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Privacy Policy of KCG Website

Thank you for visiting our website (the "Site"). Your privacy is important to us. We take the privacy of our users seriously and are committed to protecting it. This privacy policy (the "Policy") explains how we (website) collect, use, and protect personal information that we obtain from our Users.

Data Owner: KCG LTD ADGM

 

Email address of the Data Owner: privacy@kcgadgm.com

Types of Data collected

Among the Personal Data collected by [website], either independently or through third parties, are: usage data; cookies; email; first name; last name; data communicated during the use of the service; unique identifiers of advertising devices (Google Advertiser ID or IDFA identifier, for example); information about the device; answers to questions; clicks; keypress events; events related to motion sensors; mouse movements; scrolling position; touch events; number of Users; session statistics.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informative texts displayed before the data is collected.

Personal Data may be freely provided by the User or, in case of Usage Data, collected automatically during the use of [website].

If not otherwise specified, all Data requested by [website] are mandatory. If the User refuses to communicate with them, it may be impossible for [website] to provide the Service. In cases where [website] indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequences on the availability of the Service or its operation.

Users who have doubts about which Data are mandatory are encouraged to contact the Data Owner.

The possible use of Cookies - or other tracking tools - by [website] or third-party service providers used by [website], unless otherwise specified, is intended to provide the Service requested by the User, as well as for the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through [website] and guarantees to have the right to communicate or disclose them, releasing the Data Owner from any liability towards third parties.

 

 

Mode and place of processing of collected data 

Processing methods 

The Data Owner adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. Processing is carried out using computers and/or IT tools, with organizational methods and logics strictly related to the purposes indicated. In addition to the Data Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of [website] (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) also appointed, if necessary, as Data Processors by the Data Owner. An updated list of these parties may be requested from the Data Owner at any time. 

 

Legal basis of processing 

The Data Owner processes Personal Data relating to the User if one of the following conditions exists:
 

  • the User has given consent for one or more specific purposes;
     

  • the processing is necessary for the performance of a contract with the User and/or for any pre-contractual obligations;
     

  • the processing is necessary to comply with a legal obligation to which the Data Owner is subject;
     

  • the processing is necessary for performing a task of public interest or for the exercise of public authority vested in the Owner;
     

  • the processing is necessary for pursuing the legitimate interest of the Owner or third parties.
     

However, it is always possible to ask the Data Owner to clarify the specific legal basis of each processing and in particular to detail whether the processing is based on law, required by a contract or necessary to conclude a contract.

 

 

Location

Data are processed at the Holder's operational offices and at any other location where the parties involved in the processing are located. For more information, please contact the Data Owner.

The User's Personal Data may be transferred to a country other than the country where the User is located. To obtain more information about the location of the processing, the User may refer to the section on Personal Data processing details.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Owner to protect the Data.

The User may verify whether any of the transfers just described takes place by reviewing the section of this document on details of the processing of Personal Data or request information from the Data Owner by contacting it at the contact details given at the beginning.

 

Retention Period.

Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:
 

  • Personal Data collected for purposes related to the performance of a contract between the Data Owner and the User will be retained until the performance of that contract is completed.
     

  • Personal Data collected for purposes related to the legitimate interest of the Data Owner will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.
     

When processing is based on the User's consent, the Data Owner may keep the Personal Data longer until such consent is revoked. In addition, the Owner may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the expiration of this period the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

 

Purposes of the Data collected

User Data is collected to enable the Data Owner to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, as well as for the following purposes: Displaying content from external platforms, Statistics, Contact management and message sending, Contacting the User, Payment management, Remarketing and behavioral targeting, Interaction with support and feedback platforms, Hosting and backend infrastructure, Advertising, Content commentary, Managing support and contact requests, Interaction with social networks and external platforms, Web conferencing and online telephony, Online data collection and survey management, Tag management, User database management, SPAM protection and Traffic optimization and distribution.

To obtain detailed information about the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section "Personal Data Processing Details."

 

Details of the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:
 

  • Commenting on content

  • Contacting the User

  • Managing contacts and sending messages

  • Managing databases of Users

  • Managing payments

  • Tag management

  • Management of data collection and online surveys

  • Management of support and contact requests

  • Management of web conferencing and online telephony

  • Hosting and backend infrastructure

  • Interaction with support and feedback platforms

  • Interaction with social networks and external platforms

  • Traffic optimization and distribution

  • SPAM protection

  • Advertising.

  • Remarketing and behavioral targeting

  • Statistics

  • Displaying content from external platforms

Information on how to turn off interest-based advertisements

In addition to any opt-out features provided by any of the services listed in this document, Users can read more about how to turn off interest-based advertisements in the appropriate section of the Cookie Policy.

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Owner.

In particular, Users have the right to:
 

  • Revoke consent at any time. The User may revoke the consent to the processing of its Personal Data previously expressed. 
     

  • Object to the processing of their Data. The User may object to the processing of its Data when it is done on a legal basis other than consent. Further details on the right to object are provided in the section below.
     

  • Access to one's own Data. The User has the right to obtain information about the Data processed by the Data Owner, certain aspects of the processing and to receive a copy of the Data processed.
     

  • Verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected. 
     

  • Obtain restriction of processing. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Owner will not process the Data for any purpose other than its preservation.
     

  • Obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Owner.
     

  • Receive their Data or have it transferred to another Data Owner. The User has the right to receive its Data in a structured, commonly used, machine-readable format and, where technically feasible, to have it transferred unimpeded to another data Owner. This provision is applicable when the Data are processed by automated means and the processing is based on the User's consent, a contract to which the User is a party or contractual measures related thereto.
     

  • Propose Complaint. The User may propose a complaint to the competent data protection supervisory authority or take legal action.

Details about the right to object

When Personal Data are processed in the public interest, in the exercise of public authority vested in the Data Owner or in pursuit of a legitimate interest of the Data Owner, Users have the right to object to the processing for reasons related to their particular situation.

Users should note that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Owner processes Data with direct marketing purposes, Users may refer to the respective sections of this document.

How to Exercise Rights

To exercise the User's rights, Users may address a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Owner as soon as possible, but in any case, within one month.

 

Further information on treatment
 

Defense in Court

The User's Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of [website] or related Services by the User.

The User declares that he/she is aware that the Data Owner may be obliged to disclose the Data by order of public authorities.
 

Specific disclosures

Upon the User's request, in addition to the information contained in this privacy policy, [website] may provide the User with additional and contextual disclosures regarding specific Services, or the collection and processing of Personal Data.
 

System Logs and Maintenance

For operation and maintenance purposes, [website] and any third-party services it uses may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User's IP address.
 

Further information 

Further information in relation to the processing of Personal Data may be requested at any time from the Data Owner using the contact details.
 

Response to "Do Not Track" Requests

[website] does not support "Do Not Track" requests.

To find out whether any third-party services used support them, the User is encouraged to consult their respective privacy policies.
 

Changes to this privacy policy

The Data Owner retains the right to change this privacy policy at any time by notifying Users on this page and, if possible, on [website] as well as, if technically and legally feasible, by notifying Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification shown at the bottom.

If the changes affect any processing whose legal basis is consent, the Data Owner will collect the User's consent again, if necessary.

 

Legal references

We take the privacy of our users very seriously and adhere to all applicable regulations regarding the collection, use, and protection of personal data, including of Articles 13 and 14 of the Regulation (EU) 2016/679 (General Data Protection Regulation or GDPR) and the California Consumer Privacy Act (CCPA) in the United States.

 

In compliance with the EU General Data Protection Regulation (GDPR), we will only collect and process your personal data for specific and legitimate purposes, and we will take appropriate measures to ensure the security and confidentiality of your data. We will also obtain your explicit consent before collecting any sensitive data, such as health information or biometric data.

 

In compliance with the US Children's Online Privacy Protection Act (COPPA), we do not knowingly collect personal data from children under the age of 13 without the verifiable consent of their parents or legal guardians. If we discover that we have collected personal data from a child without parental consent, we will promptly delete that data.

 

Unless otherwise stated, this privacy policy covers [website] only.

 

International Data Transfers

If you are located outside of the United States, please be aware that your personal information may be transferred to, stored, and processed in the United States. By using our Site, you consent to the transfer of your personal information to the United States.

 

Contact Us

If you have any questions or concerns about this Policy or our privacy practices, please contact us at privacy@kcgadgm.com.

 

Definitions 

Personal Data (or Data)

Personal Data is any information that, directly or indirectly, including in conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.


Usage Data

This is the information collected automatically through [website] ( also by third party applications integrated in [website]), including: the IP addresses or domain names of the computers used by the User who connects with [website], the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.. ) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the User's operating system and computer environment.


User

The individuals using [website] which, except where otherwise specified, coincides with the Data Subject.


Data Subject

The natural person to whom the Personal Data refers.


Data Processor (or Processor).

The natural person, legal entity, public administration and any other entity that processes Personal Data on behalf of the Data Owner, as set out in this privacy policy.


Data Owner (or Owner).

The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of [website]. The Data Owner, unless otherwise specified, is the owner of [website].


[website] (or this Application)

The hardware or software tool by which Users' Personal Data are collected and processed.

Service

The Service provided by [website] as defined in the relevant terms (if any) on this site/application.
 

European Union (or the EU).

Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current Member States of the European Union.


Cookies

Cookies are Tracking Tools that consist of small portions of data stored within the User's browser.


Tracking Tool

Tracking Tool means any technology - e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that enables tracking of Users, for example, by collecting or storing information on the User's device.

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