Description Of Definitions:
- In this document, “GDPR” refers to the EU’s General Data Protection Regulation.
- “Register of Systems” describes a register of all the systems and contexts through which the Company processes personal information.
- “Responsible Person” is a designated individual, who is in charge of data security inside the Company.
- “Services” refers to all of SSMN LTD’s online services, including this website, and any other channels through which its content is distributed.
- “Usage Data” refers to information collected automatically when users use our Services or interact with our advertising. This data includes your Internet Protocol (IP) address, mobile device identifier or other unique identifiers, browser, and computer type, access time, the URL from which you came, the URL to which you are going, the Web page(s) accessed during your visit, and how you interacted with content or advertising on this website.
- In this document, “We”, and “The Company”, mean SSMN LTD. and its affiliate partners, advertising partners, and other third-party partners.
General Data Protection Practices
The Company is dedicated to fulfilling its obligations under the General Data Protection Regulation (GDPR) with respect to data processing.
According to the requirements listed in Article 5 of the GDPR, personal data must be:
- Processed in accordance with the law, in a fair and transparent manner related to individuals;
- Acquired for necessary, appropriate, and lawful purposes, and then processed in a manner that is in line with those purposes; this does not exclude additional processing for the purposes of public interest archiving, scientific or historical study, or statistical analysis, which should not be seen as incompatible with the original purposes for which the data was gathered.
- Adequate, relevant, and restricted to what is required in light of the purposes for which they are processed;
- Accurate and, if necessary, kept up to date; all reasonable measures must be taken to ensure that personal data that are inaccurate are deleted or corrected without delay, having respect to the purposes for which they are processed.
- Kept for no longer than is necessary for a form that permits identification of data subjects, unless such further storage is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes and the appropriate technical and organizational measures required by the GDPR.
- Processed in a way that ensures adequate security of the personal data, including protection against unauthorized or illegal processing and against accidental loss, deletion, or damage, using suitable technological or organizational methods.
- The Responsible Person shall be responsible for the Company’s continued compliance with this policy.
- This policy shall be reviewed yearly, or more often if necessary.
Legal, Transparent, and Fair Data Processing
- The Company should keep a Register of Systems to guarantee that its data processing is in line with the law, it is fair and transparent.
- At a minimum, the Register of Systems shall be updated once a year.
- Any requests made by individuals for access to their personal information shall be processed promptly by the Company.
- In order for the Company to legally process any information about you, it must have one of the following legal bases: consent, contract, legal obligation, vital interests, public task, or legitimate interests.
- The Company will make a notation in the System Register indicating the applicable legal basis.
- Evidence of opt-in consent should be kept alongside the personal data where this consent is required by the law.
- If communications are delivered to individuals based on their consent, the opportunity for the individual to withdraw their consent (opt-out) should be clearly accessible; measures shall be in place to guarantee such withdrawal is appropriately recorded in the Company’s systems.
Minimizing Data Collected
- The Company shall take reasonable steps to ensure that the data collected is sufficient, relevant, and restricted to what is required in light of the purposes for which it is processed.
- The Company shall take reasonable measures to guarantee the accuracy of personal data, and shall take measures to keep personal data up to date if required for the legitimate basis on which data is processed.
Data Removal / Archiving Policy
- The Company shall implement an archiving policy for each area in which personal data is processed and make a revision of this process yearly to ensure that personal data is kept for no longer than required.
- The archiving policy shall take into account the types of data that need to be kept, how long that data needs to be kept, and why it has to be kept.
- The Company shall use up-to-date security technologies to protect any personally identifiable information.
- Only authorized individuals should have access to sensitive personal information, and there should be protections in place to prevent such data from being improperly shared.
- The deletion of sensitive information must be carried out in a way that renders it permanently unrecoverable.
- The Company shall ensure that appropriate backup and disaster recovery systems are in place.
- The Company should rapidly evaluate the risk to users’ rights and freedoms in the case of a breach of security resulting in accidental or illegal destruction, loss, modification, unauthorized disclosure, or access to personal data.
Information Collected by the Company
What we learn about you from automatic sources:
a. When a user accesses one of our Services, we may collect information about that user’s use of the Services, including the user’s Internet Protocol (“IP”) address, mobile device identifier or another unique identifier, browser and computer type, access time, referring web page, next URL, web page(s) accessed during a visit, and interaction with content and/or advertising on the Services (“Usage Data”).
b. We may get Usage Data and User Information that users have made public on the platform when they share our content on social media.
c. We and our partners also may utilize pixel tags, which are tiny graphic files, to collect Usage Data from users.
d. We and our third-party advertising, affiliate, and analytics partners utilize cookies to store the aforementioned data in users’ local browser cache. This facilitates the collection of Usage Data on repeat visits by associating past actions with those taken during the current and subsequent sessions.
Information Provided By Users
We gather email addresses from people who sign up for our newsletter and keep them in our database. After a comment is posted, we are given access to the commenter’s profile through our partner, Disqus. Users’ name, email, website, and any other information given in the comment is sent to us when users submit an application for a job or send us a message via our Contact page.
Information Gathered From Thrid-parties
Here are some examples of when we could get User Information about you from a third-party (such as advertising or affiliate) partner:
a. When users register with our affiliate partners to make a purchase or take part in a campaign;
b. When users click on ads served by our advertising partners;
c. When users log in to our website using the system of a third-party partner.
How We Use Information?
Here is how data, collected from users is used:
- Usage Data may be shared with our third-party advertising partner, who may then display more relevant adverts to the user.
- We analyze user data in an aggregate (i.e., non-personally identifiable) form to learn about patterns of website traffic. We also use it to hone the site’s content and interface.
- We prepare daily news summaries and transmit them to subscribers using their email addresses.
- Serving ads of third-party advertising companies is how we can afford to keep providing free content. To prevent abuse of our users’ data, we have added restrictions for these partners on how user data can be used. For example, we do not permit these partners to collect user data for use in creating profiles and tailoring advertising on third-party platforms.
For How Long Do We Store Information?
- Any information sent to us through our website’s “Contact” or “Careers” forms will be stored for as long as our business is active.
- If a user doesn’t engage with our site for 36 months, we have our analytics provider, Google Analytics, delete their personal data. After this point, only aggregate data, stripped of any references to specific individuals, will be stored.
How do We Share User Data?
•We do not sell user data to third parties.
• We may share your information with our third-party (advertising, affiliate, and analytics) partners, including in the event that you connect with such partners’ applications and widgets. Sharing this data allows for better site features and/or advertising.
•For the purpose of distributing our daily newsletter, we work with a trusted third party and provide them with access to our users’ email addresses.
• We reserve the right, and the Terms of Usage of this website, to explicitly enable the Company to disclose User Information in the following scenarios:
a. In compliance with a subpoena, warrant, court order, or other legal procedure.
b. To assert, defend, or exercise our legal rights, or to prevent third-party claims from being enforced against us.
c. If we determine that it is essential to do so in order to investigate, prevent, or deal with circumstances involving possible risks to the safety of any person or property, this includes but is not limited to instances of criminal activity, fraud, or other such matters.
d. If we need to conduct an investigation, take preventative measures, or act on a major misuse of the Services infrastructure or the Internet at large, (such as voluminous spamming, denial of service attacks, or attempts to breach the security of information).
e. To prevent harm to the health or safety of our users or the general public and to protect and defend our legal rights or property, our services or their users, or any other party.
Protecting the Rights of Users
Please be aware that by using this site, you are agreeing to abide by our policies. The company’s purpose of collecting, storing, and using data depends critically on users’ willingness to provide their consent.
- Our emails to subscribers always include instructions about how to opt-out. Users may use these instructions to opt-out of getting any future messages from us.
- Please submit an email to firstname.lastname@example.org if you would want us to permanently delete the information you voluntarily provided to us via our “Contact” or “Career” pages, or through our “Subscribe” form.
- The Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”) both have self-regulatory programs for online behavioral advertising, and it’s possible that some of the third-party service providers and/or advertisers are members of these programs. You may learn more about targeted advertising and the “opt-out” processes of NAI members by visiting http://www.networkadvertising.org/managing/opt_out.asp if this seems like something you’re interested in.
- By visiting https://www.aboutads.info/choices/, you can tell us not to use information about your visits to our site to tailor ads to your interests or sign up for email newsletters.
- If you access our Services via an application on your smartphone or tablet, you can download the AppChoices app from your device’s app store (i.e., Google Play, Apple App Store, and Amazon Store).
- You may prevent the DAA’s participating firms from serving you ads based on their predictions about your interests by using this app. Visit https://youradchoices.com/appchoices for additional details.
- Please be aware that using these methods to opt-out will not prevent you from receiving advertisements. You may expect to see the generic adverts whenever you go online or use your mobile device.
While we do our best to protect your User Information, no data transfer over the Internet can be guaranteed to be 100% secure. Nevertheless, we have taken commercially reasonable steps to help protect your Personal Information from loss, misuse, or unauthorized access or disclosure. In accordance with the principles of the General Data Protection Regulation, your use of the website and disclosure of any information is entirely voluntary and at your own risk.
The Services may include links to third-party sites over which we have no control. Video, advertisements, and other content related to our Services may be hosted and provided by third parties. We have no control over the privacy policies of other sites and services.
Privacy of Children
The Services are not designed for, nor may they be used by, anyone younger than 13 years of age. We do not intentionally collect information from or market the Services to minors under the age of 13, nor do we allow them to use the Services. We strongly recommend that parents or guardians accompany their children of any age when they browse the Internet, and we disclaim all responsibility in the event that this is not done.
- In order to achieve this, a notice will be published in the appropriate sections of the Services.
- We will not use your Personal Information, without your consent, in a way that is significantly different from what was disclosed at the time when it was collected.
- This current policy will be reviewed every year, and more often if necessary, or if there is a significant shift in the legal framework governing users’ rights.