Privacy Policy

Last updated: Jun 14, 2019

Who Are We

Concurnas Ltd. ("Concurnas", "we", "us" or "our") operates on different websites and is committed to respecting your privacy on all of our websites where this Privacy Policy is posted (collectively, the "Sites") and the products and services offered on these websites (collectively, the "Services").

This Privacy Policy sets out the basis on which the personal data we collect about you, or that you provide to us, will be used by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

What Personal Data Do We Collect?

The personal data that we collect when you visit our Sites or use our Services, may include the following:

  • Information you provide to Concurnas - we collect data that you choose to provide to us when you are using our Services and that can be used to contact or identify you. Personal data may include your name and email address.
  • Information automatically collected - whenever you visit or interact with the Sites, we automatically collect data about your visit. Such information includes your computer's Internet Protocol ("IP") address, browser type, browser version, the pages you visit, the time and date of your visit, the time spent on those pages and other statistics. We gather such information through cookies and other web technologies. See also 'The use of cookies' to find out more. Concurnas Services do not automatically collect personal data.
  • Information from third parties - Sometimes the Sites may permit interactions with third-party websites, such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Services' functionality.

Purposes For Which We Use Personal Data

We collect and use your personal data for the purposes described below and on the following lawful bases:

  • For the performance of our agreement with you - We collect personal data for the purpose of providing the Services, in order to manage and handle your purchase orders, for the purpose of identifying and communicating with you and to respond to your requests or inquiries.
  • For our legitimate interests as a business when those interests are not overridden by your interests, fundamental rights or freedoms - Our legitimate interests to analyse visits to and use of the Sites to improve and develop our Services as well as to understand our customers both on aggregated and on individual basis. This also means that we analyse your use of Services and use this information to improve our Services and to give you a better experience (e.g. we analyse what webpages you visit, which Services you use and like and how you use these Services, which enables us to create personal profiles and to assess what may be interesting to you, which recommendations we can give you when you purchase our Services). Creating such personal profiles of our customers, enables us to send you marketing materials that directly relate to your use of Services, if you have chosen to receive such materials. With respect to our customers who purchased one of our Services, we may send marketing material regarding similar Services. We may also enrich your personal data to ensure the security of our Services; to prevent fraud, hacking, cheats and spamming; and to facilitate our response to legal processes (e.g., a court order, warrant or subpoena).
  • Based on your consent - We use your personal data based on your consent when you sign up to receiving our newsletters, marketing or promotion material and other information that may be of interest to you through our Sites or otherwise expressly consent to the use of your personal data. You can withdraw your consent at any time by sending an email to [email protected] or by opting-out by following the opt-out instructions in the relevant marketing communication.

Who We Share Your Personal Data With

We do not share your personal data other than described in this paragraph:

  • Service Providers and processors - We engage third party companies, individuals and affiliated entities to facilitate our Services and to provide the Services on our behalf, to perform Service-related services, to assist us in analysing how our Services are used, data storage and other services. These third parties have access to your personal data only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.
  • Third parties in case of legal requirement - We will also disclose your personal data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law or breaches of security; to respond to any claims against us; and, to protect the rights, property, or safety of Concurnas, our customers, or the public.
  • Third parties with consent - We will also disclose information about you, including personal data to any other third parties, where you have expressly consented or requested that we do so.
  • Third parties in case of a corporate transaction - In addition, your personal data may be disclosed as part of any merger, sale, reorganization, transfer of Concurnas's assets or businesses, acquisition, bankruptcy, or similar event.

Security

In order to protect your personal data we have implemented reasonable, commercially acceptable security procedures and practices appropriate to the nature of the personal data we store, in order to protect it from unauthorized access, destruction, use, modification or disclosure. Your personal data is contained behind secured networks and is only accessible by a limited number of people, who have special access rights and are required to keep the information confidential.

Please keep in mind that no website or Internet transmission is completely secure. Therefore, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe, such as closing your web browser when finished using the Sites.

Children Under The Age Of 16

Our Services do not typically address anyone under the age of 13. Therefore, we do not knowingly request or collect personal data from children younger than 13 years of age, without parental consent. If you believe that we may have unintentionally collected personal data from a child under 13, please contact us (see below 'How you can contact us') so that we may take appropriate steps to delete such information.

If you are at least 13 years of age but under the age of 16, we need the consent of your parent or legal guardian before you give us any personal data about yourself.

Use Of Cookies

We and our third party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, and use of the Services. We may combine this “activity information” with other personal data we collect about you where permitted by law.

Generally, we use this activity information to understand how our Services are used, track bugs and errors, improve our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes. For more detailed information about these mechanisms and how we collect activity information, see our Cookie Policy.

Data Retention

We will generally retain the personal data we processed through our Sites and Services for as long as it is required for purposes for which the data were collected. Unless we inform you otherwise, this will usually be the period of 3 years after the last interaction with you plus the length of any applicable statutory retention period following such activity.

International Transfers

Your personal data may be transferred to -and maintained on- computers located outside of your state, province, country or governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside the USA, please note that the information you provide (as described above under "What Personal Data We Collect") will be transferred to the USA, where the level of data protection may not be equivalent to the level of protection applicable at your location.

Where we are legally required to do so, transfers of personal data to parties outside the EU/EEA may be made pursuant to the European Commission-approved Standard Contractual Clauses or other legally acceptable mechanisms that ensure an adequate level of protection. Where applicable, you are entitled to receive a copy of the relevant contract (such as Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your personal data during such transfer.

Your Rights

We will take steps in accordance with applicable legislation to keep your personal data accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal data corrected (that is, rectified). You also have the right to request access to your personal data and to obtain a copy of it as well as additional information about the processing and to request us to erase the personal data we hold about you. In cases where we rely on your consent for using your personal data, you can withdraw such consent at any time by sending an email to: [email protected]

The following rights apply in addition to the above to European residents:

  • Right to restriction: you have the right to restrict the processing of your personal data, for example in case we no longer need your personal data in view of the initial purposes but they are required by us for the establishment, exercise of defense of legal claims.
  • Right to object: you have the right to object to our processing of your personal data which is based on our legitimate interests. We will no longer process your personal data upon your request, unless we have compelling legitimate grounds for the continuation of the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims. You may also object to our use of your data for direct marketing purposes. To that end, you may also use the unsubscribe button provided for in every email we send.
  • Right to data portability: under circumstances, you have the right to have your personal data transmitted to another data controller in a structured, commonly used and machine-readable format.
  • Right to obtain a copy of personal data safeguards used for transfers outside your location: you can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Union. We may redact data transfer agreements to protect commercial terms.
  • Right to lodge a complaint: in case you have a question or complaint about how we process your personal data, you can send an email to [email protected]. It is also a possibility to lodge a complaint with a supervisory data protection authority.
  • If you reside in France, you also have the right to issue directives relating to your digital legacy.
  • Concurnas does not, and does not intend to, sell personal information as “selling” is defined under the California Consumer Protection Act (“CCPA”). California residents who wish to submit requests for information pursuant to Sections 1798.110 and 1798.115 of the CCPA may do so by emailing [email protected]

For further information regarding your rights, or to exercise any of your rights, please contact us at [email protected] or see section ‘How you can contact us’ for more details. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Canadian Anti-Spam Legislation

If you are a Canadian resident we have the right to send you commercial electronic messages ("CEM's") under certain conditions. We are committed to ensuring that all applicable recipients of our CEM's receive them in a manner that is consistent with Canada's Anti-Spam Legislation. We will continue to send CEM's to applicable recipient in the following contexts:

  • You have provided us with your email address directly without indicating a desire not to receive CEM's.
  • You have published your email address online or otherwise.
  • You have explicitly informed us (verbally or otherwise) that you are interested in continuing to receive CEM's.
  • You have a business relations with us.
  • A third-party with whom you may have an existing relationship has referred us to you.

In the event you no longer wish to receive CEM's from us, email us at [email protected] or reply to the electronic message / email address sent to you with the word "Unsubscribe", you may also use the unsubscribe button provided for in every email we send. Our CEM's also contain information on how to unsubscribe from receiving CEM's. Your request will be processed as soon as possible, and no later than ten (10) days after you send the request.

How You Can Contact Us

If you have any questions or concerns about this Privacy Policy or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at [email protected].

Links To Other Websites

For your convenience and to improve the usage of the Sites we insert links to third parties, for which this Privacy Policy does not apply. These links take you outside our service and off the Concurnas Sites and are beyond our control. The sites you can link to have their own separate privacy policy and although we seek to protect the integrity of our Sites, Concurnas is not responsible and cannot be held liable for the content and activities of these sites. Your visit/access to these sites is therefore entirely at your own risk. Please note that these other sites may send their own cookies to users, collect data or solicit personal data.

Changes To The Policy

This Privacy Policy may be revised from time to time. If a fundamental change to the nature of the use of your personal data is involved or if the change is in any other manner relevant to you, we will ensure that information is provided to you well in advance of the change actually taking effect.