In addition, for each visitor to our website cookies will be used which do not collect or disclose any Personal Information about the visitor, but do over time build up data regarding the visitor’s usage of our website. See further information below about cookies.
What is Personal Information?
“Personal Information” is information or an opinion about you as an identified individual or an individual who is reasonably identifiable, whether or not the information or opinion is true and whether or not it is recorded in a material form.
“Sensitive Information” is a subset of Personal Information and includes information regarding your racial/ethnic origin, political views, sexual orientation and practices, membership of professional or trade association, membership of trade union, criminal record, health information, genetic or biometric information.
We do not actively collect Sensitive Information. However, if you choose to place comment on our website that contains Sensitive Information, you should be aware that it will be publically viewable.
What Personal Information do we collect from you?
The types of Personal Information collected by us will depend on whether you are a contributor, subscriber, supplier, contractor or employee.
As a subscriber to our free newsletter, we generally only require your name (which can be a pseudonym) and email address. As a paying subscriber of our website, we collect your name (which can be a pseudonym) and email address.
As a subscriber, you may deal with us anonymously or using a pseudonym.
We also collect other data which may be included within the definition ‘personal data’ for the purposes of the GDPR. For additional information please see Data Collection Processes and Third Party Providers
How do we collect your Personal Information?
We collect Personal Information in a number of ways, including:
- from you when you subscribe to our website; when you contact us via telephone, email, provide us with your business card, or any other document containing your Personal Information;
- when you visit our website;
- any other collection of or incidental or directly or indirectly related to the products or services we may be able to provide to you, on behalf of ourselves or others; and
- from our own records;
- by visiting any website or social media site established by us, including but not limited to Facebook, Twitter, Pinterest, Instagram, Google+, Youtube and Linked In (“Social Media Sites”)
- by participating in any activity on a Social Media Site including but not limited to entering competitions, posting, pinning or uploading any material on our website or any Social Media Site, following, liking and/or commenting on us or anything on our website or any Social Media Site (“Social Media Activity”).
When visiting our website the following information may be logged for statistical purposes and for the purposes of improving our services and for the purpose of marketing and advertising to you: your internet protocol address; the date and time of your visit to our site; the pages that you have accessed and the documents downloaded; website you visited before our website; and the type of browser and operating system you were using. Any such statistical analysis does not identify you.
Tracking technologies such as cookies may be used on our website to recognise your computer’s browser each time you visit our website and to track which pages you visits whilst on our website and also to send advertisements to your internet protocol address which are relevant to the pages you have visited. These tracking technologies do not personally identify you. If you do not wish to receive any cookies, you may set your browser to refuse them. However, your use of our website may be affected.
For further information regarding our use of data collection processes and our third party service providers, please visit this page.
How do we use your Personal Information?
- as a free subscriber, to provide you with our free newsletter. As a secondary purpose, it will be used by us to contact you with information and content from our website that we believe will interest you;
- as a paying subscriber, to provide you with our free newsletter (ad-free) and to enable you to access an ad-free version of our website;
- monitoring the performance of our business and providing quality assurance for our products and services;
- responding to your enquiries and feedback regarding our business, our website and services;
- marketing including email marketing, promotional and educative activities including to advise you about products, services and opportunities that may be of interest to you;
- enforcing the terms and conditions of our engagement with you (if applicable);
- for the management of our database, software, hardware or web based systems;
- to prevent fraud, crime or other activity that may cause harm in relation to our products or services;
- ensuring compliance with statutory obligations.
We will take reasonable steps to de-identify or destroy your Personal Information when it is no longer required for any of the above purposes or for a purpose that would reasonably be expected by you.
For information about how we use any ‘personal data’ as defined by the GDPR please visit this page
If you are a subscriber, we will, from time to time, communicate with you directly via email to promote our website, our products and services or those of our third party partners, that we believe may interest you. On each communication, we will advise how you may unsubscribe or opt out of receiving such communications. You may, at any time, request not to receive direct marketing communications from us by contacting our Privacy Officer and asking to be removed from the mailing list. There is no fee to unsubscribe from the mailing list.
How is your Personal Information disclosed?
We do not and will not rent, sell or otherwise disclose your Personal Information to any other company or organisation, without your prior consent, where that consent is required by law.
We may use and disclosure of your Personal Information in the following ways and for the following purposes:
- to promote and market our products and services to you and the products and services of our third party partners, including but not limited to advising you about new products, services and technologies that we believe may be of interest to you;
- to third parties to whom we outsource any of our functions, including payroll, database management and client satisfaction surveys from time to time;
- of or incidental to a sale of all or part of our business to a third party;
- to protect and enforce our legal rights; and
- as required by law, pursuant to a court order, subpoena, warrant, in the course of legal proceeding or in response to a law enforcement agency request.
Disclosure of your Personal Information via Social Media Sites
By engaging in any Social Media Activity on our website or Social Media Sites, you agree to and are subject to the terms and conditions of our website and Social Media Sites. Any Personal Information shared by you on Social Media Sites can be disclosed in accordance with the terms and conditions and privacy policies of such Social Media Sites.
Generally, photos and other material shared on Social Media Sites will be able to be viewed by the general public. Such photos and other material may be re-shared by others indefinitely and will be visible by anyone visiting the locations to which the photos or other material have been re-shared. You may be able to remove the photos or other material that you have shared from the location at which you shared it. However, any material that has been re-shared will be out of our control and neither you nor we will be able to remove it from any re-shared location. We are not responsible for any material that has been re-shared.
We reserve the right to remove any photos, comments or other material that is in any way inappropriate or offensive (in our opinion) from our website or Social Media Sites.
Cross Border Disclosure
Any Personal Information that is viewable on our website is disclosed worldwide.
Other than via our website, we do not actively disclose your Personal Information outside of Uruguay. However, some programs, software or online tools used by us, are based in and/or located overseas.
Your Personal Information can be accessed by certain other third party service providers that are necessary to enable us to provide our services to you, and they may use your information in accordance with their privacy policies which you can access here.
If you consent to disclosure of your Personal Information in this manner, we are not required to take reasonable steps to ensure that such organisations do not breach the APPs in relation to the disclosed information. Having been informed of the possibility that such disclosure may occur, you consent to that disclosure by undertaking or continuing to undertake the type of activities indicating your consent, as specified above.
We are committed to ensuring the security of your Personal Information and we will take all reasonable steps to protect such information from misuse, interference, loss, unauthorised access, modification or disclosure, including:
- ensuring the physical security of our premises and databases/records;
- restricting access to personnel and third party service providers who need that information in order for us to be able to provide our products and services; and
- technological measures, such as computer passwords, data back-up, anti-virus software and firewalls.
Please note that our website does not provide systems for secure transmission of Personal Information across the internet, except where otherwise indicated. You should be aware that there are inherent risks in transmitting Personal Information via the internet.
Our website contains links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. We are not responsible for the privacy practises of such other websites or entities.
We cannot provide any guarantee with respect to the security of your Personal Information and we will not be liable for any breach of security or unintended loss or disclosure of information due to the website being linked to the internet.
How to check or change your details
Our Privacy Officer will endeavour to ensure that your Personal Information is accurate, complete and up to date and relevant to the purposes for which we are able to use such information.
If you wish to amend your Personal or Sensitive Information because it is inaccurate, out of date, incomplete, irrelevant or misleading, please contact our Privacy Officer. There is no fee for the correction of Personal Information.
If you are located in the European Union, you can change your details and/or your preferences by contacting our Privacy Officer
If you believe that we have not complied with our obligations pursuant to the Act or GDPR (if applicable), or have a complaint about the use or disclosure of your Personal Information by us, please contact our Privacy Officer.
What action will we take in response to your complaint?
Our Privacy Officer is responsible for liaising with you to ensure that the issues you have raised are fully examined and that your complaint is handled in accordance with the process set out below. We will treat all the details of your complaint, in strict confidence. If we need to discuss any issues arising from your complaint with a third party, we will obtain your consent first.
We will endeavour to resolve your complaint as soon as possible, but the length of time will depend on the nature and complexity of the issues you have raised. You will receive acknowledgement of receipt of the complaint from us within 5 business days. We will give you an estimate of how long it may take us to deal with the matter but we will endeavour to finalise the matter within 30 days.
After investigating and assessing your complaint, we will decide what action (if any) we should take in response.
Some of the things that we decide to do include:
- take steps to rectify the problem or issue you have raised;
- provide you with additional information or advice so you can understand what happened and how we have dealt with it; and/or
- take steps to change our policies or procedures if your complaint identifies a problem in the way we are doing things.
Privacy Officer Details