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Legal Notice

Legal Notice on Privacy & Cookies Policy
Date: 23 September 2016

StornowayBids (“we”, “us”, “Bonas”), is a trading name of Bonas-Couzyn Pacific Ltd. whose registered office is 36/F Tower 2, Times Square, 1 Matheson Street, Causeway Bay, Hong Kong.

This Privacy & Cookies Policy describes our collection, use, disclosure, retention and protection of your personal information. It applies to any Bonas site where this Privacy & Cookies Policy appears in the footer, and to any Bonas application, service, or tool (collectively "Services") where this Privacy & Cookies Policy is referenced, regardless of how you access or use them, including through mobile devices.

We have strict security measures designed to protect your personal data and are committed to respecting the privacy rights of our customers ("you", "your", "yours"). The following information is intended to enable our customers to be fully informed of our Privacy Policies. By using our Services and/or registering for an account (“Account”) with us, you are accepting the terms of this Privacy & Cookies Policy, and you are consenting to our collection, use, disclosure, retention and protection of your personal information as described in this Privacy & Cookies Policy. If you do not provide the information we require, we may not be able to provide all of our Services to you.

We treat the data that you provide us with as strictly private and it shall only be used by us, by a member of our company and/or by a selected third party who complies with our high standards of data protection in order to manage the account which you open with us, to create customer profiles, to ensure the security of the site, and to enable you to use our services.

Bonas is committed to comply with the related European legislation and adheres to EU Data Protection and Electronic Communication laws for the purposes of this policy. Should you require further information or if you have any questions regarding privacy or confidentiality issues, please contact us.

Please take the time to read our Privacy Policy carefully.


1. COLLECTION OF YOUR PERSONAL DATA

We collect, process and retain personal information from you and any devices (including mobile devices) you may use when you use our Services, register for an account with us, provide us information on a web form, update or add information to your account, participate in chats, or when you otherwise correspond with us regarding our Services.

The personal information we collect includes the following:

1.1. Personal information you give us when you use our Services or register for an account with us
- Identifying information such as your name, addresses, telephone numbers, fax numbers and/or email addresses when you register for an account with us
- Company certificate of incorporation, trade license, group organogram, bank account details, passport copies of key individuals and/or directors, bourse and other trade bodies membership, generic company profile, product preferences, and all necessary documentation to comply with ‘Know Your Customer’ regulations and the Kimberley Process scheme
- Bidding information you provide during a transaction, or other transaction-based content that you generate or that is connected to your account as a result of a transaction you are involved in
- You may also provide us other information through a web form, by updating or adding information to your account, through your participation in live chats, or when you otherwise correspond with us regarding our Services

1.2. Personal information we collect automatically when you use our Services or register for an account with us
- We also collect information about your interaction with our Services and your communications with us. This is information we receive from the devices (including mobile devices) you use when you use our Services, register for an account with us, provide us information on a web form, update or add information to your account, participate in live chats, or when you otherwise correspond with us regarding our Services. This information comprises the following: Device ID or unique identifier, device type, and unique device token
- Geo-location information, including location information from your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device's settings' menu
- Computer and connection information such as statistics on your page views, traffic to and from the sites, your IP address, your browsing history and your web log information

1.3. Personal information we collect using cookies, web beacons, and similar technologies
We use cookies, web beacons, unique identifiers and similar technologies to collect information about the pages you view, the links you click and other actions you take on our Services. For more information about our use of these technologies, see below.

You also have the right to access your personal data at any time in order to make alterations to any personal information that may have changed and/or become obsolete. Should you believe that any personal information we hold for you is incorrect, please contact us as soon as possible and we will amend any information found to be incorrect.


2. USE AND RETENTION OF YOUR PERSONAL DATA

We use the personal information we collect to provide and improve our Services, to provide you with a personalised experience on our site, to contact you about your account and our Services, to provide you customer service, and to detect, prevent, mitigate and/or investigate fraudulent and/or illegal activities.
We may use and retain your personal information as follows:

2.1. Provide, improve and personalise our Services
- Provide access to and use of our Services
- Give you access to your bids, internal messages and other features
- Customise, measure and improve our Services
- Provide other services requested by you as described when we collect the information

2.2. Contact you about your account and provide you customer service
- Contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, or as otherwise necessary to provide you customer service
- Contact you as necessary to enforce our Privacy & Cookies Policy, applicable national laws and any agreement we may have with you
- For these purposes we may contact you via email, telephone, fax, text messages and/or postal mail

2.3. Prevent, detect, mitigate and investigate fraudulent or illegal activities
- Prevent, detect, mitigate and/or investigate fraud, security breaches, potentially prohibited or illegal activities
- Enforce our Privacy & Cookies Policy

We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms and Conditions and/or take other actions permitted or required by applicable national laws. After it is no longer necessary for us to retain your personal information, we dispose of it in a secure manner according to our data retention and deletion policies.

2.4. Third party privacy practices
This Privacy & Cookies Policy addresses only the use and disclosure of personal information we collect from you. If you disclose your information to others, and/or if you are directed to a third party website, their privacy notices and practices will apply.


3. WITHDRAW CONSENT

If you withdraw your consent for the use or disclosure of your personal information for purposes set out in this Privacy Notice, you may not have access to all our Services and we might not be able to provide you all of the Services and customer support offered to our customers and authorised under this Privacy & Cookies Policy.


4. COOKIES

4.1. What is a cookie?
A cookie is a short text file sent through your browser, registered on your device when visiting a website. Your web browser then sends these cookies back to the originating website on each subsequent visit, or to another website that recognises these cookies. We use cookies for navigation needs on our website, and to optimise and personalise our services, like allowing pages to load faster because certain content is stored on your browser or by helping us authenticate you to deliver personalised content. You can find out more about cookies and how to manage them at sites such as www.allaboutcookies.org.
Different types of cookies are used on our website and each has its specific target.

4.2. Cookies deemed as strictly necessary
Those cookies allow you to use the main functionalities of our website and access to secured areas of the website (example: access to your account). Without those cookies, our website cannot run normally. Those cookies also ensure security of the website and its customers. For example, we use session identification cookies to monitor the time of your connection. That’s why you are requested to re-connect after a certain time lapse. Sometimes we also use a permanent identification cookie that registers your email address (but not your password) so as to ease you next connections by filling in advance the "email" field.

4.3. Analytic cookies
Those cookies enable us to measure the website frequentation, to know how it is used and how customers react. Thus, the collected data enables us to improve our website and your navigation experience. The collected data remains strictly anonymous and is only subject to a purely statistical process. In this respect, we use a third-party service: Google Analytics. If you do not wish that Google Analytics collects or uses your information, you can directly unregister through your browser on the following Google page (https://tools.google.com/dlpage/gaoptout).

4.4. Functional cookies
Those cookies allow you to personalise your experience on our website. They may also provide you with functionalities you have personally requested. We may also use a cookie to help us route traffic between servers and thus measure loading times. Sometimes, we also store data on your browser or your device so that functionalities you usually use are automatically uploaded and thus respond quicker.

4.5. How to manage your cookies
It is not technically possible to adjust your cookie settings at our website, but you can manage your cookies through your browser. We recommend that you do not block or delete your cookies as it may limit the experience of your website visit. The cookies can usually be changed on the “Settings” section of your browser.


5. SECURITY

We protect your information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres and information access authorisation controls. If you believe your account has been abused, please contact us.

5.1. Sign in/out
You can typically end your signed in session by either signing out and/or clearing your cookies. If you have certain browser privacy settings enabled, simply closing your browser may also end your signed in session. If you are using a public or shared computer you should sign out and/or clear your cookies when you are done using our Services in order to protect your account and your personal information.

5.2. Log files
Like most standard website servers we use log files. This includes IP addresses, browser type, Internet service provider (ISP), exit pages, platform type, date/time stamp, and number of clicks to analyse trends, administer the site, and track user's movement.

5.3. Data encryption
All sensitive data, which is transmitted between your computer and Bonas, is transferred securely via the Internet, using strong encryption. Bonas uses secure and tested encryption technology bearing certificates provided by renowned certificate authorities.

5.4. Other security measures
When customers submit sensitive information via the site, their information is protected both online and offline. When our registration form asks users to enter sensitive information, that information is encrypted and is protected using secure socket layer (SSL) technology. While on a secure page, the lock icon at the bottom, or in the URL, of your web browser becomes locked.

While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user information offline. All of our users' information, not just the sensitive information mentioned above, is restricted in our offices. Only authorised Bonas employees are granted access to personally identifiable information. Our employees are regularly made aware of security best practices within the industry. Finally, the servers that store personally identifiable information are in a secure environment.


6. MODIFICATIONS

It may become necessary, at any time, for us to make modifications to the site, Terms and Conditions and/or Privacy & Cookies Policy governing our services. The purpose of such modifications may be to further simplify user processes or to further reinforce security measures in order to upgrade to future technological innovations. In such cases, customers previously registered on our site will keep their user name and password; no modifications will be required on their part. Continued use of our site by the members after any modifications to the site, Terms and Conditions or Privacy & Cookies Policy will be considered as their acceptance thereof. It is the responsibility of each customer to regularly check the Terms and Conditions, and Privacy Privacy & Cookies Policy, for updates.