Privacy policy

Effective as of 16.05.2018 SPD-Group and subsidiaries, (collectively “we” or “us” or “our”) have updated our Privacy Policy (“Policy”).


1. Introduction


This Policy details our commitment to protecting the privacy of individuals who visit our Websites (“Website Visitors”). For the purposes of this Policy, the term, “Websites”, shall refer collectively to


2. Scope Of This Policy


In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity. The use of information collected through our Service shall be limited to the purpose of providing the Service for which the Customers has engaged.

Our Websites may contain links to other websites and the information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

We collect information under the direction of our Customers and have no direct relationship with individuals whose personal information we process in connection with our Customer’s use of our Services. If you are an individual who interacts with a Customer using our Services (such as a customer of one of our Customers) and would either like to amend your contact information or no longer wish to be contacted by one of our Customers that use our Services, please contact the Customer that you interact with directly.


3. Information That You Provide To Us


We ask for and may collect personal information about you such as your name, phone number, email address, instant messaging ID, as well as certain related information like your company name and website name.

We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys or otherwise communicating with us.


4. Information That We Collect From You on our Websites


Cookies and Other Tracking Technologies:

We may use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites.

We partner with third parties to either display advertising on the Websites or to manage our advertising on other sites. Our third party partners may also use technologies such as cookies to gather information about your activities on our Websites and other sites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union you may opt-in the use of cookies, by clicking here).

Web beacons, tags, and scripts may be used on our Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

We use Local Storage Objects (“LSOs”) such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LSOs. Third parties with whom we partner to provide certain features on our Websites or to display advertising based upon your Web browsing activity use LSOs such as HTML5 and Flash to collect and store information. For further information on how to manage Flash LSOs please click here.


As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.


We collect analytics information when you use the Websites to help us improve them. We may also share anonymous data about your actions on our Websites with third-party service providers of analytics services. We do not link the information we store within the analytics software to any personally identifiable information.


5. Information Collected From Other Sources


Social Media Widgets:

The Websites include social media features, such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information From Third Party Services:

We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, we may have access to certain information from a third party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), current city, profile picture URL, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services. For example, you can log in to the Services using sign-in services such as Facebook Connect or an OpenID provider, as further described below.

Single Sign-On:

You can log into certain Services using sign-in services such as Facebook Connect or an OpenID provider. These services will authenticate your identity, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities in the Services to your profile page to share with others within your network.


6. How We Use Information That We Collect


We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to
(a) provide, operate, maintain, improve, and promote our Services;
(b) enable you to access and use the Services;
(c) process and complete transactions, and send you related information, including purchase confirmations and invoices;
(d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
(e) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;
(f) investigate and prevent illegal activities;
(g) personalize the Websites and Services; and
(h) for other purposes for which we obtain your consent.


7. Sharing Of Information Collected


Third-Party Service Providers:

We do not share personal information with third parties constantly. However, in some cases, we can do this solely to provide you with services and to ensure the security and safety of your information. We can share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

With Your Consent:

We may also share personal information with third parties when we have your consent to do so.


8. How Long We Retain Your Personal Information:


We will retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

For personal information that we process on behalf of our Customers, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.


9. Your Privacy Rights


Except for the terms, set forth above in this Policy, you have the following privacy rights. Please read them carefully!

The right to object

You have the right to object to:
processing of information, based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
-direct marketing (including profiling); and
– processing for purposes of scientific/historical research and statistics.

The objection has to be based on grounds relating to your particular situation. You can send the objection online via [email protected].

The right of access.

You have the right to access your personal data. The reason to access your personal data is so that you are aware of and can verify the lawfulness of the processing. We may verify the identity of the person making the request, using reasonable means. If the request is made electronically, we shall provide you with the information in a commonly used electronic format. You have the right to obtain:
confirmation that your data is being processed; access to your personal data; and other supplementary information – this largely corresponds to the information that should be provided in a privacy notice.

The right to rectification

This means the right to have inaccurate personal data rectified, or completed if it is incomplete. Personal data is inaccurate if it is incorrect or misleading as to any matter of fact. In certain circumstances, we can refuse a request for rectification.

The right to erasure

You have the right to have your personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances, for example:
-the personal data is no longer necessary for the purpose which we originally collected or processed it for;
-you withdraw your consent for processing personal information;
-we have to do it to comply with a legal obligation;
-we have processed the personal data to offer information society services to a child, etc.

The right to restrict processing

When processing is restricted, we can store the personal data, but not use it. You can make a request for restriction. This is an alternative to requesting the erasure of your data. The personal information can be restricted by:
-temporarily moving information to another processing system;
-making the data unavailable to users; or
– temporarily removing published data from a website.

The right to data portability

This right means that you can obtain your personal information from us and reuse it for your own purposes – to move, copy or transfer personal data easily from our site to another sites or services. We shall provide the personal information in a structured, commonly used and machine-readable form. Machine-readable means that the information is structured so that software can extract specific elements of the data. This enables other organizations to use the data. If you want it, we may transmit the personal information directly to another organization (site or service) if this is technically feasible.

We don’t use automated decision making (making a decision solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain things about an individual) systems.

What are the rules for submitting requests and considering them?

You can make the requests with regard to the rights set forth above, verbally or in writing. Requests will be handled within thirty (30) days. The period of compliance can be extended by a further two months where requests are complex or numerous. If this is the case, we shall inform you within one month of the receipt of the request and explain why the extension is necessary.

Where requests are manifestly unfounded or excessive, in particular, because they are repetitive, we may charge a reasonable fee taking into account the administrative costs of providing the information or refuse to respond.
If we refuse to respond to a request, we will explain the reason of that and inform you of your right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month. Anyway, we shall explain our decision and inform you of your rights.

An individual who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete personal information stored or processed by us on behalf of a Customer should direct his/her query to the Customer (the data controller).

We will retain personal information that we store and process on behalf of our Customers for as long as needed to provide the Services to our Customers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at [email protected]


10. Children’s Personal Information


We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Websites or Services, please contact us at [email protected], and we will use commercially reasonable efforts to delete that information.


11. Changes To This Policy


If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Websites or the Services constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Websites and the Services.


12. Contact Us


If you have questions regarding this Policy or about the SPD-Group privacy practices, please contact us by email at [email protected].