This Policy applies as between you, the User of this Web Site and ADME (CY) LTD the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.
In this Policy the following terms shall have the following meanings:
"Account": means collectively the personal information, Payment Information and credentials used by Users to access Material and / or any communications System on the Web Site;
"Content": means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site;
"Cookie": means a small text file placed on your computer by ADME (CY) LTD when you visit certain parts of this Web Site. This allows us to identify recurring visitors and to analyse their browsing habits within the Web Site.
"Data": means collectively all information that you submit to the Web Site. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;
"ADME (CY) LTD": means ADME (CY) Ltd, a Cyprus private limited liability company, having registration number HE347617, and registered address 62 Agiou Athanasiou Ave., BG Waywin Plaza, 1st Floor, Office 101, Limassol, 4102, Cyprus;
"Service": means collectively any online facilities, tools, services or information that ADME (CY) LTD makes available through the Web Site either now or in the future;
"System": means any online communications infrastructure that ADME (CY) LTD makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
"User" / "Users": means any third party that accesses the Web Site and is not employed by ADME (CY) LTD and acting in the course of their employment; and
"Website": means the website that you are currently using (thesoul-boost.learnworlds.com) and any sub-domains of this site unless expressly excluded by their own terms and conditions.
Without limitation, any of the following Data may be collected by TheSoul Publishing or any involved third party Data processor:
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2.1 name;
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2.2 date of birth;
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2.3 job title & profession;
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2.4 contact information such as email addresses and telephone numbers;
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2.5 demographic information such as post code, preferences and interests;
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2.6 financial information such as credit / debit card numbers;
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2.7 IP address (automatically collected);
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2.8 web browser type and version (automatically collected);
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2.9 operating system (automatically collected);
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2.10 a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); and
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2.11 Cookie information (see Clause 10 below).
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3.1 Any personal Data you submit will be retained by ADME (CY) LTD for as long as you use the Services and Systems provided on the Web Site. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to one year.
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3.2 Unless we are contractually required, obliged or permitted by law to do so, and subject to Clause 4, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.
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3.3 All personal Data is stored securely in accordance with the local, European, and international statutory requirements (as applicable). For more details on security, see Clause 9 below.
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3.4 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site. Specifically, Data may be used by us for the following reasons:
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3.4.1 internal record keeping;
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3.4.2 improvement of our products / services;
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3.4.3 transmission by email of promotional materials that may be of interest to you;
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3.4.4 contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Web Site.
ADME (CY) LTD may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services do not have access to certain personal Data provided by Users of this Web Site. Any Data used by such parties is used only to the extent required by them to perform the services that
ADME (CY) LTD requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with the Data Protection Act 1998. Notwithstanding anything contained in this Policy to the contrary, TheSoul Publishing will not process, store, or have access to any credit or debit card or other details related to the payment handling. All payment transactions are handled by a third-party payment processor, namely “Stripe”. Users are encouraged to review
Stripe’s Privacy Policy for more information on how their payment data is handled. This can be accessed directly via Stripe’s Privacy Policy, and generally
Stripe’s website.
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5.1 ADME (CY) LTD may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.
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5.2 In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller.
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6.1 Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
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6.1.1 use of Data for direct marketing purposes; and
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6.1.2 sharing Data with third parties.
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7.1 You may access certain areas of the Web Site without providing any Data at all. However, to use all Services and Systems available on the Web Site you may be required to submit Account information or other Data.
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7.2 You may restrict your internet browser’s use of Cookies. For more information see Clause 10 below.
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8.1 You may access your Account at any time to view or amend the Data. You may need to modify or update your Data if your circumstances change. Additional Data as to your marketing preferences may also be stored and you may change this at any time.
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8.2 You have the right to ask for a copy of your personal Data for free. We reserve the right to request the payment of a small fee should your requests be excessive, unfounded, or repetitive causing an administrative burden.
- 8.3 Any Data related requests shall be processed within reasonable time and in any case within 1 month from your written request. This period of time may be extended under certain circumstances by further 2 months.
Data security is of great importance to ADME (CY) LTD and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online. Moreover, we have procedures to deal with suspected data security breaches or threats and should a breach ever materialise, you will be notified accordingly, along with the supervisory authority, if we are required to do so.
ADME (CY) LTD reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.
We may operate within the European Union (EU), the European Economic Area (EEA), and other third countries, and therefore your Data or part of them may have to be transferred overseas. We have taken all reasonable steps to ensure that your Data are provided with adequate protection based on international protection frameworks and that all transfers of data are conducted pursuant to our written agreement and the supervisory authorities’ guidelines (if required) and/or other legal and/or regulatory requirements.
You will not be subject to decisions that will produce legal effects or have a significant impact on you, based solely on automated decision making.
Complaints may be lodged before the supervisory authority responsible for the protection of personal data, in the country of your habitual residence, place of work, or place of the alleged infringement of your Data. More information about how to contact the supervisory authorities across the EEA, can be found in the European Data Protection Board’s website
here.
If there are any questions regarding this privacy policy you may contact us at privacy@thesoul-publishing.com.
