COLLECTION OF INFORMATION
Information You Provide To Us
We may collect information you provide directly to us via the Services. For example, we collect information when you use or register for our Services, subscribe to our magazines or newsletters, create a resume, post on our Services, follow other users, participate in promotional activities, enter a sweepstakes or contest, complete a survey, or communicate with us through the Services.
Information we collect may include Personal Information: “Personal Information” is information, whether true or not, that can be used to identify you (whether alone or in combination), which may include your name, e-mail address, postal address (including billing and shipping address), geolocation information, telephone number, and fax number. You may choose to voluntarily submit certain other information to us through the Services, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not collected such information or requested that you submit such information to us.
Information We Collect Automatically From Your Use of Our Services
The methods that we and our Service Providers may use to collect Usage Information include:
Log Information: We collect information about your use of our Services, such as IP address, browser type and version, internet service provider, referring/exit pages, operating system, cookies that may uniquely identify your browser or your account, and related data, and store it in log files.
We are giving you notice of the Tracking Technologies and your choices regarding them explained in Section 12 so that your consent to encountering them is meaningfully informed.
Information from Other Sources
USE OF INFORMATION
Provide, maintain, protect and improve our Services, develop new Services, and protect MOST Engineering & IT Solutions d.o.o and our users;
Facilitate, manage, personalize and improve your online experience;
Transact with you, respond to your comments and questions, provide customer service, send you informational notices, and fulfill your requests, such as to send you newsletters, brochures, catalogs and e-mails;
Prevent and address fraud, breach of policies or terms and threats or harm, and for our business purposes, such as data analysis, audits, enhancing, improving, or modifying our Services, identifying usage trends, and operating and expanding our business activities; and
Send you newsletters and advertisements and communicate with you about products, services, offers, promotions, rewards, and events we think may be of interest to you.
If you are a user from the United States (U.S.), we may use your Personal Information for direct marketing purposes. If you are a user from outside the U.S., we will not use your Personal Information for direct marketing purposes unless we have received your express consent. As a Non-U.S. user, you have the right to opt-out from direct marketing and can require us to cease to use the data at any time for direct marketing purpose at no cost.
Please see Section 12 for more information about how to manage our communications with you.
SHARING OF INFORMATION
Please note that by using our Services, you agree to share your Personal Information and Usage Information, as described in this section.
With Service Providers
Our Service Providers may receive, or be given access to your information, including Personal Information and Usage Information, in connection with their work on our behalf. These Service Providers may be located in countries other than your country of residence. These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes. We may also share information about you with our Service Providers as necessary, for the following purposes:
To comply with the law, law enforcement or other legal process, and to respond to requests from public and government authorities, including public and government authorities outside your country of residence to meet national security or law enforcement requirements;
To enforce our terms and conditions;
To protect our operations and protect our rights, privacy, safety or property, and/or that of you or others;
To allow us to pursue available remedies or limit the damages that we may sustain;
With our affiliates for internal business purposes (for example, processing your orders, fulfilling your requests, providing customer service, and improving the Services);
With our subsidiaries, affiliates, business partners, and other third parties for their own business purposes (for example, improving their products and services); and
To a third party in connection with or during negotiations of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.
With Third Parties for Direct Marketing Purposes
We may share your Personal Information with third parties for direct marketing purposes as set forth in Section above. California residents have further rights, as set out in Section below.
Direct marketing purposes may include, but are not limited to, the following:
Sharing your Personal Information with third parties, including when you click on advertisements or articles on our Services or in emails we send to you;
Rental of email lists to third parties for marketing use;
Marketing emails sent by third parties; and
Emails sent by us sponsored by third parties.
SWEEPSTAKES, CONTESTS, AND PROMOTIONS
INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS
Additionally, the Services may offer you the option to send a communication to a friend. If so, we rely on you to only send to people that have given you permission to do so. By sending a communication to a friend, you represent that you have permission to provide your friend’s e-mail address. The friend’s information you provide (e.g., name, e-mail address) will be used to send the communication and not used by us for any other marketing purpose unless we obtain consent from that person. Your contact information and message may be included in the communication.
THIRD PARTY SERVICES AND SOCIAL FEATURES
Our Services includes hyperlinks to websites, locations, platforms, or services operated by third parties (“Third Party Services”). These Third Party Services may use their own cookies, web beacons and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.
Third Party Responsibility
ADVERTISING, ANALYTICS SERVICES, AND ONLINE TRACKING
Online Behavioral Advertising
Some information about your browsing of the Services and certain Third Party Services may be collected across time and services and shared with third parties to deliver ads and/or other content to you on the Services and certain Third Party Services. We may receive information about Third Party Services that you have visited and use it for marketing purposes—a practice sometimes termed “(re)-targeting,” “interest-based advertising,” and “online behavioral advertising.”
Do Not Track
We are not responsible for third parties or Third Party Services associated with advertising and analytics services, and related tracking activities. Please consult their privacy policies and notices for information on their practices and see Section 12regarding certain choices some of them may offer you. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.
We take reasonable technical and organizational security measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. In addition, we will not keep your Personal Information for longer than necessary for the purposes set out in this policy. Unfortunately, no data transmission or storage system is completely secure, and we cannot guarantee the security of your information collected through our Services.
Your Personal Information is stored on servers maintained with the assistance of a third party data storage provider. To help protect the privacy of data and personal information we collect and hold, our data storage provider maintains physical, technical, and administrative safeguards which are monitored, tested, and updated on an ongoing basis.
We comply with the Privacy Shield Framework, as set forth by the U.S. Department of Commerce in consultation with the European Commission, regarding the collection, use and retention of Personal Information received from the European Union. As we are a U.S. company, we have voluntarily decided to comply with the EU – U.S. Privacy Shield Framework and we are subject to the investigatory and enforcement powers of the Federal Trade Commission. We annually certify our adherence to the Privacy Shield Principles of notice; choice; accountability for onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability. To learn more about the EU – U.S. Privacy Shield Framework, please visit https://www.privacyshield.gov/EU-US-Framework. To view Arrow’s certification, please visit https://www.privacyshield.gov/list. In the event Privacy Shield is invalidated, information of EU residents will only be transferred in accordance with an approved transfer mechanism, including the model contract clauses.
Our Services are not intended for children and are not targeted to children under the age of thirteen (13). If you are a child under the age of thirteen (13), you are not permitted to use the Services and should not send any information about yourself to us through the Services.
We do not knowingly collect any personal information from children under the age of 13 and, if we learn that we have received information from a user under the age of 13, we will delete this information in accordance with the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at email@example.com
If you are a user in South Korea and you are aged under fourteen (14), you are not permitted to use the Services without the consent of your parent or legal guardian. You should not send any information about yourself to us through the Services unless your parent or legal guardian has given his or her consent. We do not knowingly collect any Personal Information from children in South Korea under the age of 14 without consent from a parent or legal guardian and, if we learn that we have received information from a user in South Korea under the age of 14 without requisite consent, we will delete this information. If you are a parent or legal guardian in South Korea and you believe that your child under the age of fourteen (14) has provided us with Personal Information without your consent, please contact us at firstname.lastname@example.org.
ACCESSING AND CHANGING INFORMATION
We will provide web pages or other mechanisms allowing you to correct or update some of the Personal Information you have provided us.
Users from the EU, Singapore, Hong Kong, Japan, New Zealand, Mexico, and Australia have a right to access their Personal Information, request corrections and/or deletions, and oppose the use of their Personal Information for specific purposes, subject to exceptions allowed by law. Such users are also entitled to request information on the origin of their Personal Information, the recipients or types of recipients to whom their Personal Information is provided, the reason for which their Personal Information is being stored, and the ways in which their Personal Information has been or may have been used or disclosed by us within a year before the date of the request. If you would like to do so, please send your request in writing by sending an email to email@example.com . To protect your privacy and the privacy of others, we will need evidence of your identity before we can grant you access to information about you or change it, including your username and password, if applicable. You will not be charged for compliance with such a request.
Changes and Deletions
We will make good faith efforts to make requested changes in our then-active databases as soon as practicable (but may retain prior information for records to the extent not prohibited by applicable law). Please note that it is not always possible to completely remove or delete all of your information or public postings from our databases (California minors see Section 13) and that residual data may remain on backup media or for other reasons. We also may retain cached or archived copies of information about you for a certain period of time.
CHOICES: TRACKING AND COMMUNICATIONS OPTIONS
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove cookies some parts of our Services may not work and that when you revisit our Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Cookies and tracking devices used by MOST Engineering & IT Solutions d.o.o, as categorized by function:
Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into areas of our website.
Analytical/performance cookies – Allow us to recognize and count the number of visitors and to see how visitors move on our website. This helps improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies – These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences.
Targeting cookies – These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Cookies can also be categorized by how long they remain on your device. There are two broad categories of duration:
Persistent cookies – Persistent cookies remain on your device until deleted manually or automatically.
Session cookies – Session cookies remain on your device until you close your browser when they are automatically deleted.
We use both persistent and session cookies. Our persistent cookies last no longer than one (1) year.
Information collected by our cookies:
Cookies on our website collect several types of information, including information about your usage of our website and we may collect your IP address as a logged file. An IP address is the number assigned to your device, for example your laptop or mobile phone, when your device accesses the internet.
To the extent that IP addresses are personal data under applicable data protection law, we treat it as Personal Information. If we link information collected through cookies with any personal data you provide to us through the website, e.g., through submitting a form, we also treat that information as Personal Information. For information on how we handle personal data collected through the site, please see above.
How to manage cookies in your browser:
Most modern browsers will allow you to:
See what cookies you’ve got and delete them on an individual basis;
Block third party cookies;
Block cookies from sites;
Block all cookies from being set; and
Delete all cookies when you close your browser.
You should be aware that any preferences will be lost if you delete cookies. This includes where you have opted out from cookies, as this requires an opt-out cookie to be set. Also, if you block cookies completely many websites will not work properly and some functionality on these websites will not work at all. We do not recommend turning cookies off when using our website and Services for these reasons.
If you are primarily concerned about third-party cookies generated by advertisers, you can turn these off separately.
With respect to our mobile applications, you can stop all collection of information by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling location identifying services, by adjusting the permissions in your mobile device.
Third-party cookies and tracking devices:
When you are using our Services, you may notice that there is content from other websites which we add from time to time to improve the user experience. As a result, you may be sent cookies from these other websites. We do not control these cookies and we suggest you check these third-party websites for more information about the cookies they use and how you can manage them.
Managing advertising cookies:
Please note that if you want to opt out from targeted advertising cookies, this does not mean that you will receive less advertising when you use our services. This just means that the advertising you see will not be as relevant or customized to you.
However, if you still want to opt out of these third party advertising cookies, you can do this by visiting the Interactive Advertising Bureau’s website www.youronlinechoices.com which lists all ad serving cookies that are currently set on your device and tells you how to opt-out from each of them. Please note that this website lists many more networks than those used by us.
Please remember that if you choose to opt out of targeted advertising from a specific company or via www.youronlinechoices.com, it only applies to the web browser on the device you are using. You will therefore need to follow the same process on every device you use or different web browser that you use to exercise the same choice.
Further information about cookies:
If you wish to learn more about cookies in general and how to manage them, visit www.allaboutcookies.org.
Analytics and Interest-Based Advertising
Certain companies may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for interest-based ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com and its opt-out program for mobile applications at http://www.aboutads.info/appchoices. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt-out of certain targeted advertising delivered by NAI members’ ad networks. To learn more about opting out of targeted advertising or to use the NAI tool, visit http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt-out of certain kinds of targeted advertising, you will continue to receive non-targeted ads. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. However, we support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf) and expect that ad networks we directly engage to serve you interest-based ads will do so as well, though we cannot guarantee their compliance.
You can opt-out of receiving promotional communications (e-mails or text messages) from us at any time by (i) for promotional e-mails, following the instructions as provided in e-mails to click on the unsubscribe link or changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions as provided in text messages from us to text the word, “STOP”. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscriptions may continue. Even if you opt-out of receiving promotional communications, we may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or our ongoing business relations.
Our mobile applications may send you notifications that may include alerts, sounds, and icon badges. These push notifications or in-app messages may include both operational messages and promotional messages regarding products, services and offers that may be of interest to you. These can be configured in Settings. As with e-mails, even if you opt-out of receiving promotional communications, we may continue to send you non-promotional push notifications, such as those about your use of the applications or our ongoing business relations.
PRIVACY RIGHTS IN NON-U.S. JURISDICTIONS
Obligation to Provide Personal Information
EU persons must, on occasion provide Personal Information to us as necessary to enter into a contract or as required to fulfil contractual obligations, including providing our products and Services, taking payment for products and Services we provide, and billing, shipping, and delivery of our products and Services. You are free to withhold your Personal Information but without this data it will not be possible to execute the contract or provide you with our products and Services.
When you make a purchase on or of the Services, you must provide Personal Information to us so that we can meet our legal obligations in accordance with applicable tax and statutory provisions. You are free to withhold your Personal Information, but without this data, it will not be possible to provide you with our products and Services.
We sometimes use EU persons’ Personal Information submitted through the Services for automated decision-making. For example, we may display advertisements and send emails to you containing content automatically chosen based on the products or Services we have provided to you in the past. However, we will not use EU persons’ Personal Information submitted through the Services for automated decision-making, including profiling, that produces legal effects or similarly significantly affects EU persons.
Legal Basis for Processing
We process your Personal Information with your consent and as required by law. In addition, we process your Personal Information as necessary for the performance of the sales contract, for example, when processing your orders and payments and to take steps, at your request, before entering into a contract with you, for example, by providing you with quotes for products and services. We also process Personal Information as necessary for our legitimate interests as follows:
Research and Development: To research use of our products and services, and to improve and develop new products and services;
Marketing and advertising: To the extent permitted by applicable law, we use your Personal Information regarding products and services you have ordered, or in which you have otherwise demonstrated an interest, as necessary to analyze your interests and to provide you information about the products and services that we think might interest you; and
Security: We use Personal Information for purposes of facility, network, and information security, fraud prevention, and reporting suspected criminal acts. For example, in the event of fraud, a security incident, or a suspected criminal act, we would examine Personal Information that appeared to be linked to the incident as necessary to determine what happened, remediate, report to the authorities, and prevent a recurrence.
Accuracy and Access to Personal Information
EU persons may request access to their Personal Information under this policy to the full extent required by applicable law in the home country of the person making the request. Such persons may request the correction, amendment, or deletion their Personal Information that is inaccurate or has been processed in violation of the Privacy Shield Principles. We will reasonably fulfill such requests to the extent required by applicable law.
Users from outside the U.S. have the right to ask us not to process their Personal Information for marketing purposes. We will inform you (before collecting your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information.
You can exercise these rights at any time by contacting us at firstname.lastname@example.org
Right to Object to Processing for Direct Marketing or Legitimate Interests
EU persons have the right to object to the processing of their Personal Information for purposes of MOST Engineering & IT Solutions d.o.o’s direct marketing or legitimate interests. You can exercise your right to prevent such processing by unsubscribing from the emails you receive from us and any third parties. You can also exercise the right at any time by contacting us at email@example.com
Revocation of Consent
Users from outside the U.S. also have the right to revoke their given consent regarding the use and sharing of their Personal Information. However, it is important to note that in some cases such request may not be immediately or fully executed because it is possible that we have a legal obligation to keep using your Personal Information. Also, you must consider that for certain purposes, the revocation of consent means that we cannot continue providing the Services you requested. You can revoke your consent at any time by contacting us at firstname.lastname@example.org
Accountability and Inquiries
Any EU person who is not satisfied with our compliance with the EU – U.S. Privacy Shield may contact us to resolve such complaints at email@example.com. If any EU person believes that such a complaint has not been resolved, he or she agrees first to try and settle the dispute by mediation, administered by the International Centre for Dispute Resolution under its Mediation Rules, before resorting to arbitration, litigation, or some other dispute resolution procedure. The rules governing these procedures and information regarding how to file a claim free of charge can be found here: http://info.adr.org/safeharbor/.
Any EU person who remains dissatisfied may contact his or her national Data Protection Authority in the country where the person resides. We have agreed to cooperate and comply with appropriate EU Data Protection Authorities and the Department of Commerce in resolving such disputes. If an EU person remains dissatisfied and meets the pre-arbitration requirements of Annex I Part C of the EU – U.S. Privacy Shield Framework, the person may invoke binding arbitration pursuant to procedures in Annex I of the EU – U.S. Privacy Shield Framework Principles found here: https://www.privacyshield.gov/EU-US-Framework.