Effective Date: 25th of May 2018
General
We respect your need for online privacy and protect any personal data, including but not limited to any ‘personal data’ defined in the applicable data protection laws and regulations that you may share with us. Our practice, with respect to the use of your personal data, is as set forth below in this privacy policy (Privacy Policy). As a condition to the use of the Website and the Services, you consent to the terms of this Privacy Policy as it may be updated from time to time.
The terms www.taxlinked.net or “us” or “we” or “our” or “Website” refer to the owner of the website, namely M.C. Trusts & More Limited, a company incorporated under the Republic of Cyprus with registration number ΗΕ 278509, whose registered office is at 21, Pandoras Street, 6042 Larnaca, Cyprus, and which is the controller of your personal data. The terms “you” or “user” refer to any visitor of the Website and to any Website user, which includes members or not.
All capitalized terms used herein but not otherwise defined have the meaning ascribed to them in the Terms of Use.
What Personal Data We Might Collect
The personal data we collect can include the following, some of which are obligatory and some are optional:
- Name and contact information: We collect your first and last name, email address, postal address, phone number, and other similar contact information.
- Credentials: During the registration process for creating a member account, you will also be asked to choose a password, which will be used solely for the purpose of authenticating and accessing your member account.
- Demographic data: We collect data about you such as your country, physical address, telephone number, fax number and website address.
- Social Media links: We collect data about your social media accounts such as Facebook, Twitter, LinkedIn and Google Plus.
- Business details/Areas of practice/Company description: We collect data about your area of practice, areas of practice of the company that you are working with in the case of an organization, your work title, your department’s information and other information related to your work or organization, expert count in the case of an organization, company’s logo and/or personal logo.
- Payment data: In case of services requiring payment, we request credit card or other payment account information, which will be used for processing payments and implement fraud prevention. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument.
- Usage details: Your usage details such as time, frequency, duration and pattern of use, features used, and the amount of storage used will be recorded by us in order to enhance your experience of the Services and help us provide you with the best possible service.
- Further information: We also collect information you provide us and the content of messages you send us and/or to other users, such as feedback and product reviews you write, or questions and information you provide for support. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
- Cookie data. We automatically collect certain information provided by your browser or operating system, such as your Internet protocol (IP) address and other browser or device identifiers, the date and time of your visit, information about your activities and actions (such as the links that you click and pages that you view). You can find out more about our use of cookies and related technologies, including the purposes for which we use them, by reading our Cookie Policy.
We may also obtain information about you from third parties and combine that with information we collect. For example, we may have access to certain information from a third party social media platform, such as Facebook, LinkedIn, Twitter or an authentication service if you provide us with access to that information. Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), current city, profile picture URL, and other information that the third party service makes available to us, and to use and disclose it in accordance with this Privacy Policy.
You have choices about the personal data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide personal data that are required, you may not be able to use the Services.
If you are working in an organization, then you should verify that you are an official representative of the company that you represent and that you have the right to act on behalf of the company in the creation of a profile page for the company within the Website’s community by clicking the relevant check box.
You will be further requested to verify that the personal data you have provided is correct.
The Purposes of Using Your Personal Data
Access to the Services: We use your personal data to authorize your access to the Services.
Optimizing your experience: We use your personal data, with the help of automated systems and inferences we make, in order to ensure that the Services you use are suited to your interests and profile. Our Services also enable you to collaborate with colleagues, and search for potential clients, customers, partners and others to do business with. We will use data about you (such as your profile, profiles you have viewed or data provided through address book uploads or partner integrations) to help others find your profile, suggest connections for you and others, and enable you to invite others to become a user and connect with you.
A number of the Services provide features including chat rooms, messaging services, video call and community and event forums for collaboration, peer connection, and information exchange purposes. Depending upon the Service, the personal data you choose to post, share, upload, or make available is public and visible to users and visitors of the Website.
Communication: We use your personal data to communicate with you. For example, we may contact you by phone or email or other means to inform you when a subscription is about to expire, inform you when security updates are available, update you or inquire about a service, invite you to participate in a survey, or tell you that you need to take action to keep your account active. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.
Keep you informed: We use your personal data to keep you informed about news, events, webinars, conferences and other topics that you care about. Also, we use the data we have about you to recommend relevant content and conversations. We will use your personal data to suggest that you follow certain members, or watch related educational content to help you improve or develop a new skill. We use your content, activity and other data, including your name and picture, to provide notices to your network and others. For example, subject to your settings, we may notify others that you have updated your profile, posted a blog, took a social action, made new connections or were mentioned in the news.
Marketing: We use personal data for invitations and communications promoting membership and network growth, engagement and our Services.
Fix problems: We use data to help you by fixing problems.
Security: We use your personal data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of the Terms of Use or this Privacy Policy and/or attempts to harm other users or visitors.
Legal Basis for the Processing of Personal Data
We will only collect and process personal data about you where we have legal bases in accordance with the data protection regulations, such as consent (where you have given consent for one or more specific purpose), contract (where processing is necessary for the performance of a contract), and where there is a legitimate interest.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal, and, where we rely on legitimate interests, we shall specify the legitimate interests pursued by the controller or by a third party and you have the right to object. If you have any questions about the lawful bases, please contact our Data Protection Officer.
With Whom We Share your Personal Data
Profile: Any personal data that you include in your profile is visible to the users and visitors of the Website.
Publication: Our Services allow viewing and sharing information including posts, articles and comments, among others.
When you publish any content (e.g., an update, image, comment, video, publication, or article), it can be viewed by everyone and re-shared anywhere. Users and visitors will be able to find and see your publicly shared content, including the personal data you have included in your profile (and photo if you have provided one).
Share personal data with affiliates and service providers: We may need to share your personal data with third parties such as our affiliates and service providers to develop and provide the Services. The purposes for which we may disclose your personal data to our service providers may include, but are not limited to, data storage, database management, hosted search and support services, website development, web analytics and payment processing. These service providers are authorized to use your personal data only as necessary to provide these services to us. In such cases, we will also ensure that such affiliates and service providers comply with this Privacy Policy and adopt appropriate confidentiality and security measures.
Website’s visitors: We provide the capacity for users to post information and comments on the Website. This information and comments are publicly available to the users and, in some cases, to the visitors of the Website. We require registration to publish any information or comments, but given the public nature of the platform, any personal data disclosed within the Website may be used to contact users with unsolicited messages. We encourage users to be cautious in the disclosure of personal data on the Website, as we are not responsible for the personal data users elect to disclose.
Legal disclosures: We will transfer, disclose, and present personal data when we have good faith belief that doing so is necessary to:
- Comply with applicable laws or respond to valid legal process, including from law enforcement or other government agencies;
- Protect our customers, for example, to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone;
- Operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks, or;
- Protect the rights of our property, including enforcing the terms governing the use of the Services.
Change in control: We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.
Need of a prior consent: We will obtain your prior specific consent before we share your personal data or data to any third party for any purpose that is not directly connected with providing the Services to you.
Personal Data Retention Period
Retention period: We retain your personal data while your member account is in existence or as needed to provide you with the Services for which you have registered. This includes personal data you or others provided to us. Even if you only use our Services occasionally, and even if your account is deactivated, we will retain your personal data until you decide to close/delete your member account.
Deletion/closure of a member account: If you choose to close your member account, your personal data will generally stop being visible to others within 90 (ninety) hours. We generally delete closed account information within 3 (three) months of account closure, except as noted below.
We reserve the right to retain your personal data even after you have closed your member account if it is reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, and/or prevent fraud and abuse.
Subject to the Terms of Use, some of the information you have published will remain visible after you closed your account or deleted the information from your own profile (i.e., where you have voluntarily participated in a project such as a webinar, e-book, interview, etc.) We do not control data that other users copied from our Services.
Access and Control Your Personal Data
You have the right to access, correct or delete your personal data, as follows:
Delete data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you or if you withdraw you consent), by sending us an email.
Change or correct data: You can edit some of your personal data through your account (edit profile/settings). In the case the platform does not allow you to proceed with any changes, you can ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate, by sending us an email.
Object to, or limit or restrict, use of data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to access and/or take your data: You can ask us for a copy of your personal data and a copy of personal data you provided in machine readable form.
Other General Information
Security of your personal data: We adopt industry-appropriate data collection, storage and processing practices and security measures, as well as physical security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal data, username, password, transaction information and data stored in your user account.
Links from our website: Some pages of the Website contain external links. You are advised to verify the privacy practices of such other websites. We are not responsible for the manner of use or misuse of information made available by you at such other websites. We encourage you not to provide personal data without assuring yourselves of the Privacy Policy of such other websites.
Enforcement of Privacy Policy: We make every effort, including periodic reviews, to ensure that personal data provided by you is used in conformity with this Privacy Policy. If you have any concerns regarding our adherence to this Privacy Policy or the manner in which personal data is used for the purpose of providing the Services, kindly contact our Data Protector Officer. We will contact you to address your concerns, and we will also co-operate with regulatory authorities in this regard if needed.
Notification of changes: We may update this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will provide you with a notice through the Website, or by other means, to provide you with the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.
You acknowledge that your continued use of the Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.
Effective Date: Effective date is the date first written above.
Filing a complaint to the supervisory authority: If you are not satisfied with how we manage your personal data, you have the right to make a complaint to the data protection authority in Cyprus at www.dataprotection.gov.cy. A list of National Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Contact us: If you have any questions or concerns regarding this Privacy Policy, please contact the Data Protector Officer, the details of whom are as follow:
Name: Kyriaki Gerolemou
Email Address: [email protected]
Address: 22, Makarios III Avenue,
Makaria Center, 4th Floor, office 403
6016 Larnaca - Cyprus
P.O. Box 40451, 6304, Larnaca - Cyprus
Telephone: +357 24 812050