Client Privacy Policy

Updated: June 15, 2018

This privacy policy gives you information on how we collect and process your client data through your use of our site:  This site is NOT intended for children and we do NOT knowingly collect data relating to children.

Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:

Background data, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), publications or news you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your client data but is not considered client data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your client data so that it can directly or indirectly identify you, we treat the combined data as client data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Client data about you.

Where we need to collect client data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Client data means any information about an individual Client and/or Client Representative from which that person can be identified. It does not include data where the identity has been removed.

We may collect, use, store and transfer different kinds of client data about your firm which we have grouped together follows:

  • Client Identity data – name (includes first, last, maiden and married names), Business name, Client id, and username.
  • Client Contact data - postal address, email address and telephone number.
  • Client Profile data - includes your username and password, purchases or orders made by you as Client, your interests, preferences, feedback and survey responses.
  • Client Financial data includes bank account, and payment card details.
  • Transaction data includes details about payments to and from you and other details of products and services you have purchased from us as a Client.
  • Technical data includes internet protocol (IP) addresses, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage data includes information about how you as Client use our site, products and services.
  • Marketing and Communications data includes your Client preferences in receiving marketing from us and our third parties and your communication preferences
  • Information we receive from other sources. We work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers).

We use different methods to collect data from and about you including through direct interactions - You may give us your Client Identity data, Contact data and Financial Data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes Client data you provide when you:

  • Apply for our products or services;
  • Enter you contact data or Identity data
  • Create an account on our site;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Give us some feedback.

When you as a Client interact with our site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this client data by using cookies, and other similar technologies.

We may receive client data about you from various third parties and public sources as set out below:

  • Analytics providers such as Google
  • Advertising networks
  • Search information providers
  • Contact data, financial data and transaction data from providers of technical, payment and delivery
  • Client identity data and contact data from data brokers or
  • Client Identity data and contact data from publicly availably sources

We will only use your client data when the law allows us to. Most commonly, we will use client data in the following circumstances:

  1. Where we need to perform the contract we are about to enter into or have entered into with you.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  3. Where we need to comply with a legal or regulatory obligation.

We use site cookies to distinguish you from other users on our site. This helps us to understand the profile of our Clients, estimate visits to our site and click through for specific campaigns. Cookies also help us to provide you with a good experience when you browse our site and they also help to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer.  Cookies contain information that is transferred to your computer's hard drive. By continuing to browse the site, you are agreeing to our use of cookies.

  • Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognize you when you return to our site. This enables us to personalize our Client content for you, greet you by name and remember your preferences (for example, your choice of language or region).

The session cookie which has info that can lead to who the Client is (i.e. "Strictly necessary cookies"), expires at the end of the browsing session.  However, we have three other cookies (on the main site – that do NOT expire.  Those cookies are:

  1. Language setting (i.e. Functionality cookies), so the next time you come back we know which language you were last looking at to give you the same language again
  2. A cookie related to Google API for logging in with Google+ to our site.
  3. A visitor tracking cookie (Analytical/performance cookies) to determine if the Client is a new visitor or Client who has previously visited the site before.

Lastly, we do NOT use targeting cookies.  We don't track behavior and we don't use your browsing habits to determine what you like or send advertisements to you.  We also NEVER share any info with 3rd parties. 


Any changes we make to our Client Privacy Policy in the future will be posted on this page.