PRIVACY POLICY

The CyNation Privacy Policy was updated on 25 May 2018 [Please note that this Privacy Policy follows current ICO Guidelines]

Your privacy is important to CyNation Limited (CyNation). So, we have developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your information. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions. CyNation may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy. Any changes we make will become effective when we post a modified version of this policy on our website, and we agree the changes will not be retroactive. If you do not agree to any changes, please notify us accordingly to contact@cynation.com. The legend at the top of the policy indicates when it was last changed/updated.

With effect from 25 May 2018, the General Data Protection Regulation (GDPR) enters force. Your rights under that new regulation are explained at https://ico.org.uk/for-organisations/data- protection-reform/overview-of-the-gdpr/. Details of how you can exercise those rights are set out in section 7 of this Privacy Policy. We have largely factored GDPR into this policy but if you think we have failed to do so in any way, please notify us at contact@cynation.com or +44 (0)20 3190 5000.

1. Collection and Use of Personal Information
1.1 Personal information means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
1.2 CyNation is the only legal entity that determines the purposes and the means of processing your Personal Information pursuant hereto.
1.3 What Personal Information we collect:
When you use our website, we collect the following information
• Questions, queries or feedback you leave, including your email address if you send an email to us.
• Your IP address, and details of which version of web browser you used.
• To help gain an understanding of how you use the website, we use cookies and page tagging techniques to help us improve the website. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media.
• Details to allow you access to our services or in any case when you contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, contact preferences, and you’ll always be told when this information is being collected and it will only be used for the purpose for which you provide it.
We may also collect Personal Information which you provide to us when you correspond or communicate with us. If, for example, you call us for professional advice and provide us with Personal Information during that discussion then we may retain that personal data for the purposes of continuing to provide professional services to you.
In the event that you formally engage us to provide professional services to you then we may enter into a further agreement that specifies additional or alternative terms about how we will process your Personal Information.
1.4 How we use your Personal Information:
1.4.1 We collect and use your Personal Information for legal purposes such as the performance of a contract you have entered into any contract with CyNation, for any other legal purpose stated in this Privacy Policy, and any other purpose for which you have given us express consent.
1.4.2 The Personal Information you provide to us allows us to keep you posted on CyNation’s latest product announcements and upcoming events. If you don’t want to be on our mailing list, you can opt out at any time by contacting us at contact@cynation.com
1.4.3 We also use Personal Information to process and deliver customer services and billing.
1.4.4 We do not offer products and services to children, and if we learn that we have collected the Personal Information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
1.4.5 From time to time, we may use your Personal Information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important for your interaction with CyNation you may not opt out of receiving these communications.
1.4.6 Where you consent to us doing so, we may use your Personal Information to send you direct marketing communications. Should you ever choose to ‘opt out’ of receiving such communications we may retain your Personal Information on file to ensure that we do not continue to target you with communications of the type that you have asked us to cease sending to you.
1.4.7 CyNation limits the use of Personal Information to the purposes identified in this Policy and for which the individual has provided explicit consent. In accordance with established policies and procedures, CyNation retains Personal Information only for as long as necessary to fulfil the stated purposes, unless it is required by law for a different period or we have the consent of the individual.
1.4.8 In accordance with established policies and procedures, CyNation will periodically destroy or erase any Personal Information that is no longer needed.
1.5 Collection and Use of Non-Personal Information:
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose.

2. Where we store the data
2.1 We store your electronic data on our secure servers in the United Kingdom, Germany and the Netherlands.
2.2 We store physical data (documents) in our office, Rain Cloud Victoria, 76 Vincent Square, London, which may include some of your data.

3. Protection of Personal Information
3.1 We have procedures and security features in place to try and keep your data secure once we receive it. Those measures are reviewed and updated regularly. To make sure your Personal Information is secure, we communicate our privacy and security guidelines to CyNation employees and strictly enforce privacy safeguards within the company.
3.2 CyNation online forms protect your Personal Information during transit using encryption such as Transport Layer Security (TLS). When your Personal Information is stored by CyNation, we use computer systems with strictly controlled access and which are housed in facilities using physical security measures.
3.3 When you post on CyNation’s forum/blog, chat room, or social networking services, the Personal Information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the Personal Information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

4. Disclosing your Personal information 4.1 Service Providers:
4.1.1 At times CyNation may make certain Personal Information available to strategic partners that work with CyNation to provide products and services to you. Personal Information will not be shared with third parties for their marketing purposes.
4.1.2 CyNation shares Personal Information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your Personal Information in accordance with their privacy policies and procedures.
4.2 Others:
4.2.1 It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence for CyNation to disclose your Personal Information. Where this is the case we will endeavour to give you notice of such disclosures, to the extent that we are lawfully permitted to do so.
4.2.2 We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or other users.

5. Information and Access to data.
5.1 Based on what you have told us, we try to ensure that your contact information preferences are accurate, complete, and up to date. You have the right to request access to and rectification or erasure of Personal Information or restriction of processing concerning your Personal Information or to object to processing as well as the right to data portability. We will comply with erasure requests as long as CyNation is not required to retain the Personal Information by law and does not need to retain it for its legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made by emailing contact@cynation.com
5.2 You can also request other information under the Freedom of Information Act and the Data Protection Act 1988.

6. Cookies
6.1 By using CyNation’s website and/or services, you accept the use of cookies in accordance with our Cookies Policy (https://cynation.co.uk/cookie-policy). If you do not accept the use of these cookies please disable them by following the instructions in our cookies please disable them by following the on-screen prompt when you visit (https://cynation.co.uk), Via our Cookies Policy or change your browser settings so that cookies from this website cannot be placed on your computer, tablet or mobile device.

7. Exercising your rights as a Data Subject
7.1 As a Data Subject you have a number of rights in relation to your Personal Information. These include your rights:
• To ask us to confirm what (if any) Personal Information we hold relating to you and how that data is processed and used by us (often referred to as a ‘Subject Access Request’);
• To have us rectify Personal Information which we hold about you that is inaccurate.
• To have us erase Personal Information which relates to you if it is no longer necessary for us to continue to process it, or if we have no lawful basis to store, process or retain it (though we do have rights to refuse these requests in certain situations).
• To have us provide you with a copy of your Personal Information for transfer to an alternative provider of similar services.

7.2 Should you ever wish to exercise one or more of these rights you should contact us at contact@cynation.com or +44 (0) 20 3190 5000.

8. Privacy Questions/ Compliance Procedures
8.1 CyNation monitors compliance with its privacy policies and procedures and has procedures to address privacy-related complaints and disputes. In this regard, individuals may address their privacy related concerns by contacting us at contact@cynation.com or +44 (0) 20 3190 5000
8.2 CyNation shall respond to all inquiries, concerns and/or complaints about its Personal Information handling practices. The regulatory body in the United Kingdom that oversees CyNation’s handling of Personal Information is the Office of the Information Commissioner. For more information, please visit https://ico.org.uk/.
8.3 Every privacy-related complaint will be acknowledged, recorded and investigated, and the results of the investigation will be provided. If a complaint is found to be justified, appropriate measures will be taken including, if necessary, amending our privacy policies and procedures.

United Kingdom

contact@cynation.com

+44 020 3190 5000

The Rain Cloud Victoria
76 Vincent Square
London, SW1P 2PD

Netherlands

contact@cynation.com

+31 20 894 3404

The Hague Security Delta
Wilhelmina van Pruisenweg 104
2595 AN Den Haag

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