This policy was last updated on 13/03/2019
About this policy
This policy explains how we collect and use personal data from and about visitors to our website.
As we make changes to our website, we may need to update this policy. If we make any important changes that affect your rights and interests, we will make sure we bring this to your attention and explain what this means for you.
If you have any questions in relation to this policy or wish to exercise any of Your rights under data protection law, you should email firstname.lastname@example.org
Who we are
This website is operated by Amdaris Group Limited (trading as Amdaris). We are a limited company registered in England and Wales under company number 10485133. We are registered as a controller in relation to personal data with the UK Information Commissioner’s Office under number ZA220379.
This policy is also issued on behalf of Amdaris S.R.L. (Moldova office) and Amdaris Romania S.R.L. (Romania office) and when we refer to we and us, we are referring to the relevant entity responsible for handling your personal data.
The data we collect about you
Personal data means any data that identifies or can be used to identify a person. It does not include data where the identity has been removed (anonymous data).
You may provide the following kinds of data to us:
- your name and contact details when you complete our callback form
- the content of any messages you exchange with us by email or online chat and any posts and messages directed to us on social media
We may collect the following kinds of data about you:
- the IP address assigned to you or to someone who provide you with Internet access
- the unique identifier of the device used by you to visit our website
- technical data about the device used by you to visit our website including the type of device, operating software, browser and browser plug-ins and the screen resolution and time zone setting of your device
- data about how you browsed and searched our website including how you arrived at our website, the time and frequency of your visits, the time spent by you on each page, how you interacted with the website, the links that you click, documents you download and content that you view
- your location (if you grant us access to it, though the IP address assigned to you or to someone who provides you with Internet access may indicate the country from which you have visited our website)
How your data are collected
How we use your data
We will use the personal data you provide to us, including your contact details, to respond to your enquiries and requests. By providing your personal data to us for these purposes, you will be treated as giving your consent to us using your data for these purposes.
We use data gathered using analytical tools to understand where traffic to our website comes from and how visitors use our website so that we can improve and optimise it. We do so based on our legitimate interests in the effective management of our website and promotion of our services (which we have concluded are not overridden by the impact on your privacy or other rights).
Who we share your data with
Personal data collected through our website is collected by Amdaris Group Limited. However Amdaris may need to share such data and other information with its offices in Moldova and Romania in other to respond to your enquiry.
Personal data collected through our website may also be shared with:
- service providers including our hosting provider, CRM platform (WordPress) and analytics providers (Google)
- any third parties to whom we may choose to sell, transfer or merge parts of our business or assets or third parties we may seek to acquire or merge with (if any change happens to our business, the new owners may use your personal data in the same way as set out in this policy)
Where your data are stored
Many of the service providers that we use in connection with our website and the services provided through it are based outside the European Economic Area (EEA) which means that your personal data may be transferred outside the EEA, in particular, the USA. Whenever we transfer your personal data outside the EEA, we ensure that a similar degree of protection applies to your personal data in one or more of the following ways:
- the country to which your personal data is transferred is deemed by the European Commission to provide a similar degree of protection for your personal data
- we have entered into a specific contract with our service providers in a form that has been approved by the European Commission as providing a similar degree of protection for your personal data
- where any service provider is based in the US and they have self-certified under the EU-US Privacy Shield Framework which requires them to provide a similar degree of protection for your personal data
Google (in respect of its analytics tools) is self-certified under the Privacy Shield framework.
We have entered into a contract with Amdaris S.R.L. (Moldova office) in a form that has been approved by the European Commission for the transfer of personal data between us.
How we keep your data secure
We have put in place appropriate security measures (for example, access to our website us secured using ‘https’ technology) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those within our organisation that have a need to access it. They will only process your personal data on our instructions and they are required to keep your personal data confidential.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner’s Office or any other relevant regulator where we are legally required to do so.
How long we keep your data for
We will only keep your personal data for as long as necessary in connection with the purposes we collected it for and to comply with any legal, accounting or reporting requirements. To determine how long we keep your personal data for, we consider the amount, nature and sensitivity of the personal data, the purposes for which it was collected and the potential risk of harm from us continuing to keep it.
We will retain personal data relating to your enquiries with us for 12 months unless your organisation becomes a customer, in which case such enquiries will be retained for 25 months.
We will retain personal data relating to email marketing data (see Marketing) until you unsubscribe or your email address has become permanently unavailable.
We will retain the analytical data collected about your use of our website for a period of 25 months.
We may retain any data that does not identify you indefinitely.
Cookies are small text files that are stored on your device and contain a uniquely generated reference which is used to distinguish you from other individuals each time your visit our website. None of the cookies used on our website store data that can directly identify you.
You can read more information cookies and how they work at All About Cookies.org and information about how online advertising works at Your Online Choices (these are third party websites that do not control). [You can manage cookies by changing your Cookie preferences at any time].
The cookies used by our website fall into the following categories:
- Strictly necessary cookies: These are required for the effective and secure use of our website to include enabling you to send messages to us securely
- Analytical cookies: these are used to recognise when you visit our website and how you interact with it so that we can improve the way our website works
- Functionality cookies: these are used to recognise when you visit our website so that we can personalise our content for you and remember your preferences
- Targeting cookies: these are used to monitor the effectiveness of our online advertising campaigns and deliver advertising about our services to you elsewhere on the web
We are required to obtain your consent to all cookies except those that are strictly necessary. You will be asked to confirm your consent when you first visit our website.
Alternatively, you can clear cookies after you visit our website, use a tracking blocker such as Privacy Badger or, for the analytical cookies stored by Google, install the Google Analytics opt-out extension.
The specific cookies used by our website are as follows:
|_cfduid||Strictly necessary||2 years||This cookie is set by the CloudFlare service to identify trusted web traffic.|
|Google Analytics||Analytical||2 years (_ga);
1 minute (_gat);
24 hours (_gid)
|This cookies are set by Google Analytics to identify and remember visitors to our website, referral sources, page views and session duration. For further information, see Google’s guidance on cookie usage.|
If you block or restrict cookies, you may not be able to use certain features of our website.
We use HubSpot to manage our email marketing campaigns. This tool is integrated with Google Analytics so that we can track whether you click any of the links contained in our emails. This helps us to understand what the recipients of our emails have found interesting and to personalise the content of emails that we may send to you in the future.
HubSpot also uses tiny invisible images called ‘pixels’ that are contained within emails to enable us to see:
- whether you opened an email
- where in the world the device used to open the email was located (based on your device’s IP address)
- the type of email client used to open the email
- whether you shared the email on any social media platforms
- whether you marked the email as spam
- your overall level of engagement with our email marketing campaigns.
We use this data to improve the format and quality of our email marketing campaigns.
You have the right to withdraw your consent to marketing at any time either by contacting us or clicking the unsubscribe link in any email.
You have a number of rights in relation to the personal data we hold about you. Some of these rights depend on certain conditions being met and you can read more about this on the ICO’s website.
The rights that you have are:
- Access: You have the right to request access to and be provided with a copy of the personal data held about you together with certain information about the processing of such personal data to check that are holding it lawfully
- Correction: You have the right to ask us to correct any inaccurate or incomplete personal data held about you
- Deletion: You have the right to ask us to delete or remove any personal data held about you where there is no good reason for us to continue holding it or where you have exercised your right to object
- Restriction: You have the right to ask us to restrict how we hold your personal data, for example, to confirm its accuracy or our reasons for holding it
- Objection: You have the right to object to our holding of any personal data about you and to object to our holding your personal data for direct marketing purposes
- Portability: You have the right to receive or request that we transfer a copy of the personal data we hold about you in an electronic format
- Complaints: You have the right to complain to the (ICO) or any other EU supervisory authority in relation to how we collect and use your personal data
You will not have to pay any fee to exercise any of the above rights though we may charge a reasonable fee or refuse to comply with your request if any request is clearly unfounded or excessive. Where this is the case, we will let you know.
To protect the confidentiality of your personal data we may ask you to verify your identity before fulfilling any request in relation to your personal data.