We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).
For the purpose of Data Protection Laws, in relation to any Personal Data you submit to our service, you will be the “Data Controller” and we will be a “Data processor” of such Personal Data, as defined by the GDPR here.
1. Personal Data We May Collect from You
“Personal Data” as defined by the GDPR here.
Personal Data can be collected and processed when our website is in operation by you. We may obtain and use the following Personal Data about you and anyone you chose to add to our service:
- Any correspondence we have with you should you contact us. Data you provide when you fill out forms on our Website, including but not limited to data you provide when you register to become a user of the Service.
- Data and information you submit or upload to SageMailer or the Service.
- Data and information you submit or upload to SageMailer or the Service, or data we collect from your systems or third-party services, including your customer data: (which may include among other things, names, email addresses, shipping/billing addresses, phone numbers, contact details);
- Sales data: (such as details of the transactions undertaken through the Services, products/services purchased, date/time, payment amount/method, cancellations, returns, exchanges, communications with controller), Financial or payment information, Marketing preferences and communications.
- Any other data that consumers/end users have provided to the Customer which are processed through the Services, the extent of which is determined and controlled by the Customer or consumer/end-user in their sole discretion.
- Details of transactions made by you through the Website.
- Details of your visits to our Website, which includes without limitation location and traffic data, weblogs, resources you access and other communication data.
You will be submitting and providing Client Data which may contain Personal Data (and potentially Sensitive Personal Data of Users and third parties. “Sensitive Personal Data” as defined by the GDPR here.
Circumstances may arise when we may need to gather information about your computer to help provide appropriate services or products to you. The data gathered is solely statistical data, which may be shared with advertisers.
The facts collected about you are statistical only. No identifying information will be shared about our visitors and how they made use of our site. No personal details will ever be shared.
Cookies are used to collect general online usage by using a cookie file. If used this cookie file is downloaded without prompting. It will be placed on your hard drive with information transferred to the hard drive allowing the cookies to be used for data collection. A cookie is used to improve any services/ products, or overall website characteristic we offer you.
Any computer has the option to decline cookies. Your web browser options include an “enable” button to decline cookies. It is imperative that you understand by declining cookies you may be limiting your access to sections of our website.
2.1 Google Analytics
If you do not wish to allow the use of Google Analytics cookies at all, Google provides an opt-out plug-in for most common website browsers:
2.2 Google Adwords
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
3. Storing Your Personal Data
3.2. Secured servers are used by our company to ensure proper data storage. Information on transactions is kept encrypted for safety measures.
3.3. Transmission of data on the internet can never be ultimately secure. We do not and cannot guarantee the security of information collected electronically or transmitted; however, we take all necessary steps to provide the best security available. As a result of our inability to guarantee safety, you are submitting information to us at your own risk. Where needed a password may be necessary to access areas of our site. You are responsible for the safety and confidentiality of the password you generate.
4. Protecting Your Personal Data
We will take reasonable steps to maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your Personal Data. All your and your customers’ Personally Identifiable Information (PII) are stored and processed according to our Data Protection Policy (“DPP”).
5. Use of Personal Data
Information stored and collected about you allows us to improve our services or products for you. Added to this parameter, we may use your information for the following purposes:
5.1. Any commitment we make on a contracted basis.
5.2. If the information is requested from our website concerning services or products offered, we may use your data. Products or services which may be of interest to you can also deem a communication from us if permission has been granted.
5.3. Notification re-changes or improvements may be sent to you in regards to product or service changes that could affect our service to you.
5.4. Existing customers can be contacted on the topic of goods or services related to a previous sale if we feel you might be interested in these additional topics.
5.5. Added use of your data may include permission for third parties to use your data. This permission would be granted by you in regards to unrelated products or services that may be in your interests. We or third parties can only contact you in regards to this information if consent has been provided for information collection.
5.6. Third party contact or communications from our website, as a new customer, is only made if you have granted us permission. These communications are only offered for the information you consented to and no other unrelated information.
5.7. Data that you do not want us to use or third parties to use can be withheld, once consent has been given regarding our collection of your data. We will always provide you with an opportunity to decline communications and our or third party data usage.
5.8. Identifiable data, which could be used to disclose who you are, is never shared. We only provide statistical related data about our visitors to third parties like advertisers to ensure your privacy.
6. Third Party Integration Partners
7. Disclosing Your Information
7.1. Personal information to third parties may be disclosed:
7.2. This disclosure occurs when we sell all or a section of our business or assets to a third party.
7.2.1. Personal information can be offered to any member of our company, such as subsidiaries, holding companies and their subsidiaries only if deemed appropriate.
7.2.2. Legal requirements may mean a sharing of your information.
7.2.3. Lowering credit risk and fraud protection may result in information disclosure.
8. Your Rights
You retain the right to request us to refrain from processing your data for the purposes of marketing. To exercise such right, you may reply to any information we send you, detailing your request that we refrain from sending any marketing correspondence, or you can exercise this same right by contacting us electronically via email at email@example.com. If at any time we intend to use your data for such marketing purposes, however, it is standard practice for us to make you aware in advance of collecting such data.
We may at times provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates or advertisers. These websites have separate privacy policies, and we, therefore, cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites’ individual privacy policies before submitting any personal data.
You retain at all times the right to access/amend/delete any Personal Data we hold about you or to exercise your right of data portability or to object to, or restrict, the purposes for which your Personal Data is processed on certain grounds. You may exercise this right by making a request in accordance with Data Protection Laws, by emailing firstname.lastname@example.org.
9. How Long We Keep Your Personal Data
We will keep your Personal Data for the duration of the Service and we may keep your and your Personal Data for a further 21 days past the end of the service to ensure a seamless return if you should decide to restart the service, in accordance with your instructions or for such periods as may be required by law.
Personally Identifiable Information of Customer consumers is automatically removed in 30 days after order shipment.
If at any time we make a change to this policy, we will update this page to reflect such change. Where we feel it appropriate, we will notify you by email, however, we recommend you review this page periodically to ensure you remain happy with the latest version.
11. Contacting Us
Sh. Nutsubidze spole, IV M/D, Building 10b, Suite 42, Tbilisi, Georgia
Material Modifications Since September 1, 2016: 24/05/2018, 31/10/2018.