Privacy Policy

October 2020

1. Introduction

This Privacy Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we collect from you (“you/your”) through the use of our services (“Services”), or the use of our website metronaps.com (“Website”), how that information may be used or disclosed by us and the safeguards we use to protect it.

Our Website and Services may contain links to third-party websites that are not covered by this Privacy Policy. We, therefore, ask you to review the privacy statements of other websites and applications to understand their information practices.

We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.

Please check back regularly to keep informed of updates to this Privacy Policy. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

If you are a citizen of an EU member state, you have the right to make a complaint at any time to your local European supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach an authority, so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you have any comments on this Privacy Policy, please email them to info@metronaps.com.

2.Who We Are

2.1 Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:

– Our Website address is metronaps.com

– Our company name is i20 LLC

– Our office address is 250 Executive Drive, Edgewood NY, USA

– Our nominated representative is Christopher Lindholst and they can be contacted at info@metronaps.com

2.2 We respect your right to privacy and will only process personal information about OR provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, and then (ii) any successor legislation to the GDPR or other applicable privacy laws.

3.What we may collect

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

– Identity Data: includes first name, last name, username or similar identifier. When you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone number.

– Contact Data: includes email address and telephone numbers as entered into our contact form.

– Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.

– Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

– Cookies Data: like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites.

– Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.

– Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

3.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

3.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

a) You have given consent to the processing of your personal data for one or more specific purposes;

b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

c) processing is necessary for compliance with a legal obligation to which we are subject;

d) processing is necessary to protect the vital interests of you or of another natural person;

e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.

3.6 If we receive personal information in the course of providing our Services to you from another data subject, we expect you to have complete responsibility for ensuring that the contents of this Privacy Policy are brought to their attention and you have obtained their consent in the process.

3.7 In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history.

4.How we may collect and use your data

4.1 We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:

Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

a) present Website content;

b) use any of our Services;

c) create an account on our Website;

d) subscribe to our Services or publications;

e) request marketing to be sent to you;

f) enter a competition, promotion or survey; or

g) give us some feedback.

4.2 In addition to the above, we may use the information in the following ways:

a) To personalize your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested.

b) To administer a contest, promotion, survey or other site feature.

c) If you have provided us with your contact details, we may send you periodic e-mails. If you would no longer like to receive promotional e-mail from us, please unsubscribe using the relevant option in the e-mail.

d) Present Website content effectively to you.

e) Provide information, and services that you request, or (with your consent) which we think may interest you.

f) Carry out our contracts with you.

g) Provide the relevant Services to you

h) Tell you our charges.

4.3 We will only contact you electronically about things related to our products and services which you have expressed interest in.

4.4 We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.

4.5 In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section, you can let us know at any time by contacting us at info@metronaps.com, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible products and services to you.

4.6 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.

4.7 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

a) Where we need to perform the contract we are about to enter into or have entered into with you.

b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

c) Where we need to comply with a legal or regulatory obligation

4.8 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third-party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at info@metronaps.com, and we will either delete your data from our systems or move your data to our “unsubscribe list”. However, you acknowledge this will limit our ability to provide the best possible services to you.

4.9 As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email and/or telephone with information, news and offers on our Services. We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.Cookies

5.1 All Cookies used by and on our website are used in accordance with current English and EU Cookie Law.

5.2 We use cookies to distinguish users and improve our Website. Please look at our Cookie Policy for more cookie information.

6.Where we store your data and security

6.1 If you are based within the EU, we may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfill your order and to receive our Services and deal with payment. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the EEA if it is necessary for us to do so.

6.2 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through our Website. Your personal data will only be processed on our instructions and all people handling your data are subject to a duty of confidentiality.

6.3 We will notify you and any applicable regulator of a breach where we are legally required to do so.

6.4 By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

6.5 We have implemented security measures to protect any data and maintain a high level of security.

6.6 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

6.7 We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of three years after our relationship has ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally permitted to.

7.Disclosing your information

7.1 We are allowed to disclose your information in the following cases:

7.1.1 If we want to sell our business or our company, we can disclose it to the potential buyer.

7.1.2 We can disclose it to other businesses in our group.

7.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.

7.1.4 We can exchange information with others to protect against fraud or credit risks.

7.2 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.

8.Your rights

8.1 Under the GDPR, you have the right to:

– request access to, deletion of or correction of, your personal data held by us at no cost to you;

– request that your personal data be transferred to another person (data portability);

– be informed of what data processing is taking place;

– restrict processing;

– to object to the processing of your personal data; and

– complain to a supervisory authority.

8.2 You have the right to ask us not to process your personal data for marketing purposes.

8.3 To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy Policy, please contact us at info@metronaps.com.

9.Links to other sites

9.1 Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

10.Changes

10.1 If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also email you.

11.Terms and Conditions

12.1 Please also visit our Terms and Conditions section for establishing the use, disclaimers, and limitations of liability governing the use of our Website.

12.Your Consent

13.1 By using our Website and by way of acknowledgment, you consent to our Privacy Policy.