Effective Date: April 1, 2022
Our Site is owned and operated by NADEL.
For our international visitors, NADEL is a company registered in England and Wales under company number 03999489; with a registered address: Monmouth House, 87-93 Westbourne Grove, London W2 4UL.
For our US visitors, NADEL is a US company with the principle place of business at 5820 Uplander Way, Culver City, CA 90230. You can contact us using the contact particulars noted below.
This Policy applies only to Personal Data. Personal Data is information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Personal Data is, in simpler terms, any information about you that enables you to be identified. Personal Data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
LEGAL BASIS FOR PROCESSING PERSONAL DATA
We may use Personal Data for our legitimate business interests that include marketing our goods and services, running Our business, as well as engaging and developing great talent. Our processing of Personal Data collected from Our websites is based primarily on this justification. However, some uses of Personal Data is necessary to comply with applicable legal or regulatory requirements.
What Data Do We Collect and How?
INFORMATION WE COLLECT FROM YOU
We will collect and process the following Personal Data about you:
- Information that you provide by filling in forms on Our Site. This includes information provided when subscribing to Our services (for example to receive information from us), posting material or requesting further information. We may also ask you for information when you enter a competition or promotion online and when you report a problem with Our site.
- If you contact us, We may keep a record of that correspondence.
- We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
- Technical details of your visits to Our site including, traffic data, location data, weblogs and other communication data, and the resources that you access. This may or may not include Personal Data.
We obtain information from you in three ways:
- either by you typing your personal details in,
- by the automatic collection of information about you as you use Our websites,
- or from third parties.
Even though We can automatically process Personal Data, We will not use solely automated means of processing your Personal Data in such a way to have any significantly adverse impact to you.
Please note that information that cannot reasonably be related to you is not considered Personal Data and is not subject to this Statement. Only information which can be connected to you is subject to this Statement.
IP ADDRESSES AND COOKIES
If you are only browsing Our website and have not logged in, We will not ask you to directly submit in any Personal Data. However, certain information (which may be considered Personal Data) - including computer and connection information, browser type and version, operating system and platform details and the time of accessing the website – will be automatically collected.
How Do You Use My Personal Data?
Generally, We use Personal Data held about you in the following ways:
- To ensure that content from Our site is presented in the most effective manner for you and for your computer.
- To provide you with the information, products and services that you request from Us or which We feel may interest you.
- To allow you to participate in interactive features of Our sites.
- To notify you about changes to what We do.
- To protect the integrity of Our website, Our services, and Our reputation.
- To prosecute or defend legal claims.
- To protect other users of Our websites, and to ensure no unlawful or unethical activity occurs through Our systems.
We may also use your Personal Data, or permit selected third parties to use your Personal Data, to provide you with information about goods and services which may be of interest to you and We or they may contact you about these by post or telephone.
With your permission and/or where permitted by law, we may also use your Personal Data for marketing purposes, which may include contacting you by email with information, news, and offers on our products or services.
We will only use your Personal Data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your Personal Data for that purpose. If we need to use your Personal Data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your Personal Data without your knowledge or consent. This will only be done within the bounds of applicable data protection law and your legal rights.
Disclosure of Your Personal Data
We may disclose your Personal Data to any affiliate of NADEL. Additionally, We may disclose your Personal Data to third parties:
- For any of the purposes described in this Policy, where such disclosure is for the third party providing services to NADEL. Such third party service providers will be under contractual obligations to protect your Personal Data in accordance with this Policy.
- In the event that We sell or buy any business or assets, in which case We may disclose your Personal Data to the prospective seller or buyer of the business or assets.
- If NADEL or substantially all of its assets are acquired by a third party, in which case Personal Data held will be one of the transferred assets. Similarly, your personal information may be passed on to a successor in interest in the event of a reconstruction, liquidation or administration.
- We also use demographic information to tailor the website to the interests of Our visitors. We share this with third parties so that they can build up a better picture of Our customer base and general consumer trends.
- You may have accessed Our website through a hyperlink from the website of a third party such as Google. If so, you consent to your personal details, including behavioral patterns, being shared between Us and that third party in accordance with Our relationship with them.
Where required, in accordance with and as permitted by applicable law and regulations, we may transfer, process, or store your Personal Data outside your country of residence. Laws of other countries on personal information can sometimes be different from those in your country of residence. Where your Personal Data is transferred outside its country of origin, we ensure security measures and appropriate safeguards are put in place to protect your Personal Data and ensure that all transfers of your Personal Data comply with applicable data protection law.
How Long Will You Keep My Personal Data?
We will store Personal Data we collect about you as long as it is necessary to fulfill the purposes for which we collected it or where there is a legal obligation - laws or regulation that may set a minimum period for which we have to keep your personal data.
How and Where Do You Store or Transfer My Personal Data?
We are a global business. As a result the data that We collect from you may be transferred to, and stored at, any of Our locations; which may be inside or outside the European Economic Area ("EEA"). Because a number of the service providers we use are located in the United States, your Personal Information may be processed and stored inside the United States. Data may also be processed by staff around the world working for Us, or for one of Our suppliers. These staff maybe engaged in, among other things, the fulfillment of your information requests, or the provision of support services. If you submit your Personal Data, We will request that you agree to this transfer, storing, or processing. If We do not request your consent to such processing outside the EEA, We will implement suitable safeguards such as data transfer agreements using the standard contractual clauses as developed and approved by the European Commission.
Your Privacy Rights
Under the various jurisdictions' data protection laws, the resident of a country or state may have the following privacy rights:
- The right to access the Personal Data we hold about you. This right may be limited by the rights of others. In other words, if your Personal Data is mixed with another's Personal Data, we may not be able to fully respond to your request.
- The right to have your Personal Data rectified if any of your Personal Data held by us is inaccurate or incomplete. However, if your Personal Data is actually accurate or complete, we may not be able to comply with your request.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your Personal Data that we hold. There are a number of exceptions to this right depending on your residence. If we reject this request, we will provide you with the reasoning for such a rejection.
- The right to restrict (i.e. prevent) the processing of your Personal Data. There are a number of exceptions to this right depending on your residence. If we reject this request, we will provide you with the reasoning for such a rejection.
- The right to object to us using your Personal Data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your Personal Data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided Personal Data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that Personal Data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your Personal Data in this way.
- Rights against Non-discrimination. Some state law prohibits discrimination against you because you exercised any your rights under state law, including, but not limited to, by: denying you access to goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Depending on your jurisdiction of residence, these rights may be restricted in various ways. We will respect your rights as required by applicable law and this Policy.
How Can I Exercise my Privacy Rights?
If you wish to request access, to limit use, or to limit disclosure, please contact us at firstname.lastname@example.org and please provide the name (if any) of your NADEL contact and we will respond to your request within a reasonable timeframe and make all reasonable efforts to honor your request. We may require further information from you in order to fulfill your request.
There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will aim to respond to your subject access request within 10 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your Personal Data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
As noted earlier Our Site may place and access certain Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. Before Cookies are placed on your computer or device, you will be shown a Cookie banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be "strictly necessary". These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser's settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
The major browsers have attempted to implement the draft "Do Not Track" ("DNT") standard of the World Wide Web Consortium ("W3C") in their latest releases. As this standard has not been finalized, the Site is not compatible with DNT.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
How Do I Contact You?
To contact us about anything to do with your Personal Data and data protection, including to make a subject access request, please use the following details:
For non-US residents:
Email address: email@example.com
Postal Address: Jack Nadel International Ltd, Monmouth House, 87-93 Westbourne Grove, London W2 4UL.
For US residents:
Email address: firstname.lastname@example.org
Postal address: NADEL Privacy, Jack Nadel International, 5820 Uplander Way, Culver City, CA 90230.