PRIVACY POLICY.

PREFACE.

The present General Privacy Policy (hereinafter referred to as the “Privacy Policy”) is that of By KeepLighting LTD (hereinafter referred to as the “Company”). Your relationship with the Company on this Website shall be regulated separately by the present Privacy Policy.

This general Privacy Policy (hereinafter referred to as the “Privacy Policy”) shall govern the relationship between the user (hereinafter referred to as “You” or “Your”) and the Company (hereinafter referred to by “We”, “Our”, “Us”), including without limitation regarding the use, collection and processing of Personal Information as defined below on the Website. We highly care about Your privacy and data protection and take Your data protection rights and our legal obligations seriously.

Privacy Policy describes the policies and procedures adopted by us as to the collection, use and disclosure of the information on promocigar.com (referred to as the "Website"), as required by the applicable data protection laws and regulations including without limitation the European Union General Data Protection Regulation (Regulation 2016/679 - “GDPR”)

Thus, we have implemented a robust data protection compliance program, which includes the adoption of the high-standard data protection principles of the GDPR at a global level, such as inter alia the adoption of internal policies and procedures to ensure compliance with applicable data protection laws and regulations; and the implementation of appropriate technical and organizational measures to implement the data protection principles.

We receive information about You from various sources, including: (i) Your registration for the Website and the Service (as defined under the general Terms of Use), through your user account on the Services (referred to as your "Account"); and (ii) Your use of the Website and/or the Service generally.

When You use the Services on the Website, You are consenting to this Privacy Policy and to the collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, transfer, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction and other uses and processing of Your Personal Information (as defined below), as further detailed under this Privacy Policy and in accordance with its terms, for the purposes of providing You with the Services on the Website and for other purposes as may be defined under this Privacy Policy.

No processing whatsoever of our personal information shall intervene without our prior written consent and such processing shall in all events intervene in accordance with applicable data protection legislations and regulations. We reserve all our rights and protections as consecrated by applicable data protection legislation and regulations.

PRINCIPLES OF THE PRIVACY POLICY.

We do not rent or sell Your Personal Information. We do not share Your Personal Information with any third party except for purposes of complying with the applicable law, providing the Services You have requested, protecting our rights, or otherwise as provided in this Privacy Policy. We do not store Personal Information on our servers unless and only for the time required for the provision of the Services and/or for the on-going operation of one of our Services.

Your Personal Information is processed lawfully, fairly and in a transparent manner. It is further collected for specified, explicit and legitimate purposes and will not be processed further in a manner that is incompatible with those purposes.

The Personal Information we collect is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. Your Personal Information is accurate and, where necessary, kept up to date by us in accordance with the terms herein. Subject to the terms of this Privacy Policy, Your Personal Information is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.

SCOPE OF THIS PRIVACY POLICY.

Privacy Policy covers the treatment of personally identifiable information (referred to as "Personal Information") gathered while You are using or accessing the Service on the Website.

We value the privacy of Your Personal Information, and we have accordingly addressed, as applicable, the GDPR which grants individuals, including individuals in the European Union, under its scope of application more control over how their data is used, and it places certain obligations on businesses that process Personal Information of those individuals. We have addressed as well, in an effort to protect the privacy of Your Personal Information, local applicable data privacy laws.

We process the below described Personal Information, in relation to You, for as long as necessary for the provision of the Service and for the sole purposes of such provision of the Service.

We shall ensure (1) that persons authorized to process the Personal Information have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality and (2) the appropriate technical and organizational measures ensuring the security of the Personal Information have been taken such as pseudonymization and encryption of Personal Information, the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; and the ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical incident.

WHAT PERSONAL DATA DO WE COLLECT?

The information we gather enables us to personalize, improve and continue to operate and provide You with the Service. In connection with certain aspects of the Service, we may request, collect and/or display some of Your Personal Information. We collect the following types of information from our users:

o Account Information

We collect Personal Information, such as your email address, name, address, when you create an Account to use the Service on the Website. You acknowledge that this information may be personal to You, and by creating an account on the Service and providing Personal Information to us, You allow us to identify You.

Important Notice: When submitting any personal data, please ensure it is accurate and do not transmit any content which is not expressly requested through a questionnaire or any other collection method (such as commercial information, advertising, personal creations, ideas, or concepts).

o User content

Some features of the Service allow You to provide content to the Service, such as written comments. We may retain all the content that You submitted to the Service indefinitely, even after You terminate your Account, unless the content contains Personal Information, in which case we can retain the content for as long as necessary for the provision of the Service or You can request that the content be provided to You and/or be deleted.

o IP Address information and other information collected automatically

Some additional information is collected indirectly about You while browsing on the Website. This information is technically needed for the proper functioning of the Website, to improve Your browsing experience or in order for us to perform analytics that will enable us to serve You better by personalizing our Service.

Such information consists of the following:

• Technical information, such as IP address and cookies, linked to your browsing on the Website, for logging purposes and identification of your country/city via geolocation, noting that your browser automatically reports IP addresses each time you view a web page;

• Information relative to your online profile and Website usage data (such as behavioral analysis via cookies and similar technologies, your navigation trail of the Website);
• Personal data collected via media platforms and social networks (such as when You follow our pages on those social networks, Personal Information that You have designated as public and that can be publicly viewed on your social network profile).

IP addresses may be used for various purposes, including inter alia (i) to diagnose or service technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company; (ii) to tailor advertising based on geographic area or other information derived from your IP address whereby aggregate information derived from IP addresses may also be reported to advertisers; and (iii) to estimate the total number of users visiting the Services from specific geographical regions.

o Cookies

When consulting the Website and viewing our contents, information relating to the navigation of Your device (such as computer, tablet, smartphone) can be stored in files “cookies” installed on Your device, subject to the choices that You expressed regarding cookies and that You can modify at any time.

You can configure Your browser so that cookies are stored on Your device or on the contrary, rejected systematically or by the issuer. You can also configure Your browser so that the acceptance or rejection of cookies will be proposed from time to time, before a cookie is likely to be stored on Your device. It is important to note that if You refuse the storing of cookies on Your device, or if You remove those that are registered, You cannot benefit from a number of features that are necessary to the navigation in some areas of our Website. Registered and unregistered users can access and delete cookies through their web browser settings.

We use our own cookies for various purposes, including to:

• Access Your information when you “sign in”.
• Keep track of preferences You specify while You are using the Services.
• Keep track of Your design file choices.
• Store credentials You may use to enable posting to other sites.
• Estimate and report our total audience size and traffic.
• Conduct research to improve our content and services.

Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who You are. As noted, however, we do use cookies to identify that Your web browser has accessed aspects of the Services and may associate that information with your Account if You have one.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on Your computer. For instance, third party websites to which a link points may set cookies on Your computer.

o Personal Information

For the purposes of providing You the Service on the Website, the Personal Information we collect and processes include your name, Your company legal name, address, email address, identification number, phone number and title.

INFORMATION DISCLOSURE.

When You access or use the Service, we collect, use, share, and otherwise process Your Personal Information as described in this Privacy Policy. When You use the Service on the Website, You are consenting to the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, transfer, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction and other uses and processing of your Personal Information, as further detailed under this Privacy Policy and in accordance with its terms. We process Your Personal Information, when necessary, inter alia to provide You with the service on the Website.

Processing of Your Personal Information by us, shall be deemed as well lawful on the following lawful bases:

For compliance with a legal obligation;

To protect the vital interests of Yourselves or others; 

• In the public interest;
• For the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by Your interests or fundamental rights and freedoms which require protection of Your Personal Information.

Some of Your activity on and through the Service is public by default. This may include, but is not limited to, content You have posted publicly on the Website or otherwise through the Service, such as on message boards, in reviews and discussion areas, and within Your public profile page. Thus, such content becomes publicly available and can be collected and used by others.

We do not use Your email address or other Personal Information to send marketing messages unless You've opted in to receive such messages. We may, however, use Your email address without further consent for non-marketing or administrative purposes (such as for customer service purposes).

We shall not disclose Personal Information about You to other individuals or entities without your consent, except as necessary to provide the Service, and the preceding shall apply notwithstanding any clause to the contrary contained herein.

Your consent on the disclosure by us is not as well required in the following circumstances:

• We may be required to disclose Personal Information and/or non-personally identifiable information to comply with applicable laws and regulations, subpoenas, warrants, court orders or legal process or to establish or exercise our legal rights or defend against legal claims.
• It may be necessary to share Personal Information in order to investigate, prevent, or take action regarding suspected or actual illegal activities, including as permitted or required by laws or regulations.
• We reserve the right to disclose Personal Information and/or non-personally-identifiable information that we deem, in good faith, is appropriate or necessary to assist government enforcement agencies, or to protect the security or integrity of our Website, and to protect our rights, and property.
• We will transfer information about You if we are acquired by or merged with another company. In such instance, we (i) will notify You by email or by putting a prominent notice on the Website before information about You is transferred and becomes subject to a different privacy policy; (ii) reserve the right, in any of these circumstances, to transfer or assign the information already collected from our users as part of such merger, acquisition, sale, or other change of control. However, in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how Your Personal Information is treated, transferred, or used.

INFORMATION SHARING.

• We may contract with various third parties who help us provide and maintain the Website or the Service (referred to as our “Agents”). In this respect, we may need to share Personal Information with our Agents in order for us to provide the Service to You. Unless we inform You otherwise, our Agents do not have any right to use Personal Information or other information and we solely share with them what is necessary to assist us. Where such Agents are appointed, we shall bind them to contractual provisions providing data protection obligations identical to those contained herein including providing sufficient guarantees to implement appropriate technical and organizational security measures. You hereby consent to our sharing of Personal Information with our Agents for the above purposes. We will use commercially reasonable efforts to prevent such third parties from disclosing Your Personal Information.
• Subject to the other terms of this Privacy Policy, we limit access to Personal Information about You to our personnel on a strict need-to-know basis for purposes of providing the Service to You and for them to properly execute their scope of work. You hereby consent to our sharing of Personal Information with our employees for the above purposes. In the event Your data is transmitted to any data processor acting on behalf of us in the management of the Website, we shall use only processors providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the GDPR and ensure the protection of Your rights.

MODALITIES FOR THE EXERCISE OF THE RIGHTS.

• A right of access and information: You have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which Your Personal Information is processed including of the identity and the contact details of the data controller as applicable and, where applicable, of the controller’s representative; the contact details of the data protection officer, where applicable; the purposes of the processing for which Your personal data are intended as well as the legal basis for the processing; the recipients or categories of recipients of the Personal Information, if any; where applicable, the fact that we or the Data Controller as defined under the GDPR intends to transfer Personal Information to a third country; and the period for which the Personal Information will be stored, or if that is not possible, the criteria used to determine that period. You also have the right to obtain (i) confirmation as to whether or not Personal Information concerning You are being processed, and, where that is the case, the purposes of such processing, the object of the processing and its nature, the categories of Personal Information concerned, the categories of recipients of the data or of those who have access to the data, and the period for which the data is stored. Typically Your Personal Information will be stored as long as Your Account exists on the Website, and as long as necessary for the purposes of providing You with the Service; and (ii) to access such Personal Information and obtain a copy thereof.
• A right to rectification: You have the right to obtain the rectification of Your Personal Information without undue delay and in all events in accordance with the timeframes as set by the applicable laws. You also have the right to have incomplete Personal Information completed. Accordingly, You agree that it is Your responsibility to notify us of this fact at the below indicated mailing or postal address and to supply us with the accurate or complete information that will enable Us to address Your concerns accordingly.
• A right to erasure: You have the right to obtain the erasure of Your Personal Information including whereby, in accordance with the GDPR, the Personal Information are no longer necessary in relation to the purposes for which it was collected or otherwise processed, You withdraw Your consent on which the processing is based and where there is no other legal ground for the processing; You object to the processing in accordance with the GDPR and there are no overriding legitimate grounds for the processing; Your Personal Information has been unlawfully processed; the Personal Information have to be erased for compliance with a legal obligation. Where applicable, You shall have the right to obtain the erasure of Your Personal Information whereby the information becomes obsolete or is incompatible with the purposes of the processing or is prohibited to be processed, collected, used, stored or transferred. However, the right to erasure is not an absolute right and we may have legal or legitimate grounds for keeping such Personal Information in accordance with the GDPR.
• A right for the restriction of processing: In accordance with the GDPR, You shall have the right to obtain the restriction of processing of Your Personal Information, for a period enabling us to verify the accuracy of the Personal Information; and where the processing is unlawful and You oppose the erasure of the Personal Information and requests the restriction of its use instead.
• A right to data portability: You have the right to receive Your Personal Information which You have provided, in a structured, commonly used and machine-readable format, and You have the right to transmit those data to another controller without hindrance. This right, under the terms of the GDPR, only applies when the processing of Your Personal Information is based on Your consent or on a contract and such processing is carried out by automated means.
• A right to object to processing: In accordance with the terms of the GDPR, You have the right to object to processing of Your Personal Information which is based on the legitimate interests pursued by us or by a third party or which is necessary for the performance of a task carried out in the public interest. We may, however, invoke compelling legitimate grounds for continued processing. You also have the right to object at any time to the processing of Your Personal Information for marketing purposes. Where applicable, the right to object is not absolute, and You may not exercise Your right to object whereby we are compelled by law to collect the Personal Information and You have consented to the processing of Your Personal Information.
• A right to withdraw Your consent: In accordance with the GDPR, where applicable, You shall have the right to withdraw Your consent to processing at any time. The withdrawal of consent shall not affect the lawfulness of processing based on Your consent before its withdrawal.

To exercise the above rights please contact us via the email provided below and communicate the following information: name, surname, e-mail or any other information necessary to confirm your identity in order for us to process the request (such as your postal address).

You can delete your Account at any time. Please note in this respect that (i) Your identification and contact information may however remain in our records for a period of 2 years; (ii) any association between Your Account and information we store will no longer be accessible through Your Account; and (iii) any public activity on your Account prior to deletion may remain stored on our servers and may remain accessible to the public unless removed pursuant to Your request.

Finally, You have the right to lodge a complaint with the competent supervisory authority in case of breach of the GDPR, as applicable to You.

DATA SECURITY AND CHANGE OF CONTROL.

Your Account information is password-protected and thus You need to prevent unauthorized access to Your Account and Personal Information by selecting and protecting Your password appropriately and limiting access to Your device and browser by signing off after You have finished accessing your Account. We use commercially reasonable physical, managerial, and technical safeguards, such as commercially available encryption protocols, to preserve the integrity and security of Your Personal Information. Once we receive your transmission of information, we make commercially reasonable efforts to ensure the security of our systems.

However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by violation of any of our physical, technical, or managerial safeguards for reasons outside of our control.

When a Personal Information breach is likely to result in a high risk to Your rights and freedoms, we shall communicate to You the personal data breach without undue delay.

MODIFICATIONS AND UPDATES TO THIS PRIVACY POLICY.

This Privacy Policy may be revised at any time, without notice, and such amendments shall be applicable as from the day they are published on the Website. Thus, we invite You to regularly consult the present page to stay aware of any such amendments. Your continued use of the Website and of the Service constitute your agreement and consent to the so updated Privacy Policy.

For revisions of this Privacy Policy that may be materially less restrictive on our use or disclosure of the Personal Information that You have already provided to us, we will attempt to obtain your consent before implementing such revisions with respect to such information.

In all events our Privacy Policy will remain subject to the terms of the GDPR as applicable and to any other applicable data privacy laws.

If You have a complaint regarding our compliance with the applicable laws and regulations (including the above-mentioned laws and regulations), first contact us to informally resolve Your complaint.

HOW TO CONTACT US FOR PRIVACY QUERIES.

If You have any questions You wish to ask us, or requests to address to us, or concerns regarding the Privacy Policy for the Services, please contact us at [email protected] We will make every effort to properly and without undue delay respond to Your inquires, requests and resolve Your concerns.

We may ask You to provide additional information for identity verification purposes, or to verify that You are in possession of an applicable email account.