PRIVACY & COOKIES POLICY

TIEBREAK SOLUTIONS LTD

1. INTRODUCTION

Tiebreak Solutions Ltd (hereinafter interchangeably referred to as the “Company”, “we”, “us” or “our”) values its relations with you and is committed to ensuring that your personal data is kept safe and at all times.

The provisions within this Privacy & Cookies Policy (the “Policy”) apply to all visitors that receive the intended services of the Company through its website and/or systems (the “Services”).

It is important therefore that you read and understand this Policy together with any other privacy document and/ or notice we post on our website so that you are fully aware of how and why we are using your personal data. 

Scope of the Privacy & Cookies Policy

This Policy sets out what personal data we collect from you and how and why such data is collected and processed. Your personal data can be collected from you in various ways: a. your use of this website, b. by providing any data to us through the Services and c. when you otherwise communicate with us. 

Amendments to this Policy and your duty to inform us of changes to your personal data

This version was last updated in June 2020. This version takes precedent over any other versions. We may amend this Policy and post updates to this Policy on our website. It is important therefore that you regularly check the website but rest assured we will inform you of any changes we consider to be important.

It is also important that the personal data that we hold about you is accurate and current.  Please let us know if your personal data that we hold about you changes. 

2. PERSONAL DATA

What is personal data?

Personal data means any information from which the identity of a person can be made. Any personal data that is collected by the Company through the provision of the Services shall be processed according to the privacy laws, as amended or replaced from time to time, and according to the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).

Collection of Personal Data

We normally collect information that you provide us via our website or when you request to otherwise use our Service including but not limited to our websites. 

Different methods to collect data from you are used and typically involve but not limited to the following:

  • Communications with us; 
  • Website forms and registrations;
  • Physical forms;
  • Social media and social networking;
  • Customer service desk; and
  • Advertisers.

The type of personal data that we may collect from you when you visit our website includes but is not limited to the following: 

  • IP address of the terminal from which you access the Internet;
  • IP address of the website from which you linked directly to our Site;
  • date and time you access our Site; ➢ browser you used to access our Site; and ➢ operating system you used to access our Site.

We store the above information in log files and can use this information to measure the number of visitors to the different sections of our website to help us make our website more helpful to visitors.  We will not obtain any other personally identifying information about you when you simply visiting our website unless you choose to provide us with such information voluntarily. 

The protection of personal data is certain for every individual and therefore such data are processed in a diligent manner that significantly minimizes the risks to breach trust, confidentiality and integrity concerning personal data.

Use of Personal Data

The Company may collect and use your personal data to comply with any legal obligation to which we are subject or in order to protect your interests.  We may also collect and use your personal data for a variety of purposes including but not limited to:

  1. performing obligations under a contract if one exists or in connection with our provision of goods;
  2. responding to emails you send us or any other communication;
  3. verifying your identity; and 
  4. complying with applicable laws, regulations, codes of practice, guidelines or as per directions given to us by any law enforcement body. 

Third Party Links

Our website may contain links to websites operated by third parties. The Company provides these links for your convenience but it does not review, control or monitor the privacy or other practices of websites operated by third parties. The Company is not responsible for the performance of websites operated by third parties or for your business dealings with them.  We urge you to read the terms of use and policies of those third-party websites.

Change of Purpose

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, only where this is required or permitted by law.

Third Country Transfers

Whenever we transfer your personal data out of the EEA, a similar degree of protection is afforded by ensuring the necessary safeguards and safety measures are in place as deemed appropriate under the relevant national or international laws. 

Storage of Personal Data

We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  In case we will store data, it will be for a specific period and we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

When personal data is no longer needed, it will be securely deleted and/or destroyed.

3. COOKIES POLICY

What are cookies? 

Cookies are a kind of short-term memory which is stored, if you agree, in your browser and enables the Services to ‘remember’ little bits of information between pages or visits. 

Use of Cookies

Use of cookies and other tracking technologies are standard across the Services through which personal data is collected. You can however control and manage the use of cookies through the Services and at any time from your browser settings. 

We use cookies to allows us to provide you with a better experience in using our Services. If you do not wish to receive cookies, you may be able to change the settings of the browser or mobile device but doing so will likely impair the quality of the Services and your browsing experience. 

The Company shall not be liable for misuse or loss of personal data resulting from cookies for Services that the Company does not have access to and/or control over.

Consent to Cookies

All websites are now obliged to inform you of the cookies that they use.  Pop-ups are seen when you enter a website for the first time.  You can either accept the cookies to be used or read more about them in policies such as this.  In any event, you can always change the cookie permission settings in your internet browser or mobile device. 

Types of Cookies

There are various types of cookies needed to be used in order to enable the provision of the Services.  This includes absolutely necessary cookies which are necessary to enable basic navigation in our website; performance cookies which are used to improve your browsing experiencing; and, functionality cookies which are used to remember your preferences such as location and language.

Technical Cookies and Cookies serving aggregated statistical purposes: cookies needed strictly necessary for the functioning of the service.  For instance, cookies used to save your session and to carry out other activities that are strictly necessary for the operation of the same, for example in relation to the distribution of traffic.

Activity regarding the saving of preferences, optimization and statistics: Use of cookies to save browsing preferences and to optimize your browsing experience; among these cookies are, for example, those to set the language and the currency or for the management of first party statistics employed directly by the owner of the site.

Other types of Cookies or third-party tools

Some of the services listed below collect statistics in aggregated form and may not require your consent or may be managed directly by you – depending on how they are described – without the help of third parties. If any third-party-operated services are listed among the tools below, these may be used to track your browsing habits, in addition to the information specified herein and without the owner’s knowledge.

Interaction with external social networks and platforms: These services allow interaction with social networks or other external platforms directly from the pages of the Services; the interaction and information obtained are always subject to your privacy settings for each social network; if a service enabling interaction with social networks is installed it may still collect traffic data for the pages where the service is installed, even when you do not use it.

You can control and/or delete cookies as you wish directly from within your own internet browser or mobile device and prevent – for example – third parties from installing them. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. It is important to note that by disabling all Cookies, the functioning of the Services may be compromised. For further information about cookies and how to disable them, please refer to www.allaboutcookies.org.

4. SECURITY

We endeavour to ensure that your personal data is protected.  We strive to protect all data from loss, misuse, unauthorised access or disclosure, alteration, or destruction.  The Company maintains policies and procedures and has measures in place in order to ensure high levels of protection of personal data which include, inter alia, appropriate restrictions on permissions of access to personal information, controls and monitoring of storing and distribution of data as well as Data Protection Impact Assessments.

We shall not however be liable for unlawful or unauthorised use of any personal information due to misuse or misplacement of the passwords, negligent or malicious use.

6. CONSENT

A User by visiting and/or accessing the Company’s website will be required to consent to the present Policy for the collection, maintenance and/or use the personal data as per the present Policy.

7. RIGHTS

You have rights under data protection laws in relation to your personal data.  However, those rights may not be exercised in certain circumstances for example if there is an overriding law and/or regulation. 

You generally, have the right to:

  • Request access to your personal data. This enables you to receive a copy of the personal data, in case we collect such, and to check that we are lawfully processing it.  We can charge a reasonable fee for providing such record of personal data unless we are not permitted to do so under local laws.  We may also need to confirm your identity. 
  • Request to correct personal data. Any incomplete or inaccurate data we might hold about you may be corrected at your request, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure. You may ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing.  You also have the right to object in case we will process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or that is needed further to regulatory or legal requirements. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

8. CONTACT US

For any questions or clarifications you may need, or if you wish to file a complaint, please contact us at info@tiebreaksolutions.com. We aim to respond to all data subject requests within one month but it could take us longer. We will in any event acknowledge your email in the first instance. Whilst you have the right to withdraw your consent for us to use your personal data in the future we may first need to ask you to prove your identity.