In the ordinary course of business, Affinity, and all of its affiliates (“Affinity”) collect, use, and share personal information pertaining to its partners, employees, clients, and others. Obtaining this information is important to our ability to conduct our operations and to deliver the highest level of service, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information that a relevant Affinity entity may collect about you in compliance with applicable legal and regulatory requirements, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.

HOW WE COLLECT INFORMATION ABOUT YOU

• When you visit our website (the “Site”), our web servers collect the details of your operating system, browser version, domain name and IP address and the details of the web site you linked from to the Site. Our web servers may seek to place a “cookie” (a small data file) on your computer’s hard drive, which allows the server to recognize your computer when you visit again. If you prefer not to accept cookies, you can set your browser to reject them or to alert you before one is placed. More information on how we use cookies can be found below.
• There are parts of this Site where we may need to collect personal information from you for a specific purpose, such as to provide you with certain information you request. If you voluntarily submit information to our Site (for example, in a request for general information or through the submission of a business proposal), we may store and use any personally identifiable information, such as your name, phone number, fax number and e-mail address, for reasonable business purposes including, but not limited to, fulfilling your request and marketing and business communications and you expressly agree with the collection, use, storage and handling of your personal information as set out in this policy. If you do not provide all such information we need, we may not be able to give you the information you request.

When you contact us by email or phone about or in relation to our services or to respond to our communications we may record and use the personal information you provide, such as your name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.

Please also note we have certain responsibilities under the US Department of the Treasury Financial Crimes Enforcement Network (FinCEN) Customer Due Diligence (CDD) Rule, UK Money Laundering Regulations 2007 and other rules and regulations, to verify the identity of clients and may need to make certain inquiries and obtain certain information from you for that purpose. You confirm that all information you supply will be accurate and that we may disclose such information as we consider necessary to comply with any reporting or legal and regulatory requirements.

COOKIES

What are cookies?

Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties who receive data obtained from that website.

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.

Why do we use cookies?

Cookies help us to provide customized services and information. We use cookies on all our Site to tell us, in general terms, how and when pages in our Site are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our Site is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, whilst others have a longer life span to ensure that they fulfil their longer-term purposes (as explained in more detail below). Please note that, however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.

In broad terms, we use cookies on our Site for the following purposes:

• Analytical purposes: Analytical cookies allow us to recognize measure and track visitors to our Site and compile a record of this usage information. This helps us to improve and develop the way our Site works, for example, by determining whether visitors to the Site can find information easily, or by identifying the aspects of Site that are of the most interest to them.
• Session management: The software that runs our Site uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine what features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the Site to function.

Please note that third parties may use cookies. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policy.

Your cookie preferences

Cookies are necessary in order for you to be able to make full use of our Site. If you chose to disable cookies, some of our Site’s functionality might be impaired.

Third party cookies

When you visit our Site, you may receive cookies that are set by third parties. These may include cookies set by Google Analytics, WordPress or Vimeo.com. These cookies are used for the purposes described in the “Why Do We Use Cookies?” section of this policy. We do not control the setting of these third party cookies, so we suggest you might wish to check the third party websites for more information about their use of cookies and how to manage them.

For more information about how Google Analytics collects and processes your data, please visit www.google.com/policies/privacy/partners.

Amending cookie preferences

If you wish to remove cookies set by our Site from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our Site will impair the functionality of the Site.

The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browsers, or you may consult the vendor documentation for your specific software.

Do Not Track

“Do not track” signals are preferences that users can set on their web browsers to limit how their activity is tracked across online services. The Site does not respond to “do not track” signals in your web browser.

USES OF COLLECTED INFORMATION

The purposes for which we use your personal information are:

• To monitor, improve and administer the Site and the information and services provided on the Site;
• To provide you with information on selected services that we think may be of interest to you (unless you have asked us not to do so);
• For the management and administration of our business;
• In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
• To set you up as a client;
• To provide you with our services;
• To understand feedback on our services and to help provide more information on the use of those products and services quickly and easily;
• To communicate with you in order to provide you with services or information about Affinity and our products and services; or
• To understand your needs and interests.

However we use personal information we make sure that the usage complies with applicable law and the law allows us and requires us to use personal information for a variety of reasons. These include where:

• We need to do so in order to perform our contractual obligations with our clients;
• We have obtained your consent;
• We have legal and regulatory obligations that we have to discharge;
• We may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
• The use of your personal information as described is necessary for our legitimate business interests, such as (i) allowing us to effectively and efficiently manage and administer the operation of our business; (ii) maintaining compliance with internal policies and procedures; and/or (iii) promoting our business and services.

DISCLOSURES OF YOUR PERSONAL INFORMATION WITHIN AFFINITY

In order to provide efficient and reliable services and to improve service options available to you, we may share your personal information with our subsidiaries or affiliates. For this purpose, we may transfer the information you provide outside your country to a Affinity entity in another country that does not have similar data protection legislation and may provide a lower level of protection for your information. By submitting any information you consent to these transfers. We have taken certain measures outlined below to try to ensure the security of your information.

DISCLOSURES OF YOUR PERSONAL INFORMATION TO THIRD PARTIES

We may share, and have shared over the past twelve (12) months, your personal information with other companies we have hired to provide services for us, or have hired us to provide services to them. These companies – our vendors – are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only on our behalf for the purposes that Affinity has hired them and for which it has instructed them.

We may also release information about you if you direct us to do so, or if we are required or authorized by law to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding, or to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.

Where you have provided personal information to us, you expressly consent to the sharing of such personal information with third parties for the purposes set out in this section.

RETENTION PERIOD AND SECURITY OF COLLECTED INFORMATION

How long we will retain your personal information for will vary and will be determined by the following criteria:

• The purpose for which we are using it – Affinity will need to keep the data for as long as is necessary for that purpose; and
• Legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.

Although Affinity endeavors to take steps to provide a secure environment for users accessing the Site, due to the nature of the Internet, Affinity cannot guarantee confidentiality or security of the personal and other information being provided. Affinity makes no warranty whatsoever to you, express or implied, regarding the security of the Site, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through the Internet.

Affinity welcomes your e-mail correspondence. However, it is possible that information transmitted to Affinity may be read or obtained by other parties. Messages sent over the Internet cannot be guaranteed to be completely secure or error free as they are subject to possible interception, corruption, delays, loss or possible alteration. Affinity is not responsible for them and will not be liable to you or anyone else for any damages or otherwise in connection with any messages sent by you to Affinity or any message sent by Affinity to you over the Internet. If you send e-mail (encrypted or not) to Affinity over the Internet, you are accepting the associated risks, including lack of confidentiality.

Further, despite all possible security measures that Affinity would take to keep this Site free from hacking and other interference, this Site like any other website is not free from such risks. Affinity disclaims all liability on account of any loss or damage that any user may suffer or incur on account of any alteration or manipulation of any data or information accessed or downloaded from this Site.

Whilst Affinity endeavors to take every reasonable precaution to ensure accuracy, security and confidentiality of information available through / on the Site, Affinity cannot be held responsible for any consequence of any action(s) carried out by any authorized or unauthorized user.

CHANGES TO THIS POLICY

We may update this policy from time to time as the Site changes and privacy law evolves. If we update it, we will do so online and follow such other steps as required by applicable law.