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Privacy policy

PRIVACY POLICY  


 

 

This Privacy Policy was last updated on 25th May 2018 

 

GENERAL PROVISIONS

This website (the “Website”) is operated and owned by Hagshama Keebali Investments Two General Partnership (“HKITGP”, “we”, “us” or “our”).  HKITGP is committed to protecting and respecting your privacy.

This Privacy Policy together with the Terms of Service apply to your use of this Website and any of the services accessible through this Website (the “Services”).   http://grammarist.com/terms-of-service/

This Privacy Policy outlines the method and framework on which any personal data we collect from you, or that you provide to us, will be processed and used by us.

In the course of this Privacy Policy “personal data” (“personal data”, “personal information”) means data relating to natural person who is identified or can be identifiable directly or indirectly, in particular by reference to the data which is provided to us by you or collected by us from you and therefore come into the possession of the data controller, i.e. HKITGP.

We have been making our best efforts in order to comply with Data Protection Law (“Data Protection Law”),  including without limitation applicable US law, European General Data Protection Regulation (“General Data Protection Regulation”, “GDPR”), EU-US and Swiss-US Privacy Shield Frameworks as well other with other relevant data protection rules.

Please take your time to read this Privacy Policy carefully and make sure you understand it.

Your use of this Website is possible only upon your acceptance of this Privacy Policy. If you do not agree with this Privacy Policy, please leave this Website and do not use it.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This Website is not intended for children and we do not intentionally collect data relating to children.

This Website may include links to third-party websites, applications or plug-ins. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

 

 

 

 

INFORMATION WE COLLECT ABOUT YOU

We used to collect from you following personal data: name, email address, computer’s internet protocol (IP) address, username or id in social networks (facebook, twitter).

When processing your personal data we are governed by following principles:

  • personal data is processed lawfully, fairly and in a transparent manner in relation to you;
  • personal data is collected only for specified, explicit and legitimate purposes;
  • personal data is always adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

 

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PURPOSES OF PROCESSING OF PERSONAL DATA

We may process your personal data for a number of different purposes. For each purpose we must have a legal ground for such processing.

Generally such legal grounds are as follows:

  • you have given us explicit consent to the processing of your personal data;
  • processing is necessary for the performance of a contract to which you are the party or in cases you requested us to process your prior to entering into a contract;
  • processing is necessary for compliance with our legal obligation to which we are the subject;
  • processing is necessary in order to protect the your vital interests or of another natural person;
  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority laid upon us as controller;
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

What do we mean when we say “Legitimate Interest” and “Performance of contract”?

Legitimate Interest shall mean our interest as a business in conducting and managing. We hereby confirm that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

DISCLOSURE

We may disclose your personal data if such disclosure is required or permitted by law.

In some cases personal data may be shared with certain third party service providers as well as between our internal departments (engineering, analytics, legal, customer and marketing, etc.) for the purposes specified in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you are resident of the EU please be informed that some of our third parties may be based outside the EU which means that the processing of your personal data will involve a transfer of data outside the EU.

Whenever we transfer your personal data out of the EU, we ensure that at least one of the following safeguards is implemented:

  • we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU;
  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the USA.

If there is neither adequacy decision nor appropriate safeguards implemented we still may transfer your personal data out of the EU due to following justifications:

  • we have been informed you about the possible risks of transfers of your personal data and you has explicitly consented to the proposed transfer of your personal data out of the EU;
  • the transfer is necessary for the performance of a contract concluded between you and us. or if you requested us to perform pre-contractual measures;
  • the transfer is necessary for the conclusion or performance of a contract concluded between us and other natural or legal person for your benefit;
  • the transfer is necessary for important reasons of public interest;
  • the transfer is necessary for the establishment, exercise or defence of legal claims;
  • the transfer is necessary in order to protect your vital interests or interests of other persons in cases where you are physically or legally incapable of giving consent;

Please feel free to contact us in case if you want to get more information on the specific mechanism used by us when transferring your personal data outside the EU.

 

COOKIES

“Cookies” are small pieces of information that are stored by your browser on your device. Like most websites, we use cookies to keep track of your activity and enhance your experience. We also use cookies to assist us in the fight against fraud or malice. If you wish not to receive cookies, you can disable them on of the toolbar of your browser at any time. However, if you do that, you may not be able to access certain areas or features of this Website.

SECURITY

We use reasonable security precautions to protect the security and integrity of your personal data, both during transmission and once we receive it, in accordance with this Privacy Policy and applicable law.  We have been making our best efforts to use all reasonable industry standards to secure your personal data. However, no method of electronic storage or Internet transmission is completely secure, and we can not guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

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