1. General

CREDEMA is committed to protecting the privacy of any person or entity that uses, or makes use of its services, products, or system (“User” or “Users”). This privacy policy (hereinafter “Policy”) explains when and how personal information is collected, used, disclosed and protected with respect to the CREDEMA website located at www.credema.cloud (the “Site”). By using the Site, the User fully understands and consents to the privacy practices described in this Policy, as reasonably modified from time to time by us. Please carefully review this Policy in order to fully understand our data privacy practices.

  1. Personal Information

Personal Information shall be defined, but not limited to, as information that is specifically identifiable to a unique individual, information such as a name, address, individual’s telephone number, e-mail address, account number, information about an individual’s activities if directly linked to that person (hereinafter “Personal Information”).  Personal Information also includes, but shall not be limited to, demographic information, such as date of birth, one’s gender, geographic area, and personal preferences if such information can identifiable and unique.

  1. Personal Information We Collect

CREDEMA collects Personal Information from Users in a number of ways. For example, we collect personal information when you: (1) register and set up an account; and (2) contact us by e-mail for any reason. When you visit our web site, some information is also automatically collected, such as your computer’s Internet Protocol (IP) address, your computer’s operating system, the browser type, the address of a referring web site, and the time and date of your visit and purchases. We treat this information as personal information if we combine it with or link it to any of the identifying information mentioned above.  While these may be some examples of how we can gather and obtain User Personal Information, User shall not consider this to be an exhaustive list.

  1. How We Use Personal Information

CREDEMA uses personal information to process your requests and provide you with service or to inform you about other products or services we think will be of interest. When we use personal information in our marketing efforts, we provide you with options and do not disclose the information to third parties except as described in this Policy. Personal information provided online may be linked together or merged with other personal information so that we may better understand your needs and inform you about our products or services. We also use your personal information to send you informational e-mails, including without limitation newsletters, notifications by account owners, league managers, captains, players and group members, and reminders of event schedules and attendance.

  1. Emails

If Users send emails through the CREDEMA site, the User must understand that the email will include email address and any personal message included. Due to the nature of the e-mail being sent from our site, these emails are not private communications and therefore are not confidential. We have no responsibility to keep such information confidential if a User sends emails through the CREDEMA Site.  User shall not use the Site or any software provided through the Site to send spam or content that violates this agreement or any other User agreement. To stop receiving emails from us or our clients, please click the link found at the bottom of each email or update your account preferences.

  1. Security

CREDEMA has put security measures into place in an effort to protect User’s Personal Information while such information is under our control. All Personal Information relating to Users are stored in a reasonably secure environment, separate from the Site. User’s account information is accessible online only through the use of a confidential password. To protect the confidentiality of Personal Information, User must keep its password confidential and not disclose it to any other person. User is solely responsible for all uses of the Site by any person using User password. User shall advise us immediately if User believes its password has been misused or improperly obtained.

  1. Control of Personal Information

CREDEMA gives the User the opportunity to opt-out of receiving communications from us, and to limit the use and disclosure of the User’s own Personal Information for purposes other than which it was originally collected or subsequently authorized.  Every non-transactional email sent by our servers includes a link to manage preferences.  Use that link to opt-out of any communications from that sender. You can also opt out by sending an email to support@credema.eu with a reference to the email you received.  CREDEMA does not sell, rent, or share Personal Information with third parties without User’s prior consent, except in the limited circumstances, such circumstances described in this Policy.  CREDEMA acknowledges that EU individuals have the right to access the personal information that we maintain about them.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to the contact information listed below. If requested to remove data, we will respond within a reasonable time frame.

CREDEMA may share Personal Information with third-party vendors who assist us in performing functions necessary to operate our business. These functions may include, but are not limited to, website hosting, credit card transaction processing, and data entry. We limit User Personal Information shared with our third-party vendors to that which we believe is necessary to carry out those functions. In addition, we may disclose Personal Information in the good faith belief that we are lawfully authorized to do so, or that doing so is reasonably necessary to comply with legal process or authorities, respond to any claims, or to protect the rights, property or personal safety of CREDEMA, its users, its employees or the public.  We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.  Information about our Users, including Personal Information, may be disclosed or transferred as part of, or during negotiations of, any merger, sale of company assets or acquisition.

Notwithstanding any other provision, we may also engage a data provider who may collect web log data from contacts in CREDEMA accounts (including IP address and information about browser or operating system), or place or recognize a unique cookie on such contacts’ browsers to enable the delivery of customized content.   These cookies contain no personally identifiable information.  The cookies may reflect de-identified demographic or other data linked to data that our users have voluntarily submitted to us, e.g., email address, that we may use to interface with a data provider solely in hashed, non-human readable form. To opt-out of these data provider cookies, please go to http://www.aboutads.info/choices

  1.  EU-US and Swiss-US Privacy Shield

CREDEMA complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. CREDEMA has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the US-EU and Swiss-US Privacy Shield Principles, CREDEMA commits to resolve complaints about your privacy and our collection or use of your personal information.

CREDEMA has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

When a customer and CREDEMA have agreed by contract that transfers of personal information from the European Economic Area (“EEA”) or Switzerland will be transferred and processed pursuant to the Privacy Shield for the relevant services, when conducting those activities on behalf of its EEA/Swiss customers, CREDEMA holds and/or processes personal information provided by the EEA/Swiss customer at the direction of the customer. We will then be responsible for ensuring that third parties acting as agents on its behalf meet the same standards.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. CREDEMA is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

  1. Cookies, IP Addresses and URLs

Automatically Collected Information: CREDEMA automatically receives certain types of Personal Information whenever a User interacts with us. For example, when a User visits the Site, we automatically collect the User IP address and the type of browser the User uses. Information may be automatically collected through the use of a term called “cookies.” We also collect various types of information called ‘clickstream information’, which is information about Users browsing behaviour, such as IP address information, entry and exit points for the Site, search terms, web site addresses User visits, page views, and impressions. Cookies are also collected.  Cookies are small text files placed on Users hard drive by a web site when Users visit a particular website. These files identify a User’s computer and record a User’s preferences and other data about a User’s visit so that when the User returns to the site, the site knows who the User is, and can personalize the User visit. Most browsers automatically accept cookies as the default setting. Users can modify the setting to reject cookies or to prompt Users before accepting a cookie from the sites User visit by editing browser options. We may place or recognize a unique cookie on Users browser to enable Users to receive customized content or services. Any cookies made available to shopping carts or other tracking information sent to third parties will reflect only de-identified demographic or other data linked to data Users have voluntarily submitted to us, will be encrypted, and will not be used to identify Users individually. If Users decide not to accept our cookies, Users will still be able to access those parts of our site available to the general public, but Users may not be able to login or use the site’s features or services, and Users may have a less satisfactory experience.

  1. Links to Other Web Sites

The CREDEMA website may contain links to other web sites. Any Personal Information User provides on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Except as described above, we are not responsible for the content or privacy and security practices and policies of web sites to which we link. Links from our website to third parties or to other sites are provided for User convenience. We encourage Users to learn about their privacy and security practices and policies before providing them with Personal Information.

  1. Policy Changes

We reserve the right to change or alter this Policy at any time. We may use User Personal Information for new, unanticipated uses not previously disclosed in this Policy. If our privacy practices change, we will post the policy changes to our web site and notify Users by indicating the date the privacy policy was last updated. We encourage Users to check back at our website periodically if the User is concerned about how the Users Personal Information is used.

 This privacy policy was last updated 23 August 2017