Privacy and Cookie Policy

Please get acquainted with the information below as well as the Disclaimer, before continuing to use

This privacy policy applies between you, the user of this website, and the owners and providers of this website. Here at, we are committed to protecting your privacy and security of your personal information. There are various ways you might interact with our website, and the information you provide while doing so allows us to ensure the best experience and improve our services. The following document applies to all data collected by us or provided by you concerning your usage of

(Effective Date: 01/11/2020)

Definitions and Interpretation

1. In this privacy policy the following definitions are used:

Data or InformationCollective personal and non-personal data that is collected or submitted using our website.
Personal Data or Personal InformationAny information relating to an identifiable individual that can be used to identify them either directly or indirectly. Including but not limited to identifiers such as a name, phone number, location data, an online identifier or factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
Non-Personal Data or Non-Personal InformationData logged for internal system-related or statistical purposes, which cannot be used to trace and identify a specific individual. Including but not limited to names of the files accessed, date and time of access, data volume transferred, web browser, time spent on specific pages, pages visited, geographical region, etc.
Data Protection LawsAny applicable law relating to the processing of personal information, including but not limited to directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations, and secondary legislation, for as long as the GDPR is effective in the UK.
GDPRGeneral Data Protection Regulation (EU) 2016/679
ProcessingCovers all operations and sets of operations that are performed on personal and non-personal data or sets of personal and non-personal data, whether or not by automated means, from its collection, throughout its storage, to its disposal and everything in between inclusively.
Owners, We or UsCurrent legal owners of
User, You or Data SubjectAny third party that accesses this website and is not either employed by the owners and acting in course of their employment or engaged as a consultant to the owners and accessing it in connection with the provision of such services.
Website or SiteThis website you are currently using ( and any of its subdomains unless explicitly excluded by their own privacy policy.
This Document or This Privacy PolicyThe privacy and cookie policy of (This privacy policy you are currently reading.)

2. In this privacy policy, unless the context requires a different interpretation:

  1. The singular includes the plural and vice versa.

  2. References to clauses, sub-clauses, schedules, or appendices are to clauses, sub-clauses, schedules, or appendices of this privacy policy.

  3. References to a physical entity also include legal entities (firms, companies, government entities, trusts, and partnerships, etc.).

  4. “Including” is understood to mean “including but not limited to”.

  5. Headings and sub-headings are not a part of this privacy policy.

  6. The official document starts with the figure one (1) mark (including the mark) and ends at the end of the figure twenty point one (20.1).

Scope of This Privacy Policy

3. We often provide links to various other websites. We have no control of, and cannot be held responsible for the content or policies implemented by the websites that can be accessed from this website, including social media. This document applies only to the actions of the owners and users concerning this website. It is advisable to read the privacy policies of other websites prior to using them.

4. For the purposes of applicable Data Protection Laws, the owners are “data controllers”. This means that the owners determine the purposes for which and the manner in which users data is processed.


5. Like virtually all websites, our website uses so-called cookies to ensure the expected performance of its functions and sufficient administering of said performance. A cookie is a small section of code automatically placed in a user’s browser after they indicate their consent by performing an affirmative action, specified in the notification presented upon entering (a contrary action indicates refusal).

  1. Contradictory to a popular belief, cookies are not tracking software and have nothing in common with spying or invading one’s privacy.
  2. To our knowledge, the cookies we use are anonymous (predominantly analytical). They help us distinguish recurring and new visitors, count the number of visitors and see their interactions with the website (specific pages visited and time spent on them, retention rate, etc.)
  3. Cookies are also used to retrieve information previously entered on our website, to facilitate reuse of this information by the user.

6. Users can also decide whether or not to accept cookies through their internet browser settings. (Doing this may require adjusting preferences every time they visit our website and disrupt the functionality of certain features.)

Most browsers have an option for turning off the cookie feature, which will prevent the acceptance of new cookies, as well as (depending on the sophistication of the browser software) allow to decide on acceptance of each new cookie.

  1. It’s up to our users to delete all cookies that are already on their browsers in their browser settings.

Principles of Data Processing

7. We comply with the principles of GDPR. The six overall guiding principles are as follows:

  1. Lawfulness, fairness, and transparency: obeying the law; only processing personal data in a way that is reasonably expected; openness about data protection practices.
  2. Purpose limitation: under usual circumstances, only processing the data in regards to the reason it was originally collected.
  3. Data minimization: not processing more data than needed.
  4. Accuracy: making sure any data held, is adequate and up-to-date. 
  5. Storage limitation: not storing information for longer than necessary.
  6. Integrity and confidentiality: always processing information securely; not disclosing to third parties under normal circumstances.

Data subjects’ privacy is one of our top priorities. We will always follow these principles and enquire users about their communication preferences.

Types of Data Processed

8. Different personal and non-personal data is collected in different ways:

  1. Provided voluntarily by our users: users provide different types of information while interacting with our website, either on their behalf or on behalf of an organization (commenting, subscribing to newsletter or marketing products, using contact forms, etc.). This information usually falls under the definition of personal data (1).
  2. Collected automatically: as is true for most websites, we, and in some instances, our third-party service providers, collect some technical information about users’ behavior in regards to our website and services. This information is usually anonymous (i.e. non-personal information (1)).

Processing of Acquired Data

9. Under the guides of purpose limitation (7.2) and data minimization (7.3), we must have a good reason for processing any of the personal data in our possession. Including, but not limited to:

  1. Studying visitors’ behavior on our website for the purposes of improving the design, content, functionality of the website, and the quality of services provided.
  2. Subscription-based messages and newsletters, including service messages regarding them.
  3. Informational messages regarding relevant products or services as well as promotional offers, assuming an explicit consent for receiving sich messages has been expressed.
  4. Push notifications and website overlays.
  5. Personalizing the advertising on the website to improve user experience.

Legal Basis

10. Processing of personal information is prohibited unless sufficient legal justification is established. The GDPR (1) allows processing personal information on one of the six legal grounds:

  1. Legitimate interests: processing data subjects’ personal information is in our interests (9), and we have carried out a sufficient legitimate interest assessment.
  2. Public task: carrying out a task that’s in the public interest requires personal data processing.
  3. Contract: contract fulfillment requires personal data processing.
  4. Consent: permission was given or implied in a regulatory compliant approach.
  5. Legal obligation: not processing personal information would mean breaking the law.
  6. Vital interests: data subject’s or someone else’s life depends on personal data processing.

Data Retention

11. The principle of “storage limitation” prohibits retaining personal information for longer than necessary. Different types of data may be retained for different periods depending on their purpose:

  1. Unless a longer retention period is required or prohibited by law, we will only hold users’ data to fulfill the purposes outlined in figure 9, or until you request its deletion.
  2. Even after data deletion, it may persist in backups or archives for tax or regulatory purposes.

Data Sharing

12. We are allowed to share data with third parties, as long as there are sufficient legal grounds for doing so. The types of third-party processors we may share the elements of collected data with include:

  1. Providers of data aggregation and analytics software that enables us to effectively monitor, optimize, and improve the delivery of our services.
  2. Providers of email management and (or) distribution tools.
  3. Providers of security and fraud prevention services.
  4. Payment processors engaged by us to securely store and (or) handle payment information.

Dats Subjects’ Rights

13. Under data protection legislation we are required (subject to certain conditions) to facilitate the following user rights:

  1. Access: the right to request copies of the information we hold about them at any time free of charge (unless the request is “manifestly unfounded or excessive”). On certain grounds, we might refuse the request providing argumentation for doing so.
  2. Rectification: the right to request correction of inaccuracies or incompletions in the data we hold about them.
  3. Erasure (to be forgotten): the right to request deletion or removal of their information from our systems that are accessible to us.
  4. Portability: the right to request their information to be transferred, moved, or copied.
  5. Processing restriction: the right to restrict, or in some instances, prevent us from processing their information.

14. To exercise any of the aforementioned rights or withdraw their consent (where consent is our legal basis for data procession), users need to contact us via our contact form.

  1. In certain instances, the requester’s identity might require verification to prevent unlawful activity or data breaches.
  2. Every right described in this document is subject to circumstances, and may or may not be possible to facilitate with reasonable efforts.

15. It’s the user’s responsibility to make sure the data we hold about them is accurate and up to date during the period for which we hold it. Failure to inform us about changes may result in disruptions of service provision.

Changes of Business Ownership or Control

16. We may expand or sell our business, and this may involve the transfer of all or a part of the data we hold as well as the rights to collecting it in the future:

  1. Collected data will, where it is relevant to any part of the business transferred, be transferred along, and the new owner or controlling party will, under the terms of his privacy policy, be permitted to use and collect the data regarding the purposes for which it was originally collected or supplied.
  2. We may disclose data or parts of it to potential purchasers of our business or any part of it.
  3. In the aforementioned instances, we will ensure the necessary steps are taken to guarantee data subjects’ privacy.


17. Users may not transfer any of their rights under this privacy policy. We may transfer our rights under this privacy policy (16, 12), where we reasonably believe data subjects’ rights will not be affected.

18. If any court or competent authority finds any provision or a part of it invalid, illegal or unenforceable, that provision or sub-provision will, to the extent required, be deleted ant the validity and enforceability of other provisions of this privacy policy will not be affected.

19. Unless otherwise agreed, no act, delay, or omission by any party in exercising any of the rights outlined in this document, will be deemed a waiver of that or any other right.

Changes to This Privacy Policy

20. We will update this document to reflect relevant changes in our services, new projects, or legal requirements. When that happens, the “effective date” at the top of this page will be revised, and the users will be acquainted either by a conspicuous notification on our website or (if possible) a direct notification before they take effect.

  1. Continued use of the website and provided services shall be interpreted as acceptance of new changes, regardless of the readers’ awareness of them.


If you have any questions about the above policy, would like to report a potential data breach, or exercise any of the rights outlined in figure 13, please contact us using our contact form.