Privacy Policy of Business News Daily Website
Introduction
At Savoo UK Ltd (“Savoo”), we take our ethical responsibilities and your privacy seriously by recognizing that your privacy is important. Savoo has a strong commitment to providing excellent service to all its customers, visitors to this Business News Daily web site (the “Web Site”), and other users of our products and services (“Users”), including respecting your concerns about privacy. Please note that this Privacy Policy applies only to this Web Site, products and services provided through the Web Site wherein Savoo is acting as controller regarding to processing of your personal information. This Privacy Policy discloses how we collect personal information on our Web Site, the types of personal information we collect, our use and disclosure of such information, as well as the steps that we take to safeguard your information. Your use of this Web Site is subject to this Privacy Policy (the “Privacy Policy”) in effect at the time of your use. We hope that this disclosure will help increase your confidence in our products and services, and enhance your experience.
Personal information means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a real name, postal address, e-mail address, telephone number, payment information, and account ID (“personal information”). When other information is directly associated with personal information, that information may also be considered personal information. Information that is irreversibly anonymized is not considered personal information.
A subset of personal information Savoo collects is defined as “sensitive personal information” under applicable law, and includes categories as described below.
Personal information we may collect from you:
Savoo collects and generally processes the personal information that you provided us with, directly when you use our Web Site. In particular, we may collect personal information at the following times:
(1) when you register to receive communications from this Web Site,
(2) when you seek information or apply for products and services offered through this Web Site,
(3) when you enter promotions or sweepstakes offered by this Web Site,
(4) when you provide personal information to us through feedback, survey, or other forms hosted on this Web Site,
(5) when you visit our Web Site, including through cookies and clear gifs, as described further below,
(6) when you contact us, and
(7) when you apply for a job with Savoo.
Such personal information may include:
Such personal information may also include the following sensitive personal information: your gender or race if you choose to provide them to us in the context of your application. Sensitive personal information will only be used for the limited purposes specified in this Privacy Policy.
In some cases, Savoo may also collect personal information about you indirectly from third parties or other sources[2] , for the purposes as outlined in this Privacy Policy, namely from your references, a recruiter, your prior employers, and your places of education, service providers and unaffiliated third party marketing companies.
Like other web sites, subject to your consent, we also automatically receive and record certain types of information every time you visit us. We use “cookies” for the Web Site to work but also to help with functionality and performance. [3] More information about cookies can be found in our Cookies section below.
Use made of your Personal Information:[4]
We only use personal information collected through our Web Site when we have a legal basis to do so and for the purposes outlined below.
First, we process personal information for the management of our relationship on the basis of the contract between Savoo and you in order to:
Besides, we rely on your prior consent in order to:
In this regard, please note that you have the right to withdraw your consent at any time (without calling into question the processing previously carried out) by sending a request at the contact details specified at the end of this Privacy Policy.
In addition, we process personal information based on our legitimate interests which consist in:
If you wish to obtain further details regarding our legitimate interests, please contact us by sending a request using the contact details specified at the end of this Privacy Policy.
Finally, we process personal information to comply with the legal obligations to which we are subject, namely tax obligations.
To serve you more efficiently and effectively and subject to your consent, we use “cookies” technology. A cookie is a piece of small text file stored on the user’s terminal equipment when he assesses a web site that contains personal information about the user’s preferences or past actions. Cookies are linked to particular terminal devices over time, but we do not link personal information obtained from cookies to any other personal information we obtain.
If you reject cookies, you may still use our Web Site, but your ability to use some areas of it will be limited. For the exhaustive list of cookies used on our Web Site, their purposes and the related retention periods, please refer to our “About Cookies” page.
If you consented to our use of cookies but later wish to opt out, you may change, at any time, your browser settings in order to block the cookies. For more information about these controls and to exercise your cookie preferences, visit your browser or device’s help material.
In addition, the following links provide instructions in order to manage your cookie preferences:
Clear Gifs
We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs) that help us better manage content on our Web Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movement of web site users. We also use clear gifs in our HTML-based emails to let us know which emails the recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
Who do we share Your Personal Information with?
For the purposes referred to under this Privacy Policy, we share certain personal information to recipients. Such recipients will either act as independent controller or as processor acting on behalf and upon our instructions.
We will share your personal information with BZ Holdings, Inc., which is part of our group and acting as processor.
In addition, we will share your personal information to the following categories of third parties, and/or under the following circumstances described below:
International Transfer of Personal Information
As mentioned above, we may share your personal information to recipients which are located out of the European Economic Area (“EEA”) and the UK, in countries which have not been recognized as having an adequate level of protection.
In this context, we ensure that such transfers are governed by appropriate safeguards in accordance with applicable privacy laws. Such appropriate safeguards may include standard contractual clauses issued by the European Commission (as amended by the UK Addendum issued by the UK Information Commissioner, where relevant) and we will provide you with a copy of applicable safeguards upon request, at the contact details specified at the end of this Privacy Policy.
Retention of your Personal Information[8]
Unless otherwise stated above, Savoo retains personal information only as long as required to fulfill the purposes described above, or as required by law.
Please note that the data retention period actually applied by Savoo may vary, depending on the relevant purpose.
With respect to the services and products provided to you, we will keep your personal information during the period of our contractual relationship extended by the applicable limitation period. With regard to marketing communications with prospects, we will keep your personal information for three (3) years after the last correspondence with us.
With respect to the processing carried out in order to protect or defend your rights, property and security and ours, Savoo will keep your personal information for the time of the relevant dispute or statute limitation period.
As to the processing carried out in order to comply with a legal obligation, we will keep your personal information for the duration of such obligation.
Upon expiry of the applicable data retention period, we undertake to erase or irrevocably anonymize the relevant personal information.
Advertisements & Pop Up Windows
On occasion, you may receive advertisements for Savoo from third parties. These advertisements are served by the third party web site that you have visited or directly from this Web Site. In addition, such advertisements may be placed by third party ad servers or ad networks. We maintain relationships with a number of third party ad networks currently operating. You may find more information on the web site of either the individual ad network or the network advertising initiative. Your relationships, transactions and any opt-in/opt-out requests with any such third party are governed by the specific policy such third party has, and not those of Savoo.
Confidentiality and Security[9]
The security of your personal information is important to us and we take a number of steps to safeguard it:
We limit access to personal information to those employees or agents who assist us in providing requested products and services to you.
Employees are required to comply with our strict policies and procedures regarding the handling of your personal information. Employees who violate these policies are subject to our usual disciplinary process.
We maintain physical, electronic, and procedural safeguards that comply with latest data protection standards to guard personal information about you.
We use industry standard data encryption technologies when transferring and receiving consumer personal information on the Web Site.
You must be at least 16 years old to use this Web Site. We do not knowingly collect, use, or disclose personal information about visitors under 16 years of age. If you are under 16 years of age, you may not use the services offered on our Web Site unless they are used with the consent, permission and supervision of your parents or guardians.
Third Party Links
This Privacy Policy applies to all information that Savoo collects. However, when you visit web sites to which this Web Site provides a link, keep in mind you will be interacting with a third party that operates under its own privacy and security policies, and terms of use. If you choose to obtain certain services through a third party web site, the personal information collected by the third party is governed by that third party’s privacy policy. A third party web site will also have its own policy regarding the use of cookies and clear gifs. We encourage you to review the privacy policies and terms of use of any other service provider from whom you request services.
Your Rights regarding your Personal Information
You have various rights in relation to the processing of your personal information:
In order to exercise any of your rights, or if you have any other questions about our use of your personal information, please send a request at the contact details specified at the end of this Privacy Policy. Please note that we may request you to provide us with additional information in order to confirm your identity.
In any case, you also have the right to lodge a complaint with the competent data protection authority, in particular in the country of your habitual residence, place of work or place of an alleged infringement if you consider that the processing of your personal information carried out by us infringes the applicable privacy laws.
Questions and Suggestions
If you have any questions, concerns or suggestions about our Privacy Policy, you may contact us:
(1) By sending an email to: [contactus@savoo.co.uk]
(2) By sending a letter to:
Savoo UK Ltd
Attn: Customer Service
Third Floor
Lamplighter Works
49-51 Farringdon Road,
London EC1M 3JP
Savoo Data Protection Officer Contact details
Mary Kennedy
dpo@savoo.com
Savoo UK Ltd,
Attn: Data Protection Officer
Third Floor
Lamplighter Works
49-51 Farringdon Rd, London EC1M 3JP
Changes to this Privacy Policy
Savoo reserves the right to update or modify this Privacy Policy at any time. The provisions contained in this Privacy Policy supersede all previous notices or policies regarding our privacy practices. We encourage you to check our Web Site frequently to see the current privacy statement and to be informed of how we are committed to protecting your information and providing you with improved content on our Web Site in order to enhance your online experience. Upon any material changes to the policy statement, we will notify you in this respect. If such change to the Privacy Policy requires your consent, you will have a choice to consent as to whether or not Savoo may use your personal information in this different manner. Our Privacy Policy will indicate the date it was last updated.
[1]Please specify the purpose of such voice recording.
[2]Please specify any other sources from which data originates (privately/publicly accessible sources & types of organization/industry/sector etc.) and the categories of personal information collected indirectly.
[3]This should be consistent with the cookie banner. We remove the reference to advertising cookies as this is not covered in the cookie banner/about cookies. If you are using advertising cookies, this policy and the cookies materials should be modified accordingly.
[4]Please confirm/complete any additional purposes conducted on the legal basis mentioned below.
[5]Please note that this purpose may be considered as too vague by EU supervisory authorities.
[6]We simplified this section as the information are provided in the “About Cookies page”. Please also refer to our email containing recommendations on cookie practices.
[7]This was included in the “Sale of Your Personal Information” section – to be confirmed if this is actually the case here.
[8]It is required to provide information on the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period.
We made suggestions based on the Savoo privacy policy. These periods should be in line your actual practice, please confirm.
[9]This section is included in the privacy policy of Savoo and is market practice. Thus, we suggest to include it (while not strictly required by the GDPR).
[10]Where a consent is collected in relation to the offer of information society services to a child, the processing of the personal data of a child shall be lawful where the child is at least 16 years old.
Where the child is below the age of 16 years, such processing shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child.
In this respect, EU Member States may provide by law for a lower age for those purposes provided that such lower age is not below 13 years.
For harmonization purposes, we suggest to provide for 16 years of age.