Privacy policy

Privacy and Cookies Policy

Version 1.0 – Last updated 5th October, 2015.

Go Beyond Limited understands the importance of protecting the data received or collected and approved this Privacy and Cookies Policy to inform users of its website about the collection and use of their personal data.

This Privacy and Cookies Policy provides the conditions, procedures, and purposes of collecting, using, processing, storing, disclosing, transferring and deleting of the user’s personal information, as well as the conditions of the user’s personal information protection.

This Policy explains how an Investor can view, update and request to delete Personal Data as stipulated under the Governing Law. This Policy also provides the conditions, procedures, and purposes of the use and storage of cookies by the Administration.

This Policy is applied for the Website and the services offered via the Website.

Any use of the Website shall mean that you are acquainted and you agree with this Policy and unconditionally accept all its terms.

If you do not agree with any conditions of this Policy, you have no right to further use the Website. In such case, please leave this Website and do not use any services offered through the Website.

Definitions

1.The following words and terms, should be interpreted as follows, unless, the context clearly implies otherwise:

(i)“Account” shall mean the personal account opened by a User and maintained by the Company so as to allow a User to make use of the Services; 

(ii)“Administration” shall mean the employees of the Company;

(iii)“Company” shall mean Go Beyond Ltd, a private limited liability company registered under the laws of Malta with company number C 28207, having its registered address situated at 93, Mill Street, Qormi QRM 3102, Malta;

(iv)“Governing Law” shall mean the Laws of Malta;

(v)“Personal Data” shall have the same meaning attributed thereto under article 2 of the Data Protection Act, Chapter 440 of the Laws of Malta.

(vi)“Policy” shall mean this Privacy and Cookies Policy;

(vii)“Services” shall mean the services offered by the Company and that are available through the Website;

(viii)“User” shall mean the individual who has accessed the Website and/or who makes use of the Services;

(ix)“Website” shall mean the website [insert link] and all other websites connected to it and accessible through links or other access paths and the services available through such sites;

Obligations

2.The Company is committed to respecting the privacy of the User whilst complying with all applicable data protection laws as established under the Governing Law.

3.The Company ensures that the User’s Personal Data is processed fairly, lawfully and in accordance with good practices and is only collected for specific purposes which are known and accepted by the User.

4.The Company is registered with the Data Protection Commissioner in Malta and adheres to the Data Protection Act, Chapter 440 of the Laws of Malta and any other relevant regulations, legal notices and/or similar rules in Malta.

5.This Policy covers all resources, materials, services, online forms and means of communication used, offered or present within the Website.

6.The Company assures that all that is reasonably possible has been put in place so that Personal Data is at all times:

a.processed in accordance with User’s rights;

b.processed fairly and lawfully;

c.obtained only for a specific and lawful purpose;

d.adequate, relevant and not excessive to the purpose of collection;

e.accurate and updated;

f.kept in a secure manner;

g.not kept longer than is necessary for the purpose of collection;

h.not transferred to jurisdictions which do not ensure adequate protection of Your Personal Data; and

i.is only utilized for the reasons disclosed herein.

7.Personal Data received by the Company can only be accessed by the Company’s employees and representatives as well as the affiliates of the Company in possession of the required clearance. All persons who have access to such Personal Data are required to comply with the terms of this Policy and are contractually obliged through their employment contract or other agreement to keep such information strictly confidential even after the employment with the Company has been terminated.

8.The Company is committed to take all reasonably possible organizational and technical measures to protect the User’s Personal Data from illegal or accidental access, destruction, alteration, blocking, copying, distribution, as well as other illegal actions of third parties.

9.The Company has adopted the best practices when it comes to the principle of protection of e-mail communication with You and protection of any other method of communication which might be necessary from time to time.

10.Data protection legislation may differ in different countries. The Company will strive to follow the conditions of this Policy as much as possible and will protect the User’s Personal Data as much as possible, regardless of where it has been collected and/or how it has been transmitted.

11.The Company may only transfer Personal Data to third countries if the third country has an adequate level of Personal Data protection or if such transfer is required for conclusion or performance of any Service requested by the User. [t1] 

Collection of Personal Data

12.The Company shall have the right to request from the User any relevant information in order to enable the use of the Website or the Services. This information may include any information provided in the course of filling special forms in the Website, information provided during registration, subscription to services, publication of materials and request for other services, including e-mail, phone number and identification data.

13.If the User starts any correspondence with the Administration, the Administration has a right to store all this correspondence.

14.The Administration may ask the User to take part in surveys and request certain information in the course of surveys but this is not a mandatory procedure and any User may refuse to participate.

15.The User’s browser or program may transfer certain information about the details of visits to the Website, including the information about traffic, log-files, the data about geographical location of the User’s computer and its possibilities, and other information. The User hereby accepts that the Administration may use this information for the purposes and in accordance with the procedures established in this Policy.

16.The Administration may request other information from the User to carry out the Services, including  sex, age, date of birth, and other preferences or data

User’s Consent

17.If in the Account’s registration form or any other registration form used in the Website or Services, the User furnishes any Personal Data, such provision means that the User has expressly given his direct and definite consent to this Policy.

18.Personal Data shall only be collected for legal ends and in particular shall be collected for the hereunder reasons:

a.verification of  User’s details;

b.registering an Account with the Company;

c.promotion and marketing of activities;

d.compliance with applicable laws;

e.providing the User with any additional services that the Company may offer; and

f.performance and fulfillment of this Policy.

19.The Company shall have the right to collect and make any use it deems fit of any information which is not deemed to be Personal Data according to the Governing Law, and the User hereby accepts that the Company may disclose to any third parties such non-Personal Data.

20.The User has the right to object to the processing and collection of his Personal Data and has the right to withdraw such consent at any time, except where otherwise determined by the Governing Law. Whenever such a User withdraws his consent, he understands and accepts that this may have a negative influence on the quality of the Services or Website as well as may cause the impossibility of access to the Website or Services and the User hereby agrees that the Company shall have no liability for any loss and/ or damage to the User’s Personal Data in such a scenario.

Use and processing of Personal information

21.The User hereby further accepts that the Company shall have the right to store and process the Personal Data provided, which the Company deems necessary in order for the User to make use of the Website or Services. The User further accepts and understands that all activities within the Website are logged.

22.The Personal Data that is disclosed by the User is collected and processed by the Administration for the purposes of appropriate and qualitative provision of the Services to the User, for the purpose of development and improvement of the Website, to perform this Policy and other actions specified in the Website or Services.

23.The processing of Personal Data are collection, recording, systematization, classification, storage, accumulation, updating, modification, grouping, blocking, use, disclosure, transfer to the third parties, dissemination, destruction, deletion, and other actions necessary for the performance of this Policy.

24.The Administration does not sell the User's Personal Data and does not disclose such information to third parties, except as provided in this Policy. The Administration may disclose the general demographic and statistical information to business partners or advertisers. This is not directly related with the Personal Data and cannot identify nor relate to a specific User.

25.To ensure proper provision of services, the Administration has the right to transfer Personal Data to other persons or organizations that provide hosting services, payment services and services related to sending e-mails. These persons and organizations have the right to use the received Personal Data for the sole purpose of providing services to Users and are to be bound by the terms of this Policy and by other agreements ensuring the proper use of the Personal Data furnished.

26.The User accepts that the Company shall have the right to transfer the Personal Data provided to any affiliates of the Company for the purpose of appropriate and high-quality provision and improvement of the Website or Services and for the performance of the Services and this Policy.

27.If the Company merges with another company in the future through the process of reorganization and/or merger and/or sale and/or acquisition and/or liquidation and/or through any other process, the User(s)'s Personal Data may be transferred along with the Company or its part, or it may be sold as part of the Company.

28.The User accepts that the Company shall have the right and the obligation to disclose Personal Data when ordered to do so by a decision deriving from the Governing Law and/or any other reputable jurisdiction and/ or when ordered to do so by order of the Regulatory Authority and/or when ordered to do so by order of the Data Protection Commissioner and/or in the event of User being directly and/or indirectly involved in any crime which somehow involves the Website and/or the Services.

Storage of personal information

29.The Administration will take all the necessary measures for the proper and safe storage of the User’s collected Personal Data in accordance with the conditions of this Policy. All information provided by User is stored on the servers of the Administration.

30.The Administration shall use a standard technology which includes firewalls to ensure the safety of the Personal Data.

31.The User is obliged not to disclose or transfer his/her identity or Account details, which are used for authorization in the Website or in the Services. User is fully responsible for storage of his Account information.

32.If User becomes aware that his/her Account information have been stolen and/ or are in the possession of any third party, User shall immediately inform the Company about such circumstances so that the Company can take the necessary measures. In such cases the Company cannot guarantee the safety of User’s Personal Data and User hereby accepts that the Company shall not be held liable for any use of this Personal Data.

Cookies, IP-addresses and log-files

33.The Administration may collect and process information about the User’s computer, log files, including IP-address, type of operating system, browser and e-mail client, information about the traffic, date and time, details of visits to the Website, user activity, information about accesses, settings and system notifications. This information about the Users’ actions in the Website is collected and stored for the purposes of systems administration, ensuring due functioning of the Website, proper provision of Services and for the purposes of safety and strengthening of protection and ensuring system integrity (prevention of hacker attacks, unauthorized access).

34.The Administration makes use of cookies in order for the Website to function properly. Cookies are small bit record-keeping text information that are automatically created and stored in User’s computer/ other equipment in order to associate and identify activity with User (hereinafter referred to as “Cookies”). Cookies do not typically include names and/or email addresses and/or other Personal Data, in fact they typically contain anonymous information which is required for the better functionality of the Website.

35.Cookies stored in a User’s computer/ any other equipment through which the User makes use of the Website and/or Services. Cookies have amongst others but without limitation, the following functions:

a.the provision of access to secured areas which User has requested, without these Cookies, services you have requested like secure login areas cannot be provided;

b.Visit Cookies - remembering the choices and/ or settings User has made and to enable User recognition when making use of the Website. Without such Cookies the functionality of the Website may be impaired;

c.Voting (Survey) Cookies - marking the items of any survey for which User has cast a vote and prevent User from voting again in the same survey;

d.Loading Balancing Session Cookies- improving the Website’s loading time by spreading workload and timing optimization of game services. Without these Cookies the functionality of the Website or Services may be lost;

e.User Interface customization cookies which make it possible to save the User’s interface settings in case of repeat entry to the Website;

f.Cookies placed and used for synchronization with the User’s data in social networks.

g.Performance (Analytics) Cookies - collecting anonymous information on how User makes use of the Website;

h.Advertising Cookies - delivering User with the most relevant advertisement and help improve the effectiveness of advertisement campaigns. User hereby accepts and agrees that the Company may make use of these cookies for its own advertisement campaigns.

36.Administration may also allow certain third parties to put and make use of their own web performance (analytics) and advertisement cookies on the User’s equipment and to collect information from the Company’s Cookies, for the purposes of storage and analysis of information about the Users’ preferences and to improve the quality of services. At this case such third parties are bound by this Policy. Administration guarantees that it shall exclusively allow reputable third parties to make such use.

37.By using the Website the User has understood and accepted this Policy and expresses his/her direct and definite consent that Administration  may  put, store and make use of cookies in User’s computer/ any other equipment through which the User make uses of the Website. Administration may continue to presume that User consents to this Policy until and/ or unless User has disabled cookies through browser settings as provided herein. By providing this consent, User gives Administration a possibility to better understand Users and their preferences, develop and improve the quality of services all the time considering Users’ interests. User hereby agrees that without enabling Cookies the Website may not function properly.

38.Administration guarantees that the stored cookies are safe for Users and absolutely necessary for normal functioning of the Website and for providing the Services to the Users.

39.The Cookies are stored for no more than one year. The terms of Cookies storage by the third party shall be established by such third party.

40.User may at any time refuse to accept Cookies and disable Cookies by changing his/her browser settings. Disabling Cookies may have a negative influence on the quality of the Website or the Services and may also cause the impossibility to access the Website or Services. The User hereby agrees that the Company shall have no liability for any loss and/ or damage to User information in case User has disabled cookies.

Obtaining and Changing Your Personal Data

41.You shall have the right to contact the Company at any time in order to obtain a copy of Your Personal Data which the Company has stored and to have any inaccuracies corrected where appropriate. You shall have a right to request that Your Personal Data be erased, rectified, amended or completed. To contact the Company regarding Your Personal Data You should e-mail on [insert e-mail address].

Refusal to provide any Personal Data

42.Any Personal Data provided by the User to the Company is provided on a voluntary basis. Nonetheless the Company cannot guarantee that the Website or Services shall function properly and/or shall function at all in case of failure to provide any Personal Data when requested.

Changes of the Policy

43.This Policy is valid as of the date of the last version. This Policy may be changed, amended, replaced in any form and at any time without prior or following notification of User, so we recommend to look through this Policy from time to time to be informed of all changes. Any further use of the Website means unconditional acceptance of the modified version of this Policy.

Contacts with Administration

44.If you have any questions, remarks, complaints or comments regarding this Policy, please contact us at [insert e-mail address]. We will consider and reply to your questions as soon as possible.

45.The Administration may decline any unreasonably frequent requests, which require disproportionate technical efforts, jeopardize the privacy of other Users or are extremely impractical.

46.If User starts any correspondence with Administration or submits a report about problems with the Website or Services, the Administration shall have the right to store all this correspondence.