Effective Date: 1st september 2018
In connection with the User’s access and use of the GTH Services and its service providers may collect both personal information and non-personal information (“Information”). In general, you can visit our Site without revealing any information about yourself. In some cases, including when you are wishing to get services through the Site, GTH may ask you to register and provide personal information. GTH undertakes to make sure that clear notice and choice is provided to all visitors of the Site before the personal Information is collected, and that they have opted-in to GTH use of their data.
Personal information is information that either identifies an individual or relates to a specific individual.
GTH collects, processes, or uses the following personal data, if the User actively provides this information to GTH:
· first name, last name, date of birth, email address, postal address, country, job title, telephone number, fax number, company name and additional information that the User provides when contacting GTH using the Site, especially information provided in free text fields of contact forms ("contact data"),
· other data that you have provided in comments on the Site, especially using the forms of the discussion boards or the comment functions of the blogs,
· data that you have sent to us during an online job application, including your CV, certificates, reports, job references etc.;
· email address, phone number, name, company name and country provided when subscribing to a newsletter or other marketing information of GTH.
Besides that GTH also processes the following personal data, which is passively collected:
· personal data sent by your web browser, i.e. information about your type of web browser, your operating system and selected settings (e.g. language, region, font size, font types and other configuration) may be collected ("browser data");
· your IP address, information about the amount of data transferred, stored in access log files ("usage data").
Non-personal information is information that does not reveal a person’s specific identity or relates to a specific individual and may include electronic interaction information, geographic or geo-location information, statistical and aggregated information. While statistical and aggregated information may be derived from personal information GTH will anonymize any personal information prior to sharing this information with third parties.
Types of Cookies
The Site uses "cookies" to help you personalize your online experience. A cookie is an identifier, which is stored on your device by your browser, if your browser is configured to do so. Most browsers can be configured to reject cookies or to inform you, when a cookie is stored. By using cookies, GTH collects, processes, and uses your personal data in pseudonymous form for promotional and market research purposes and to adjust the Site to your interests (unless you have opted out of this), for displaying or sending you -if applicable with your consent information about us and to keep you updated about our products and services that might be of interest to you. Based on this technology we might get reports from our service providers that include references to personal or aggregated data. Aggregated data might include data like general demographic or usage characteristics describing the visitors of our Site.
You may find the following cookies that are used on the Site: (i) the required cookies which enable the navigation and basic functionality of the Site, e.g. access to protected areas of the Site;
(ii) the functional cookies allow to analyze your website usage and your selections on the website (e.g. your login name, language, or region), so we can remember these settings and to offer you a more personal experience on our Site; these cookies can also be used to remember settings like font size, font style and other configurations that you have chosen on the Site; (iii) advertising cookies with their related services help us to analyze and monitor the effectiveness of our marketing activities. In some cases we make use of third-party service providers to track and analyze statistical information about the usage and scope of content that is used by individual users of our Site. This might result in cookies being set by the service providers to track the performance of our advertisement. These cookies might, for example store information about the browsers that have been used to visit our Site. The information provided to third-party providers by us does not include personal information, but the collected information might be linked with other personal information gathered elsewhere.
Besides that we have contracts with advertising networks. These advertising networks track your online activities and navigation over time and across multiple websites or other online services by setting cookies. This might result in information being tracked about you across multiple browsing devices, like your PC or laptop, smartphone, or tablet. Third-parties use such information to target advertising for products and services based on your personal interests. This might result in advertisement being displayed on any of your browsing devices.
The User can stop the placement of cookies on its device by using the opt-out options. In addition, the User can use the browser settings to control and restrict the placement of cookies. In this respect the User can also delete existing cookies. However, this can lead to a restriction of the functionalities of our Site.
GTH makes use of log files for statistical purposes and internal system specific purposes. GTH also collects, processes, and uses your usage data in combination with your IP address and information about the amount of transmitted data stored in log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider ( ISP ), date/time stamp, referring/exit pages, and number of clicks to analyze trends, administer the site, track user 's movement around the Site, and gather demographic information. IP addresses and other such information are not linked to any information that is personally identifiable. The log files are used to statistically analyze visits on the Site. The data is being deleted after it has been analyzed for statistical purposes.
GTH collects, processes, and uses the Information for purposes which you have consented to or for the purposes of providing the Services that you want to get while using the Site, including but not limited to:
-downloads, discussion boards, individual requests (e.g. using our contact form), blogs;
-registration to our courses and other offerings;
-the creation of statistics and the improvement of the Site and the offered services in order to ensure the security of the Site;
-if you have consented to it, for marketing purposes especially sending our email newsletters or advertisements; if you receive a marketing e-mail from GTH, you will generally be provided with an automated way to unsubscribe from that marketing e-mail sent by GTH;
-for purposes of contract management and processing your enquiries and requests;
-for purposes of administering the program and system, such as maintaining account information, sending payments, etc.;
-for purposes of improving or marketing the Services.
The lawfulness for the data processing is the performance of a contract or steps prior to entering into a contract. Using the personal data is required to provide the contractual obligations. Without this personal data you would not be able to receive the services offered by GTH.
The non-personal Information that GTH collects is used for marketing and sales efforts to better target advertisements and other content to individuals in an effort to create a personally relevant experience for each person. The data is also used to predict responses to advertisements, and to help determine which ads perform best and which content is most appropriate for different individuals.
Providing the direct marketing data and browser data is optional. If you do now provide this data, you will not receive any direct marketing information from us and your data will not be used to improve your user experience and will not be used for statistical purposes.
All personally-identifiable data is maintained in strict confidence by GTH and will be treated with the same level of respect and care that GTH treats its other proprietary information and trade secrets.
GTH contracts with third parties to administer, host, distribute, resell, and/or support the Services. These third-party services providers have access to personal information only for the limited and specific purpose of performing services on GTH’s behalf and are expressly obligated not to disclose or use personal information for any other purpose.
GTH has contracted external data processing service providers to collect, process, or use personal data on behalf and according to the instructions of GTH. Such service providers support GTH, especially relating to hosting and operating the websites and blogs, marketing purposes, statistical analysis, improving the websites and sending our email newsletters. These service providers may be located outside the European Union or the European Economic Area which means that the level of protection in respect to data protection law might differ from the level of protection provided by European data protection law.
Unless there is an adequacy decision by the EU Commission for these states or the transfer is based on an exemption provided for by the GDPR (e.g. express consent, assertion, exercise or defense of legal rights), we take all necessary measures to ensure that transfers to such organizations are adequately protected, e.g. by signing the standard contractual clauses stipulated by the EU Commission with the data recipients.
A transfer of data to official authorities in countries outside the European Union or the European Economic Area (so-called third countries) takes place, if required by law, you have given us your express consent or this is legitimated by the legitimate interest of us or the third party for data protection purposes, e.g. internal administrative purposes and no higher legitimate interests on your part.
The Information may be shared, from time to time, with the following third-parties, including but not limited to:
· investors or partners who enter into business relationships with GTH; · vendors in providing administrative services such as billing, delivery and payouts, or for other services related to providing a GTH product or service;
· third party who provides substantially similar services as the original service signed up for, if GTH decide to stop providing such services.
GTH reserves the right to disclose any Information as GTH in its sole discretion, believes necessary: (i) to satisfy or comply with any applicable law, regulation or legal process or to respond to lawful requests, including subpoenas, warrants or court orders; (ii) to protect the GTH’s property, rights and safety and the rights, property and safety of third parties or the public in general; and (iii) to prevent or stop activity GTH considers to be illegal or unethical.
Any third-party so used will be required to enter into a confidentiality and non-disclosure agreement with GTH upon terms and conditions consistent with the policies set forth herein.
This Site may be hosted on the web servers outside the EU. If you are located in the EU jurisdiction you agree that the provision of the Information or other access to the Site constitutes your consent to the transfer of such data/information, including Personal Information, to the jurisdiction where the Site is hosted that may not provide an equivalent level of data protection to the laws in your home country however we have procedures in place to ensure the protection of your information, including your Personal Information.
GTH implements the technical and organizational measures that are commercially reasonable in relation to the respective purpose of data protection, in order to protect the information provided by you against abuse and loss. Such data is stored in a secure operating environment that is not accessible to the public. In addition, each of our employees is instructed on data protection and obliged to enter into a confidentiality agreement. Any data that is stored on GTH's or the third party servers is treated as proprietary and confidential and is not available to the public. Please keep in mind, however, that the Internet is not a 100% secure medium. Therefore, although we use industry standards to protect information, the possibility of somebody defeating our security measures does exist.
Upon your request, GTH will provide you with information as to whether – and if so, which – personal data we store in relation to you. Should your personal data be incorrect, you may have this rectified immediately. Any such information or modification is free of charge.
Moreover, you are entitled to revoke your consent to use your personal data in the future, in whole or in parts. Should you desire to do so, we will delete or block your relevant data. In order to assert such rights, please contact -Elena Privalova.
Please feel free to direct any questions, comments, or complaints regarding this privacy statement or the privacy practices of GTH to:
P.M. Investment Agency LLC OGRN: 1157746261111 INN (Tax ID)/KPP (Industrial Enterprise Classification Code): 7701095620/770301001 RCBIC: 044525593 Current account: 40702810701990002085 Correspondent account: 30101810200000000593 JSC ‘ALFA-BANK’
Address: 123112, Moscow, Presnenskaya embankment, 8, building 1, 48 flow, 484C К5 office
137.1 Email: firstname.lastname@example.org
All matters relating to your access to and use of the Site shall be governed by and construed in accordance with the laws of the country in which GTH has its registered office.