09.03.2020

Privacy and cookies policy

Privacy and cookies policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and
customers; in this policy we explain how we will handle your personal data.
1.2 This policy applies where we are acting as a data controller with respect to
your personal data; in other words, where we determine the purposes and
means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly
necessary for the provision of our website and services, we will ask you to
consent to our use of cookies when you first visit our website.
1.4 In this policy, "we", "us" and "our" refer to Fastnetmon LTD. For more
information about us, see Section 14.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage
data"). The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit,
page views and website navigation paths, as well as information about the
timing, frequency and pattern of your service use. The source of the usage
data is our analytics tracking system. This usage data may be processed for
the purposes of analysing the use of the website and services. The legal basis
for this processing is our legitimate interests, namely monitoring and
improving our website and services.
2.3 We may process your account data ("account data"). The account data may
include your name and email address. The source of the account data is you
or your employer. The account data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.
2.4 We may process information contained in any enquiry you submit to us
regarding goods and/or services ("enquiry data"). The enquiry data may be
processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is consent.
2.5 We may process information relating to our customer relationships, including
customer contact information ("customer relationship data"). The
customer relationship data may include your name, your employer, your job
title or role, your contact details, and information contained in
communications between us and you or your employer. The source of the
customer relationship data is you or your employer. The customer relationship
data may be processed for the purposes of managing our relationships with
customers, communicating with customers, keeping records of those
communications and promoting our products and services to customers. The 
legal basis for this processing is our legitimate interests, namely the proper
management of our customer relationships.
2.6 We may process information relating to transactions, including purchases of
goods and services, that you enter into with us and/or through our website
("transaction data"). The transaction data may include your contact details,
your card details and the transaction details. The transaction data may be
processed for the purpose of supplying the purchased goods and services and
keeping proper records of those transactions. The legal basis for this
processing is the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract and our legitimate
interests, namely the proper administration of our website and business.
2.7 We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters ("notification
data"). The notification data may be processed for the purposes of sending
you the relevant notifications and/or newsletters. The legal basis for this
processing is the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
2.8 We may process information contained in or relating to any communication
that you send to us ("correspondence data"). The correspondence data
may include the communication content and metadata associated with the
communication. Our website will generate the metadata associated with
communications made using the website contact forms. The correspondence
data may be processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website and business and
communications with users.
2.9 We may process any of your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure. The
legal basis for this processing is our legitimate interests, namely the
protection and assertion of our legal rights, your legal rights and the legal
rights of others.
2.10 We may process any of your personal data identified in this policy where
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice. The legal basis for this
processing is our legitimate interests, namely the proper protection of our
business against risks.
2.11 In addition to the specific purposes for which we may process your personal
data set out in this Section 2, we may also process any of your personal data
where such processing is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital
interests of another natural person.
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional
advice, or the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure.
3.2 Financial transactions relating to our website and services are handled by our
payment services providers, listed at our site
https://fastnetmon.com/fastnetmon-ltd-subprocessors-and-subcontractors/.
We will share transaction data with our payment services providers only to the
extent necessary for the purposes of processing your payments, refunding
such payments and dealing with complaints and queries relating to such
payments and refunds. You can find information about the payment services
providers' privacy policies and practices at their official sites.
3.3 We may disclose your personal data to one or more of those selected third
party suppliers of goods and services identified on our website
https://fastnetmon.com/fastnetmon-ltd-subprocessors-and-subcontractors/ for
the purpose of running our business and site.
3.4 In addition to the specific disclosures of personal data set out in this Section
3, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person. We
may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which
your personal data may be transferred to countries outside the European
Economic Area (EEA).
4.2 The hosting facilities for our website are situated in UK, Netherlands,
Germany, US. The European Commission has made an "adequacy decision"
with respect to the data protection laws of each of these countries.
4.3 Our payment, site performance, subscription and support system contractors
are situated in US. The European Commission has made an "adequacy
decision" with respect to the data protection laws of each of these countries.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept
for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) All personal data requested during checkout process will be retained for
a minimum period of 3 years following date when you close your
account and cancel all active subscriptions, and for a maximum period
of 5 years following date when you close your account completely.
5.4 In some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will determine
the period of retention based on the following criteria:
(a) the period of retention of all personal data will be determined based on
period from 3 to 5 years. We keep this data for this time to comply with
legal regulation and protect us from any possible issues .
5.5 Notwithstanding the other provisions of this Section 5, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or
the vital interests of another natural person.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on
our website.
6.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.
6.3 We may notify you of significant changes to this policy by email or through
the private messaging system on our website.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant
laws and guidance from the regulatory authorities for a full explanation of
these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your
personal data and, where we do, access to the personal data, together with
certain additional information. That additional information includes details of
the purposes of the processing, the categories of personal data concerned
and the recipients of the personal data. Providing the rights and freedoms of
others are not affected, we will supply to you a copy of your personal data.
The first copy will be provided free of charge, but additional copies may be
subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified
and, taking into account the purposes of the processing, to have any
incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for
exercising the right of freedom of expression and information; for compliance
with a legal obligation; or for the establishment, exercise or defence of legal
claims.
7.6 In some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the 
personal data; processing is unlawful but you oppose erasure; we no longer
need the personal data for the purposes of our processing, but you require
personal data for the establishment, exercise or defence of legal claims; and
you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store
your personal data. However, we will only otherwise process it: with your
consent; for the establishment, exercise or defence of legal claims; for the
protection of the rights of another natural or legal person; or for reasons of
important public interest.
7.7 You have the right to object to our processing of your personal data on
grounds relating to your particular situation, but only to the extent that the
legal basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of
any official authority vested in us; or the purposes of the legitimate interests
pursued by us or by a third party. If you make such an objection, we will cease
to process the personal information unless we can demonstrate compelling
legitimate grounds for the processing which override your interests, rights and
freedoms, or the processing is for the establishment, exercise or defence of
legal claims.
7.8 You have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to process your personal data for this
purpose.
7.9 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to
which you are party or in order to take steps at your request prior to
entering into a contract,
and such processing is carried out by automated means, you have the right to
receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.
7.10 If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member
state of your habitual residence, your place of work or the place of the alleged
infringement.
7.11 To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any
time. Withdrawal will not affect the lawfulness of processing before the
withdrawal.
7.12 You may exercise any of your rights in relation to your personal data by
contacts published on our site https://fastnetmon.com/contact/.
8. Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and
practices of third parties.
9. Updating information
9.1 Please let us know if the personal information that we hold about you needs to
be corrected or updated.
10. About cookies
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that
is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.
10.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set expiry
date, unless deleted by the user before the expiry date; a session cookie, on
the other hand, will expire at the end of the user session, when the web
browser is closed.
10.3 Cookies do not typically contain any information that personally identifies a
user, but personal information that we store about you may be linked to the
information stored in and obtained from cookies.
11. Cookies that we use
11.1 We use cookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit our
website and as you navigate our website;
(b) status - we use cookies to help us to determine if you are logged into
our website;
(c) shopping cart - we use cookies to maintain the state of your shopping
cart as you navigate our website;
(d) personalisation - we use cookies to store information about your
preferences and to personalise our website for you;
(e) security - we use cookies as an element of the security measures used
to protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally;
(f) advertising - we use cookies to help us to display advertisements that
will be relevant to you;
(g) analysis - we use cookies to help us to analyse the use and performance
of our website and services (cookies used for this purpose are: [identify
cookies]); and
(h) cookie consent - we use cookies to store your preferences in relation to
the use of cookies more generally.
12. Cookies used by our service providers
12.1 Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.
12.2 We use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google's privacy policy is available at:
https://www.google.com/policies/privacy/.
12.3 We use Yandex Metrica to web site analytics. This service uses cookies for web
site visitor reports. You can view the privacy policy of this service provider at
https://yandex.com/legal/metrica_agreement/.
13. Managing cookies
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies.
The methods for doing so vary from browser to browser, and from version to
version. You can however obtain up-to-date information about blocking and
deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookieswebsite-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-andprivacy (Edge).
13.2 Blocking all cookies will have a negative impact upon the usability of many
websites.
13.3 If you block cookies, you will not be able to use all the features on our
website.
14. Our details
14.1 This website is owned and operated by Fastnetmon LTD.
14.2 We are registered in England and Wales under registration number 10667417,
and our registered office is at 20-22 Wenlock Road, London, N1 7GU.
14.3 You can contact us:
(a) using our website contact form; or
(b) by email, using the email address sales@fastnetmon.com.