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STURME undertakes to collect Your Data by means that are:
- If you visit STURME's web-site, your web-browser automatically discloses, and STURME's web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested,and whether your request was successful. This data may or may not be sufficient to identify you.
- Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.
- Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in'cookies' and submits them each time you request a web-page within a particular domain (such as STURME.com). This data may or may not be sufficient to identify you.
- If you disclose personal data to STURME in conjunction with an identifier such as your name or your contact details (such as your e-mail address), STURME will collect Your Data. Moreover, any data that becomes available to STURME through any of the means described in the preceding paragraphs may be able to be associated with that identifier,and hence become Your Data.
- Subject to the qualifications immediately below, STURME undertakes to collect Your Data from you and not from other parties.
This undertaking is qualified as follows:
- Where STURME reasonably considers that the protection of its financial interests requires that it gather Your Data from other sources, or from additional sources. This applies in particular where STURME has a lending exposure to you, and seeks information about your creditworthiness;
- Where STURME reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering Your Data from other sources. This applies in particular to consumer profile data.
Where STURME collects Your Data from sources other than you, it undertakes:
- To do so only by legal means;
- To do so only with your Consent;
- To declare to you what sources it uses, and under what circumstances.
- STURME undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.
- STURME undertakes to store Your Data in a manner that ensures security against unauthorized access, alteration or deletion, at a level commensurate with its sensitivity.
- STURME undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.
- STURME undertakes to transmit Your Data in a manner that ensures security against unauthorized access, alteration or deletion, at a level commensurate with its sensitivity.
- STURME undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behavior by STURME's staff-members and contractors.
- Training for staff in relation to privacy;
- Access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it;
- Particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
- Reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behavior;
- Declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behavior
- Clear communication of policies and sanctions;
- Processes to audit, to investigate and to impose sanctions.
- Use refers to the application of Your Data by any part of STURME, or any staff-member or contractor of STURME in the course of their work.
STURME undertakes to use Your Data only for:
- The purposes for which it was collected;
- Such other purposes as are subsequently agreed between STURME and You;
- Such additional purposes as may be required by law. In these circumstances, STURME will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law;
- Such additional purposes as are authorized by law (in particular to protect STURME's interests, e.g. if it believes on reasonable grounds that You have failed to fulfill your undertakings to STURME or have committed a breach of the criminal law
- At all times, we will offer you opportunities to unsubscribe out of any service or update to which you have subscribed, if you changed your mind. Any email we send you will contain an easy automate Unsubscribe link at the bottom, so that you can opt-out of that subscription. Simply follow the indication in the email.
- When you register on STURME.com and subscribe to the categories you prefer, you will also be given the option of opt-out of subscribing to our regular updates. Once you subscribe, we’ll send you a mail alerts for featured offers, deals, new arrivals, contests, events of interest, system enhancement, and marketing promotions. Such alerts may include information about STURME.com, subsidiaries, or partners.
- STURME undertakes to use Your Data only if it has demonstrable relevance to the particular use to which it is being put.
- STURME undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
- Disclosure refers to making Your Data available to any party other than STURME and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
STURME undertakes to disclose Your Data only under the following circumstances:
- In the course of business being conducted between You and STURME, where disclosure is necessary to a contractor, such as payment processors like PayPal and transportation companies. Where Your Data is disclosed in this way, STURME undertakes to exercise control over STURME's contractors to ensure that their actions are compliant with these Terms;
- In other circumstances that are directly implied by the purpose agreed between You and STURME at the time of data collection or subsequently. Where Your Data is disclosed in this way, STURME undertakes to exercise control over STURME's contractors to ensure that their actions are compliant with these Terms;
- With your consent, or at your request;
- Where required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena. In these circumstances, STURME will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
- Where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where STURME believes on reasonable grounds that the disclosure of Your Data will materially assist in the protection of the life of health of some person), provided that STURME will apply due diligence to ensure that the exercise of the permission is justifiable.
- In all cases, STURME undertakes to disclose only such of Your Data as is necessary in the particular circumstances.
Data Retention and Destruction
Subject to the qualifications immediately below, STURME undertakes:
- To retain Your Data only as long as is consistent with its purpose;
- To destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered.
In these circumstances STURME:
- Will take any reasonable steps available to it to communicate to You that Your Data is being retained, unless it is precluded from doing so by law;
- Will only retain Your Data while that provision is current, and will then destroy Your Data;
- STURME follows all of the existing Google's Remarketing Privacy Guidelines, Policies, and Restrictions.
- STURME uses Analytics data and the DoubleClick cookie to serve ads based on your prior visits to STURME.com.
- You may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or you may opt out of Google Analytics by visiting the Google Analytics Opt-out page.
- Your Data may be retained beyond the expiry of its purpose if it is authorized by law (in particular to protect STURME's interests, e.g. if it believes on reasonable grounds that You have failed to fulfill your undertakings to STURME or have committed a breach of the criminal law). In these circumstances, STURME will only retain Your Data while that situation is current and will then destroy Your Data.
Access by You to Your Personal Data
- STURME undertakes to provide you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances.
In particular, STURME undertakes to enable access:
- Without unreasonable delay
- Without cost
- STURME undertakes to establish and operate identity authentication protections for access to Your Data that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with STURME (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.
- In the event that you dispute some aspect of Your Data, STURME undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.
- Not to seek access for frivolous purposes, or unreasonably frequently;
- To accept that deletion of some data may not be consistent with the provision of particular services by STURME to you.
Information about Data-Handling Practices
STURME undertakes to make information available to you about the manner in which STURME handles your data:
- In general terms, in a readily accessible manner
- In more specific terms, on request
- Where Your Data is disclosed to a contractor, STURME undertakes to make information available to you on request about the manner in which STURME's contractors handle your data.
- STURME undertakes to ensure that the information provided is meaningful and addresses your concerns.
- Not to seek such information for frivolous purposes, or unreasonably frequently
- To accept that the disclosure of excessive detail may harm the security of Your Data and STURME's business processes, and may harm STURME's commercial interests.
Handling of Enquiries, General Concerns and Complaints
- If you have enquiries, general concerns, or complaints about these Terms, or about STURME's behavior in relation to these Terms.
- To provide one or more channels for communications to STURME, which are convenient to users
- To promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication, the date and time it was registered, and STURME's reference-code for the communication;
- To promptly provide a response to the communication, in an appropriate and meaningful manner.
You further undertake to not pursue STURME through any Regulator or the media:
- Until and unless STURME has had a reasonable opportunity to respond to the initial communication;
- In sufficient detail
- While STURME and you remain are conducting a meaningful dialogue about the matter.
- STURME declares that its undertakings in these Terms are intended to create legal obligations, and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.
- You undertake to seek enforcement only in a jurisdiction that is relevant to the transactions that have taken place between You and STURME, in particular the jurisdiction in which you live or in which you performed the relevant acts, and the jurisdiction in which STURME is domiciled or performed the relevant acts.
If you wish to discover the relevant laws in any particular jurisdiction, STURME draws your attention to the following resources:
- World LII Privacy Links
- Compilation of [U.S.] State and Federal Privacy Laws Privacy Journal, Providence RI
- Privacy Law Sourcebook 2004, EPIC Washington DC
The Australian Privacy Foundation's pages:
- International Instruments Relating to Privacy Law
- Privacy Laws of Countries of the World
- Privacy Laws of the Commonwealth of Australia
- Privacy Laws of the States and Territories of Australia
- Privacy International
Changes to These Privacy Undertakings
- To provide one or more channels for communications to STURME, which are convenient to users
- Not to materially change these Terms in a manner that reduces the protections for Your Data;
- To take all possible steps to prevent any company that acquires this company or any of its relevant assets from materially changing the Terms applicable to Your Data in a manner that reduces the protections for Your Data;
- Where it is considering making changes to these Terms, or creating more specific Terms relating to specific services, to consult with appropriate representative and advocacy organizations;
- Where it makes changes to these Terms, to ensure that the differences between successive versions are readily accessible;
- To maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.