Privacy Policy

Privacy Policy last updated on May 24th 2018 to comply with GDPR.

NEREL ONLINE PRIVACY POLICY FOR SUBSCRIBERS AND WEBSITE

GENERAL

This Privacy Policy is applicable to www.cogipas.com a division of Matthew Bailey carrying on business as Nerel Online (“Nerel Online” or “we”) database of subscribers and website visitors.

This Privacy Policy describes how we process personal data of our website visitors as well as the representatives of our subscribers and potential subscribers (all the aforementioned hereinafter “Subscribers”) regarding users visiting our website, subscribing to newsletter(s) and/or posting comments (all the aforementioned hereinafter “Services”).

This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on this page of our website. We will not make substantial changes to this Privacy Policy or reduce the rights of Subscribers under this Privacy Policy without providing a notice thereof.

Please note that this Privacy Policy only applies to processing of personal data carried out by Nerel Online as a data controller. In regard to the data generated by Nerel Online’s subscribers or users when using the Services while using the Nerel Online service in their own business, Nerel Online processes this personal data as a data processor. In such case the relevant subscriber shall be considered to be the data controller.

CONTROLLER’S CONTACT DETAILS

Name: Matthew Bailey cob as Nerel Online

Address: St. Louis, Carriacou, GRENADA (WI)

Email: [email protected]

PERSONAL DATA PROCESSED AND SOURCES OF DATA

We collect two types of information concerning the Subscribers: (i) Subscriber Data; and (ii) Analytics Data. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with Subscriber Data. In such situations, Analytics Data shall also be considered to be personal data under applicable laws and we will treat the combined data as personal data.

Nerel Online may collect and process the following Subscriber Data: (i) name and contact details (including user names where applicable); (ii) e-mail address; (iii) communication history; (iv) data concerning your use of the Services or your interest in our Services; (v) subscriber opt-outs and opt-ins.

Most of the Subscriber Data is received directly from Subscribers in connection with the Subscriber’s use of the Services.

Analytics Data we gather in connection with the use of our Services includes for example the following data: (i) Subscriber’s IP address; (ii) device and device identification number; (iii) operating system; (iv) time of visit; (v) browser type and version; (vi) language settings. (vii) URL route and search history on the page.

Cookies

We use various technologies to collect and store Analytics Data and other information when Subscribers visit our Services, including cookies.

Cookies are small text files sent and saved on your device that allows us to identify visitors of our websites and facilitate the use of our Services and to create aggregate information of our visitors. This helps us to improve our Services and better serve our Subscribers. The cookies will not harm your device or files. We use cookies to tailor our Services and the information we provide in accordance with the individual interests of our Subscribers.

Subscribers may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:

Please note that some parts of our Services may not function properly if use of cookies is refused.

Web analytics services

Our Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.

PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL DATA


Purposes

Personal data is processed by Nerel Online for the following purposes:

To provide our Services and send Subscribers occasional email communications

We process personal data in the first place to be able to offer the Services to our Subscribers and to run, maintain and develop our business. Personal data may be processed in order to carry out Services towards the Subscriber. We may use the data for example to offer essential functionalities of the Services and to provide access to the Services. If Subscriber posts comments, we may use the provided information for replying and/or email communications.

For customer communication and marketing

We may process personal data for the purpose of contacting Subscribers regarding our Services and to inform Subscribers of changes in our Services as well as to market our Services.

For quality improvement and trend analysis

We may process information regarding the use of the Services to improve the quality of our Services e.g. by analysing any trends in the use of our Services. When possible, we will do this using only aggregated, non-personally identifiable data.

Legitimate grounds for processing

We process personal data to perform Services towards Subscribers and to comply with legal obligations. Furthermore, we process personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain Subscriber relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy.

In some parts of the Services, Subscribers may be requested to grant their consent for the processing of personal data; for example, when subscribing to a newsletter or when posting comments. In this event, Subscribers may withdraw their consent at any time.

TRANSFER TO COUNTRIES OUTSIDE EEA

We store personal data in several geographic locations, including areas outside of the European Economic Area. As such, we or our service providers (such as Google) may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or the Subscriber’s domicile.

We will take steps to ensure that the Subscribers’ personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers.

PERSONAL DATA RECIPIENTS

We do not share personal data with third parties outside of Nerel Online’s control unless one of the following circumstances applies:

It is necessary for the purposes set out in this Privacy Policy

To the extent that third parties need access to personal data to perform the Services, Nerel Online has taken appropriate measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.

For legal reasons

We may share personal data with third parties outside Nerel Online’s control if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Nerel Online, our Subscribers or the public in accordance with the law. When possible, we will inform Subscribers about such transfer and processing.

To authorized service providers

We may share personal data to authorized service providers who perform services for us (including data storage, sales, marketing and customer support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy. Please bear in mind that if you provide personal data directly to a third party, such as through a link on our website, the processing is typically based on their policies and standards.

For other legitimate reasons

If Nerel Online is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the protection of personal data. We will give notice to Subscribers concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.

With explicit consent

We may share personal data with third parties outside Nerel Online’s control for other reasons than the ones mentioned before, when we have the Subscriber’s explicit consent to do so. The Subscriber has the right to withdraw this consent at all times.

STORAGE PERIOD

Nerel Online does not store personal data longer than is legally permitted and necessary for the purposes of providing the Services or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.

Subscriber Data relating to your use of the Services are typically deleted within reasonable time after you no longer use the Services. We will store Subscriber’s personal data for as long as the Subscriber is a registered user of our Services and, thereafter, for no longer than is required by law or reasonably necessary for our legitimate interests for example for internal reporting, marketing and reconciliation purposes.

Analytics Data relating to the Services do not automatically expire.

CUSTOMERS’ RIGHTS

Right to access

You have the right to access your personal data processed by us. Subscribers may contact us and we will inform what personal data we have collected and processed regarding the said Subscriber.

Right to withdraw consent

In case the processing is based on a consent granted by Subscriber, Subscriber may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

Subscribers have the right to have incorrect or incomplete personal data we have stored about the Subscriber corrected or completed. You can correct or update some of your personal data through your user account in the Services.

Right to erasure

Subscribers may also ask us to erase the Subscriber’s personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.

Right to object

Subscribers may object to the processing of personal data if such data are processed for other purposes than purposes necessary for the performance of our Services to the Subscriber or for compliance with a legal obligation. In case we do not have legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.

Right to restriction of processing

Subscribers may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Services.

Right to data portability

Subscribers have the right to receive their personal data from us in a structured and commonly used format and to independently transmit those data to a third party.

How to use the rights

The above mentioned rights may be used by sending an e-mail to us on the addresses set out above, including the following information: the full name and email address. The email must be received from the same Subscriber email for verification purposes. We may request the provision of additional information necessary to confirm the identity of the Subscriber. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

DIRECT MARKETING

Notwithstanding any consent granted beforehand for the purposes of direct marketing, Subscriber has the right to prohibit us from using Subscriber’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the Services or the unsubscribe possibility offered in connection with any direct marketing messages.

LODGING A COMPLAINT

In case Subscriber considers our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.

INFORMATION SECURITY

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. Our Services, systems, and other assets are regularly tested by the applicable providers for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of Subscribers, we will inform the relevant Subscribers and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

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