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1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors, service users, and clients.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data.
1.4 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.
1.5 In this policy, "we", "us" and "our" refer to IK-IP Ltd.
2. The personal data that we may collect
2.1 In this Section 3 we have set out the general categories of personal data that we process[ and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data].
2.2 We may process data enabling us to get in touch with you ("contact data").[ The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If you log into our website using a social media account, we may obtain elements of the contact data from the relevant social media account provider.
2.3 We may process information contained in or relating to any communication that you send to us or that we send to you] ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.4 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control]. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website, services and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].
3.3 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
3.4 Direct marketing - We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent or our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
3.5 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent or our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.6 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely [ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.8 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.9 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.10 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 Your personal data held in our website database or will be stored on the servers of our hosting services providers.
4.3 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfer of your data
5.1 Our web-hosting parent company, GoDaddy Operating Company, LLC (and related entities, including GoDaddy.com, LLC, Blue Razor Domains, LLC, Starfield Technologies, LLC, Domains by Proxy, LLC, Outright, Inc., Mad Mimi, Inc. and Media Temple, Inc.) participates in and has certified its compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Framework. GoDaddy Operating Company, LLC is committed to subjecting all personal information received from the EU or Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
5.2 Our hosting company GoDaddy.com, LLC is responsible for the processing of personal information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. GoDaddy.com, LLC complies with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.
5.3 With respect to personal information received or transferred pursuant to each Privacy Shield Framework, GoDaddy.com, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, GoDaddy.com, LLC may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
5.4 If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our web hosting service U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
5.5 In compliance with the Privacy Shield Principles, we and our web-hosting service commit to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us in any manner provided in the "CONTACT US" section below in this Privacy Policy.
5.6 Our hosting service GoDaddy.com, LLC has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
5.7 ‘Do Not Track’ notifications.
Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.
5.8 Age restrictions.
Our Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal information, please contact us.
5.9 Non-Discrimination.
We will not discriminate against you for exercising any of your privacy rights. Unless permitted under applicable laws, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. Changes to this policy.
6.1 We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.
7. Data Protection Authority.
7.1 If you are a resident of the European Economic Area (EEA) and believe we maintain your personal information subject to the General Data Protection Regulation (GDPR), you may direct questions or complaints to your local supervisory authority or our lead supervisory authority, the UK's Information Commissioner’s Office, as noted below:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Phone: 0303 123 1113
8. Contact us.
8.1 If you have any privacy-related questions, concerns or complaints about our Privacy Policy, our practices or our Services, you may contact our Office of the DPO by email at support@ik-ip.com. In the alternative, you may contact us by mail as follows: Attn: Office of the Data Protection Officer, IK-IP Ltd, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE. We will respond to all requests, inquiries or concerns within thirty (30) days.
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