referral source, duration of the visit, page views and website navigation paths;
3. information you provide when you register on our website, such as your email address;
4. information you provide when you create a profile on our website, such as your name, gender, relationship status, birthday, profile pictures, interests, hobbies, and information about your education and employment;
5. information you provide to subscribe to our emails and/or newsletters, such as your name and email address;
6. information that you provide when you use our website’s services;
7. information generated when you use our website, including when, how often and under what circumstances you use it;
8. information relating to anything you purchase, the services you use, or transactions you make through our website, including your name, telephone number, address, email address, and credit card details;
9. information that you post on our website with the intention of publishing it on the Internet, including your username, profile pictures and the content of your posts;
10. information in any form of communication that you send to us via email or our website, including its content and metadata;
11. any other personal information that you submit to us.

Before you provide another person’s personal information to us, you need that person’s consent to that personal information being both disclosed and processed in accordance with this policy

D. Use of your personal information

Personal information submitted to us through our website will be used for the purposes set out in this policy or on the relevant pages of the website. We may use your personal information for the following purposes:

1. to administer our website and business;
2. to customize our website for you;
3. to enable you to use the services available on our website;
4. to send you goods that you have purchased through our website;
5. to deliver services purchased through our website;
6. to send you statements, invoices and payment reminders and collect payments from you;
7. to send commercial communications that are not for marketing purposes;
8. to send you emails that you have specifically requested;
9. to send you our newsletter by e-mail if you have requested it (you can inform us at any time if you no longer need the newsletter);
10. to send you marketing communications relating to our business or carefully selected third party businesses which we think may be of interest to you by post or, where you have specifically consented to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
11. to provide third parties with statistical information about our users (but these third parties will not be able to identify an individual user from the information);
12. to deal with enquiries and complaints from or about you regarding our website;
13. to keep our website secure and prevent fraud;
14. to confirm your agreement to our website’s terms of use (including monitoring private messages sent through our website’s private messaging service); and
15. other uses.

If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the permission you give us.

Your privacy settings may be used to limit the publication of your information on our website and may be adjusted with the website’s privacy controls.

We will not disclose your personal information to third parties for their or any other third party’s direct marketing without your explicit consent.

E. Disclosure of Personal Information

We may disclose your personal information to any of our employees, directors, insurers, professional advisers, agents, suppliers or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our holding company and any of its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

1. to the extent that we are required to do so by law;
2. in connection with ongoing or future court proceedings;
3. to establish, exercise or defend our legal rights (including disclosing information to others for fraud prevention and credit risk mitigation purposes);
4. to the buyer (or prospective buyer) of any business or asset that we are in the process of (or considering) selling; and
5. to any person we reasonably believe may request from a court or other competent authority that we disclose the personal information if, in our reasonable opinion, such court or authority could reasonably order us to disclose the personal information.

We will not disclose your personal information to third parties except as set out in this policy.

F. International Data Transfers

1. Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
2. Information that we collect may be transferred to the following countries that do not have data protection laws equivalent to those applicable in the European Economic Area: the United States, Russia, Japan, China and India.
3. Personal information that you post on our website or submit for publication on our website may be available via the internet around the world. We cannot prevent the information from being used or misused by others.
4. You expressly consent to the transfer of personal information as described in this Section F.

G. Retention of Personal Information

1. This Section G describes our data retention policies and procedures, which are designed to ensure that we comply with our legal obligations regarding the retention and deletion of personal information.
2. Personal information that we process for any purpose or purposes will not be kept for longer than is necessary for that purpose(s).
3. Notwithstanding the other provisions of this Section G, we will retain documents (including electronic documents) containing personal data:
   1. to the extent that we are required to do so by law;
   2. if we believe that the documents may be relevant to ongoing or future court proceedings; and
   3. to establish, exercise or defend our legal rights (including disclosing information to others for fraud prevention and credit risk mitigation purposes).

H. Security of Your Personal Information

1. We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
2. We will store any personal information that you provide on our secure (password and firewall protected) servers.
3. All electronic financial transactions made through our website are protected by encryption technology.
4. You acknowledge that the transmission of information over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet.
5. You are responsible for keeping the password you use to access our website confidential; We will not ask you for your password (except when you log in to our website).

I. Amendments

We may update this policy from time to time by posting a new version on our website. You should check this page from time to time to make sure you understand any changes to this policy. We may notify you of changes to this policy by email or through our website’s private messaging system.

J. Your rights

We may withhold the personal information you request as permitted by law.

You can ask us not to process your personal information for marketing purposes at any time.

In practice, you will typically either explicitly accept our use of your personal information for marketing purposes, or we will provide you with the opportunity to opt-out of the use of your personal information for marketing purposes.

K. Third Party Websites

Our website contains hyperlinks to and details of third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

L. Updating Information

Please let us know if the personal information we hold about you needs to be corrected or updated.

M. Cookies

Our website uses cookies. 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 stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can be either “persistent cookies” or “session cookies”: a persistent cookie is stored by a browser and remains valid until the specified expiration date, unless it is deleted by the user before the expiration date; A session cookie, on the other hand, will expire at the end of the user session, when the browser is closed. Cookies do not typically contain 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.

1. Below are the names of the cookies we use on our website and the purposes for which they are used:
   1. We use Google Analytics and Adwords on our website to recognize a computer when a user visits the website, track users when they browse the website, improve the usability of the website, analyse the use of the website, administer the website, prevent fraud and improve website security, customise the website for each user/target ads that may be of particular interest to specific users.
2. Most browsers allow you to refuse to accept cookies – for example:
   1. in Internet Explorer (version 10), you can block cookies using the settings to opt out of cookie management by clicking on “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
   2. in Firefox, you can block all cookies by clicking on “Tools”, “Preferences”, “Privacy & Security”, selecting “Custom Content Blocking” and clicking on “All Cookies”; and
   3. In Chrome, you can block all cookies by opening the “Settings” menu and clicking on “Site Settings” under “Privacy & Security,” then unchecking “Allow sites to save and read cookie data.”

If you block all cookies, it will have a negative impact on the usability of many websites. If you block cookies, you may not be able to use the full functionality of our website.

3. You can delete cookies that have already been stored on your computer – for example:
   1. in Internet Explorer (version 10) you will have to manually delete cookies (you can find instructions for doing so on http://support.microsoft.com/kb/278835 );
   2. in Firefox (version 24), you can delete cookies by clicking on “Tools”, “Preferences”, “Privacy & Security” and then selecting “Clear Data” under “Cookies and Site Data”; and
   3. in Chrome (version 29), you can delete all cookies by opening the “Settings” menu and clicking on “Clear browsing data” under “Privacy & Security”.
4. Deleting cookies will have a negative impact on the usability of many websites.