Last Updated: DATE
1. Purpose.
Demerzel Solutions Limited (“Nethermind”, “The Company”, “we”, “us”) is committed to protecting your Personal Information when you use our website, products and services. We recognise that when you choose to provide us with information about yourself, you trust us to treat it in a responsible manner.
The purpose of this Website Privacy Policy is to inform you about how the Company may use your Personal Information when you visit our website at https://voyager.online/ (“Site”) or when you have other interactions with us.
In order to optimise the provision of our services to you and to facilitate some of our marketing efforts, we collect certain specific information about you.
This Website Privacy Policy explains the following:
The Company uses all Personal Information that you provide to us or that we collect from you in accordance with all applicable laws, including those concerning the protection of Personal Information such as the UK General Data Protection Regulation.
2. Terms of Use.
This Website Privacy Policy forms part of our Terms of Use available at https://voyager.online/ (“Terms”).
3. Definitions.
UK GDPR : the UK General Data Protection Regulation (“UK GDPR”) is a regulation in UK law on data protection and privacy, introduced following the UK’s exit from the European Union. The primary aim of the UK GDPR is to give control to individuals over their personal data and to ensure the UK data protection regime remains adequate for the purposes of cross-border data transfers with EU Member States.
Data Protection Law : all legislation and regulations in force from time to time regulating the use of personal data and the privacy of electronic communications including, but not limited to, the UK GDPR and the Data Protection Act 2018, which should be read together.
Encryption or encrypted data : The most effective way to achieve data security. To read an encrypted file, you must have access to a secret key or password that enables you to decrypt it. Unencrypted data is called plain text.
ICO : Information Commissioner’s Office. The supervisory authority for data protection in the UK.
Personal Data : any information relating to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data. The terms Personal Data and Personal Information are used interchangeably within this policy.
Personal Data Breach : a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Special Categories of Personal Data : this data needs more protection because it is sensitive. It includes data which relates to an individual’s health, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
Business Contact : an individual employee, consultant or agent of a business or other commercial organisation we engage with in relation to our business or Services.
User : any person accessing our Site.
4. Scope.
This Website Privacy Policy applies only to the actions of the Company and use of the Site.
The Site may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, and are also likely to use cookies. We recommend that you review these policies which will govern the use of Personal Information which you submit when visiting these websites and which may also be collected by cookies. We do not accept any liability for such third party websites and your use of such websites is at your own risk.
5. The Collection and Use of Data.
5.1. What information do we collect.
When you participate in, access or sign up to any of the Company’s services, activities or online content (including on social media and messaging applications), such as newsletters, promotions, live chats, message boards, web and mobile notifications or votes, we may receive Personal Information about you.
We may collect, use, store and transfer different kinds of such data about you which we have grouped together as follows:
The Company does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5.2. How do we collect information.
We use different methods to collect data from and about you including through:
5.3. If you fail to provide personal data.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5.4. How will we use the information?
Depending on your use of our Site, we will use your personal information for a number of purposes including:
To provide our services, activities or online content, or communicating information about them (e.g. relating to upcoming promotions or new product launches) or dealing with your requests and enquiries.
To provide you with better ways of accessing information from this Site.
To perform the contract we are about to enter into or have entered into with you.
For service administration, which means that we may contact you for reasons related to the service, activity or online content you have signed up for.
To contact you about any submission you have made.
To use IP addresses and device identifiers to identify the location of users, blocking disruptive use, establishing the number of visits from different countries, tailoring the content of our sites, apps or other services based on browsing behaviours, and determining the country from which you are accessing the services.
For analysis and research so that we may improve the services we offer.
Where we need to comply with a legal obligation.
We collect and use the Personal Information about you for the purposes described above, because we have a legitimate business interest to do so that is not overridden by your right to have your Personal Information adequately protected. You do not have to provide us with any of the Personal Information described above, but if you choose not to do so, you may not be able to receive certain Company services, access certain parts of our Site or receive information from us that you have requested.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
5.5. Change of Purpose.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5.6. Data aggregation.
The Company may collect, use and share aggregated data.
Aggregated data could be derived from your Personal Information but is not considered Personal Data under the UK GDPR on the basis that it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. The Company may share this anonymous data with third-parties.
For the avoidance of doubt, if the aggregated or combined data we hold on you can directly or indirectly identify you, the Company treats the data as Personal Data which will be used in accordance with this Policy.
5.7. Sharing information with third parties.
We may send your personal information to other affiliates and third parties to help us process your personal information for the purposes set out in this policy, such as:
Service Providers, including those who provide:
Professional Advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Corporate Partners, including third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We may disclose personal information to third parties when we reasonably believe we are required by law, and in order to investigate, prevent, or take action regarding suspected or actual unlawful or otherwise prohibited activities, including, but not limited to, fraud.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5.8. Where do we send your information.
The Company may be required to transfer personal data to a country/countries around the world including countries in Europe, US, Asia, Africa.
If we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
The country has been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office.
If we use certain service providers based outside the UK, we may use specific contracts approved by the ICO which give personal data the same protection it has in the UK.
In any other case, we will obtain your explicit consent before any transfer takes place.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
6. Site Analytics and Cookies.
The Company has minimised its collection of user personal data by employing a privacy-first analytics solution. By using Plausible Analytics, the Company ensures that all the Site measurement is carried out absolutely anonymously. Cookies are not set and no personal data is collected as part of our Site analytics. All data is in aggregate only.
We do not track users across their devices and across websites and applications that they visit. All the data is isolated to a single day, single device and the Site only.
6.1. Use of Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org. You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser.
While the Company at present does not collect cookies, we reserve the right to do so in the future, without any notice given to users. The Website Privacy Policy will be updated accordingly should this become the case.
We reserve the right to use cookies that fall into one or more of all the categories below:
Strictly necessary cookies – these enable services you have specifically asked for. Without these cookies certain services you have asked for cannot be provided.
Performance cookies – these collect information on the pages visited. These cookies collect information about how users use a website, for instance which pages users go to most often, and if they get error messages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. They are only used to help make improvements to the website for a better user experience.
Functionality cookies – these remember choices you make to improve your experience. These cookies allow the website to remember choices you make and provide enhanced, more personal features. They may be used to help provide services you have asked for such as watching a video. The information these cookies collect may be anonymised and they cannot track your browsing activity to other websites.
7. Keeping Data Secure.
7.1. Third Party Websites.
Our Site may link to third party sites which we do not operate or endorse. These websites may use cookies and collect your personal information in accordance with their own privacy policies. This privacy policy does not apply to third party websites and we are not responsible for third party websites.
7.2. How do we protect your information?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7.3. Data Retention.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. What are Your Rights?
Under the UK GDPR, you have the following rights, which the Company will always work to uphold:
Right to access - for a copy of the Personal Information we hold about you, and details about how we are processing your Personal Information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
8.1. Right to opt out.
You can request that we stop sending you marketing materials at any time, by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase.
8.2. How to contact us.
This Website Privacy Policy should tell you everything you need to know, but you can always contact our data privacy manager to ask any questions or if you wish to exercise any of your rights in relation to your Personal Information, using the contact information below:
legalnotices@nethermind.io
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint to the supervisory authority if you are unhappy with how we’ve handled your Personal Information. In the UK, the supervisory authority is the Information Commissioner’s Office (http://www.ico.org.uk).
9. Changes to the Privacy Policy.
We may change this Website Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.
Any modification to this Website Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the Site or Services after the posting of any modified Website Privacy Policy indicates your acceptance of the modified terms.