Privacy Policy

<p style="margin-left:0cm; margin-right:0cm">This Privacy Policy (Effective Date: from 25 May 2018) explains how Tonypicks collect, use, and disclose your personal data; together with your rights in relation to the personal data it holds.&nbsp;<br /> &nbsp;</p> <ol> <li><strong>YOUR PERSONAL DATA</strong></li> </ol> <p style="margin-left:0cm; margin-right:0cm">Tonypicks (in this Privacy Policy, &laquo; us &raquo;, &laquo; we &raquo; and &laquo; our &raquo;) is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the GDPR) and the Data Protection (Bailiwick of Guernsey) Law, 2017 (together with the GDPR, the Data Protection Legislation).</p> <ol start="2"> <li><strong>CONTACT US ABOUT YOUR DATA</strong></li> </ol> <p style="margin-left:0cm; margin-right:0cm">If you have any questions about this Privacy Policy or our privacy related practices, you can contact us:&nbsp;<br /> <br /> email: tonybasketpicks@gmail.com</p> <p style="margin-left:0cm; margin-right:0cm">This Privacy Policy supersedes any previous Privacy Policy or equivalent that you may have been provided with or seen prior to the Effective Date stated above.</p> <ol start="3"> <li><strong>YOUR RIGHTS</strong></li> </ol> <p style="margin-left:0cm; margin-right:0cm">Under the Data Protection Legislation you have the following rights:&nbsp;</p> <ul> <li style="list-style-type:none"> <ul style="list-style-type:circle"> <li>Right of subject access: The right to make a written request for details of information about you held by Tonypicks and a copy of that information</li> <li>Right to ectification: the right to have inaccurate information about you rectified.</li> <li>Right to erasure ( &laquo; right to be forgotten &raquo; ): the right to have certain information about you erased.</li> <li>Right to restriction of processing: the right to request that your information is only used for restricted purposes.</li> <li>Right to object: the right to object to the use of your information, including the right to object to marketing.</li> <li>Right to data portability: the right, in certain circumstances, to ask for information you have made available to us to be transferred to you or a third party in machine-readable formats.</li> <li>Right to withdraw consent: the right to withdraw any consent you have previously given us to handle your information. If you withdraw your consent, this will not affect the lawfulness of Tonypicks&#39;s use of your information prior to the withdrawal of your consent.</li> </ul> </li> </ul> <p style="margin-left:0cm; margin-right:0cm">You can find out more about your rights at https://dataci.gg/</p> <ol start="4"> <li><strong>HOW WE COLLECT YOUR DATA</strong></li> </ol> <p style="margin-left:0cm; margin-right:0cm">In the course of providing services to you, we collect information that personally identifies you. The information we collect about you comes from:&nbsp;<br /> <br /> &nbsp;</p> <ul> <li style="list-style-type:none"> <ul style="list-style-type:circle"> <li>application forms or other materials you submit to us during the course of your relationship with us;</li> <li>your interactions with us, transactions and use of our products and services (including the use of our website);</li> <li>your dealings with us, including via email, telephone or as stated in our contracts with you;</li> <li>depending on the products or services you require, third parties (including for credit and money laundering checks, among other things); and</li> <li>recording and monitoring tools that we use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).</li> </ul> </li> </ul> <p style="margin-left:0cm; margin-right:0cm">&nbsp;</p> <ol start="5"> <li><strong>THE INFORMATION WE COLLECT</strong></li> </ol> <p style="margin-left:0cm; margin-right:0cm">If you are our customer, we collect information that helps us to identify you and to manage your accounts. We also collect financial information about you, information about your transactions with us and information required for us to carry out credit, money laundering and other checks and to comply with our legal obligations. Where you are our customer, information that we collect includes:&nbsp;<br /> &nbsp;</p> <ul> <li style="list-style-type:none"> <ul style="list-style-type:circle"> <li>your name and contact details (email and telephone number);</li> <li>your age;</li> <li>personal identifiers such as your IP address or our internal electronic identifiers;</li> <li>payment card details, bank account details or online e-wallet details.</li> </ul> </li> </ul> <p style="margin-left:0cm; margin-right:0cm"><br /> You are not obliged to provide us with your information where it is requested but we may be unable to provide certain products and services or proceed with our business relationship with you if you do not do so. Where this is the case, we will make you aware.</p> <ol start="6"> <li><strong>OUR USE OF YOUR INFORMATION</strong></li> </ol> <p style="margin-left:0cm; margin-right:0cm">Where you are our customer, we collect, use, share and store information about you to process transactions and to improve the quality of the service that we provide to you. When processing your information, we do so in our legitimate interests (as set out in the bullet points below), because of legal obligations that we are subject to or because the information is required in order to provide our products or services to you. Where we process special &laquo; special categories &raquo; of information about you, we do so either because you have given us your explicit consent, we are required by law to do so or the processing is necessary for the establishment, exercise or defence of a legal claim. We use your information for the purposes of the following legitimate interests:&nbsp;<br /> <br /> &nbsp;</p> <ul> <li style="list-style-type:none"> <ul style="list-style-type:circle"> <li>to process your registration and determine your eligibility for Membership;</li> <li>to conduct appropriate fraud checks;</li> <li>to allow you access and use the Tonypicks website;</li> <li>to administer your account;</li> <li>to maintain our own accounts and records;</li> <li>to better understand our Membership profile and tailor our services accordingly;</li> <li>to notify you of additional services that may become available on Tonypicks or on websites that we or any of our associated companies might establish;</li> <li>to notify you of promotional offers and provide you with promotional materials; and</li> <li>to process payments to and from you.</li> </ul> </li> </ul> <p style="margin-left:0cm; margin-right:0cm"><br /> If you wish to receive future marketing, promotional or sales material from Tonypicks, you can opt-in for this type of communication.&nbsp;<br /> <br /> Tonypicks may also pass on your Personal Information to trusted third parties in order to assist us with the purposes listed above. Such disclosures to trusted third parties enables us to provide you with the best user experience on our site and shall not be used for the purposes of marketing other goods or services to you. When sharing your personal data with third parties as set out in this Privacy Policy, it may be transferred outside Guernsey or the European Union.&nbsp;<br /> <br /> We reserve the right to pass on any information to any public, regulatory, sporting or other relevant authority as may be required in order to carry out any investigation and prosecution into such matters.</p> <ol start="7"> <li><strong>RETENTION OF INFORMATION</strong></li> </ol> <p style="margin-left:0cm; margin-right:0cm">We will hold your personal information on our systems for the longest of the following periods:&nbsp;<br /> &nbsp;</p> <ul> <li style="list-style-type:none"> <ul style="list-style-type:circle"> <li>a minimum of six years;</li> <li>as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with us;</li> <li>the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;</li> <li>any retention period that is required by law; and/or</li> <li>the end of the period in which litigation or investigations might arise in respect of the services that we provide to you.</li> </ul> </li> </ul> <p style="margin-left:0cm; margin-right:0cm"><br /> These rights are not absolute: they do not always apply and exemptions may be engaged. We may, in response to a request, ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why. To exercise any of these rights, or if you have any other questions about our use of your information, please contact us at the details set out in the &laquo; Contact Us &raquo; page.&nbsp;<br /> <br /> If you are unhappy with the way we have handled your information you have a right to complain to the data protection regulator in the EU Member State where you live or work, or where you think a breach of your personal information has taken place.</p> <ol start="8"> <li><strong>SECURITY</strong></li> </ol> <p style="margin-left:0cm; margin-right:0cm">Your Personal Information will be held on secure servers and all transactions are encrypted using secure socket layer (SSL) advanced encryption technology up to 128-bit encryption. Please note that email communications with Tonypicks are NOT encrypted or otherwise secured against outside interference; please use discretion when providing personal details via email. Once we receive your data, it will be held by us on secure servers and we will use all reasonable commercial efforts to ensure its security.</p> <ol start="9"> <li><strong>COOKIES</strong></li> </ol> <p style="margin-left:0cm; margin-right:0cm"><strong>What are cookies?</strong>&nbsp;<br /> <br /> Cookies are pieces of information in the form of very small text files that a website stores in a user&#39;s browser and can retrieve whilst a user is browsing the website in order to identify the user and understand the user&#39;s activity. Tonypicks uses cookies on our website to improve its performance and your user experience.&nbsp;<br /> <br /> <strong>What type of cookies does Tonypicks use?</strong>&nbsp;<br /> <br /> When you use the Tonypicks website the following types of cookies can be set on your device:&nbsp;<br /> <br /> &nbsp;</p> <ul> <li style="list-style-type:none"> <ul style="list-style-type:circle"> <li>1. Session Cookies: these are stored on a user&#39;s device and remain there until the termination of the session of a given browser. Stored information is then permanently removed from the device memory. Session Cookies Mechanism do not allow Tonypicks to access any personal data or private information from a user&#39;s device.</li> <li>2. Persistent Cookies: these are stored on a user&#39;s device and remain there until deleted. Termination of the session of a given browser does not cause their removal from the user&#39;s device. Persistent Cookies Mechanism do allow Tonypicks to access personal data or private information from a user&#39;s device.</li> </ul> </li> </ul> <p style="margin-left:0cm; margin-right:0cm"><br /> <strong>What does Tonypicks use cookies for?</strong>&nbsp;<br /> <br /> <em>Session management</em>: Cookies are used for authenticating a user in the website, securing the user&#39;s session in the website and facilitating the correct configuration of the user&#39;s preferred website functions.&nbsp;<br /> <br /> <em>Session management</em>: Cookies are used for authenticating a user in the website, securing the user&#39;s session in the website and facilitating the correct configuration of the user&#39;s preferred website functions. Example: Identifying you as being signed in to Tonypicks.com and keeping you logged in throughout your visit.&nbsp;<br /> <br /> <em>Personalisation</em>: These cookies allow the website to remember choices a user makes and provide enhanced experience and more personalised features. They allow the user to personalise the content of the website according to user preferences, recognition of the user&#39;s device and its location and displaying the web pages accordingly, remembering user&#39;s settings and personalising user&#39;s interface. Example: Remembering your preference for type of language or currency.&nbsp;<br /> <br /> <em>Tracking</em>: Tonypicks uses Google Analytics that set their own cookies. These cookies are used to collect statistical information about visitors of the website and the pages they view. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and used anonymously. Example: Understanding what content is popular to helps us to improve our website.&nbsp;<br /> <br /> <em>Third party cookies</em>: Some cookies that have been set on our websites are not related to Tonypicks.com. When you visit a page with content embedded from other services, these service providers may set their own cookies on your web browser. We do not control the use of these cookies and cannot access them, as cookies can only be accessed by the party who originally set them. Please inspect the cookie policy of the third party for further details. More information about cookies and details of how to manage or disable them can be found on www.aboutcookies.org.&nbsp;<br /> <br /> <em>PLEASE NOTE</em>: We strongly recommend that you permit the use of cookies; if you choose to disable cookies by modifying the settings in your browser then you may find that certain sections of the Website do not work as they should, and we do not accept any liability to you for any losses you incur as a result of this.</p>

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