The policy set forth below is provided in English only to avoid any misinterpretations caused by a language translation. If necessary, please seek the proper advice, or please do not use this web site.
Last Updated on March 12, 2020
Profiles and inferences: inferences drawn from any of the above used to create a profile reflecting an individual’s preferences, behaviours or other characteristics.
Overview of Our Collection and Use of Personal Information: While the actual information we collect and our use of such personal information varies depending upon the nature of our relationship and interactions with an individual, the table below provides a general overview of the categories of personal information we collect and the purposes for which we use such information. Where required by law, we obtain your consent to collect certain categories of personal information. To learn more, please see Section 15 below.
Categories of personal information We Collect
Use of personal information
Name, contact information and other identifiers: such as name, contact information IP address and online identifiers.
Providing support and services
Customer Records: paper and electronic records containing personal information, including without limitation, name, signature, photo, contact information, education and employment history, government identifiers, insurance policy number, financial or payment information.
Protected classifications: characteristics of protected classifications under applicable law, such as race, colour, sex, age, religion, national origin, disability, citizenship status.
Commercial Information: including records of real property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
Usage data: internet or other electronic network activity Information including without limitation browsing history, search history, and information regarding an individual’s interaction with our Services or an advertisement.
Geolocation data: precise location information about a particular individual or device.
Audio, video, and other electronic data: such as, video footage, photographs, call recordings, and other audio, electronic, visual, or similar information.
Employment history: professional or employment-related information.
Education information: education information and records.
Profiles and inferences: inferences drawn from any of the above used to create a profile reflecting an individual’s preferences, behaviours or other characteristics.
Individual rights. Please see Your Rights and Choices in Section 10 below for a description of the choices we provide and the rights you have regarding your personal information.
This privacy notice applies to our collection, use, disclosure, and other processing of personal information related to:
Our collection, use, disclosure, and processing of personal information about individuals will vary depending upon the circumstances. This privacy notice is intended to describe our overall policy data protection practices. I some cases, different or additional notices about or data collection and processing practices may be provided and apply to our processing of certain personal information.
Personal information. In this privacy notice, out use of the term “personal information” includes other similar terms under applicable privacy laws such as “personal data” and “personal identifiable information”. Unless otherwise specified, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a particular individual.
Not covered by this notice. This privacy notice does not apply to our employees and non-employee workers.
We collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that we deem mandatory, we may not be able to access certain Services or we may be unable to fully respond to your inquiry.
Sources of personal information we collect. The personal information that we collect and process will vary depending upon the circumstances. We collect personal information directly from individuals, automatically related to the use of the Services, and in some cases, from third parties (such as social networks, platform providers, data providers and operators of certain third-party services that we use). For example, some of the ways that we collect information are as follows:
Information we collect directly. We collect information that you voluntarily provide us, such as
Information we collect form third parties. We may collect personal information about you and your property from third party sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected), from brokers and independent agents, and from other third parties. For example, without limitation:
Certain laws, including the Electronic Transactions Act, 2000 (“ETR”), requires that we inform applicable individuals of the legal bases for our use and other processing of personal information. Pursuant to the ETR (and other relevant laws), we process personal information for the following legal bases:
While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below. Where ETR or other relevant laws apply, we have set forth the legal bases for such processing in parenthesis (see above for further explanation of our legal bases).
Aggregate and de-identified information. We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes.
We may disclose the personal information that we collect about you as set forth below or as otherwise described at the time of collection or sharing.
Anonymised and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics, and other purposes.
COOKIES, TRACKING, AND ANALYTICS
Our Services may use first party and third-party cookies, pixel tags, plugins, and other tools to gather device, usage and browsing information when users visit our Services. For instance, when you visit our Services, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you select on the Services, as well as date and time stamps associates with your activities on our Services.
We use the information for security purposes, to facilitate navigation, to personalise and improve your experience while using the Services, to improve and measure our advertising campaigns and to better reach users with relevant advertising both on our Services and on third party websites. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.
Essential cookies are essential, as they enable you to move around the Service and use its features. Without these cookies we could not, for example, authenticate your login or remember that you are logged-in as you move through the Service.
Functionality cookies allow us to remember choices you make (such as the region you're in) and tailor the Service to provide enhanced features and content for you. For instance, they can be used to remember your login details or remember your nickname when you next login. They may also be used to provide services you've requested, for example leaving a comment on the Service.
Analytics & performances cookies collect information about how the Service is used, for example which pages users visit most often and if any error messages are displayed on certain pages. Information collected using these cookies is used to monitor activity on the Service and understand how it is being used.
If you have disabled one or more cookies, we may still use information collected from cookies before your disabled preference was set. However, we will stop using the disabled cookie to collect any further information.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Websites to, among other things, track the actions of users of the Websites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Websites and response rates. We and our service providers may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, track whether our emails are forwarded, and conduct analytics.
Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.
Do-Not-Track signals. Please note that our Websites do not recognise or respond to any signal which your browser might transmit through the so-called 'Do Not Track' feature your browser might have. If you wish to disable cookies on our Websites, you should not rely on any 'Do Not Track' feature your browser might have. For more information about do-not-track signals, please click here.
You can manage how your preferences regarding third party ad company cookies set by this Service by reading the cookie discussion above.
Please also see the cookie discussion above for information about the third parties we may work with to display targeted ads on third-party sites and to measure the success of our marketing and campaigns. You may also obtain more information about targeted or “interest-based advertising” and opt-out of many ad networks.
The Services may integrate with social sharing features and other related tools which let you log in to the Services or share actions you take on the Services. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them. We do not receive or store passwords to your third-party social media accounts in this context.
The Services are hosted on servers located in The Republic of Vanuatu. Note that some countries may not provide the same level of data protection as your home country. If you are located, for example, in Australia, your personal information will be transferred to The Republic of Vanuatu and possibly to other jurisdictions, which may not provide the same level of protection under your local data safeguards. You may have the right to request a copy or information about those safeguards by contacting us as detailed below.
We use technical, administrative, and physical controls in place to help protect Personal information from unauthorised access, use, and disclosure. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable. In the event that the security of your account has been compromised, please immediately notify us in accordance with Section 14 below (“Contact Us”).
We will retain your personal information for the period necessary to fulfill the purposes outlined in this privacy notice unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others. With respect to the data and files we handle as a processor, we retain this personal information in accordance with our clients’ instructions.
Marketing. You may opt out from receiving marketing-related communications from us on a going forward basis by contacting us or by using the unsubscribe mechanism contained in each email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
Cookies and similar technologies. Please review your browser or device settings for certain cookies and see above to exercise certain choices regarding cookies.
Access, amendment and deletion. Under applicable privacy laws, you may have the right to request to review, make amendments, have deleted or otherwise exercise your rights over your personal information that we hold, subject to certain legal limitations and requirements. If you are subject to such a privacy law, you may submit a request to us related to your personal information:
We follow applicable law to take steps to keep your personal information accurate, complete and up-to-date. In your request that is covered by an applicable privacy law, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. We may only implement requests (a) where required by applicable law and (b) with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
As outlined below, you may have additional rights.
Deactivation. You can deactivate your account at any time by contacting us at the email address at the bottom of this page. However, you will not be able to access many of the services to deactivate your account. Please note that even if you request deactivation of your account, it may take some time to fulfill this request.
Responding to Requests. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Additional information for certain jurisdictions. We are committed to respecting the privacy rights of individuals under all privacy laws applicable to us. Some privacy laws require that we provide specific information about individual rights to applicable consumers, which we have set forth at the end of this privacy notice in Section 15 below.
The Services are not intended or directed to children under the age of 18, and we do not knowingly collect any personal information, or knowingly track the use of our Services, from children. If we have actual knowledge that personal information about a child under 18 years old has been collected, then we will take appropriate steps to try and delete such personal information.
We may amend this Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process personal information, we will prominently post a notice regarding such change on the Services. Any material changes to this Policy will be effective 10 days after our posting of the updated Policy or as otherwise required by applicable law. Where required to do so by law, we may seek your prior consent to any material changes we make to this Policy.
If you have any questions or concerns about this Policy, please use the following contact information:
Mailing address: ATT: Data Privacy – Island Property, P.O. Box 2, Port Vila, The Republic of Vanuatu
Phone number: (+678) 24630
In this section, we provide information for Vanuatu residents, as required under Vanuatu privacy laws, including the Vanuatu Electronic Transactions Act, 2000 (“ETA”), which requires that we provide Vanuatu residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by governments or other personal information that is subject to an exemption under the ETA.
Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a Vanuatu resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. We collect categories of personal information from the sources described in the Information We Collect section above, and for the purposes described in the Disclosure of Personal Information section above.
We will respond to verifiable requests received from Vanuatu residents as required by the law. For more information about our privacy practices, contact us as set forth in the “Contact Us” section above.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for: