Privacy Policy

Background

NMORE GROUP LTD understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. 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 Site. You will be also required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

As of May 25, 2018, the EU General Data Protection Regulation (GDPR) 2016/679 is in effect, providing protections for individuals regarding the processing of personal data and ensuring the free flow of such data. This regulation replaces Directive 95/46/EU, which was implemented through Law 138(I)/2001. Consequently, as of May 25, 2018, that law is considered abolished.

More information may be obtained from the European Commission’s relevant website here and from the official Cyprus Government portal at www.dataprotection.gov.cy.

Our role as service providers include the obligation to secure that, personal data of yours and of any third parties such as employees, contractors, clients, principals and other individuals and contracting parties related to you, which has come or may come into our possession and which may also contain sensitive data, is processed in accordance with relevant Regulation and/or other laws in force.

Such processing may relate to agreements entered between us as service providers and yourselves, to the provision of services by us as service providers and intermediate service providers, to the adherence with laws, regulations and directives, KYC (know-your-client) procedures, the manner of operation and management of our business, including business development, account management, internal financial reporting, IT and/or marketing processing, legal due diligence or disclosure of information clients, to banks, legal or other associates of ours who may offer services to you, to international organizations whether in the Republic of Cyprus or any other European Union or other third countries.

Unless otherwise instructed by you we consider that we may process, collect, store, disclose, copy and transfer personal data, relating to you and/or your employees, contractors, clients, principals and other individuals and contracting parties of relevance to you in the same manner without the need for a separate consent on each occasion and at each time, such consent considered as duly given. Collection of such data may be made from you, any authorised by you person, any agencies who carry out investigations on our behalf, other public domain information sources such as the internet etc. Please be informed that we may not follow any instructions by you prohibiting the processing, collection, storage, disclosure, copying and transferring of personal data, relating to you and/or your employees, contractors, clients and other individuals of relevance to you, in the event that any other law/regulations in force imposes upon us any contrary obligation. For all intents and purposes the provisions of any laws/regulations in force which may provide otherwise, shall override any of your instructions.

When you provide personal data to us about third parties such as employees, contractors, clients, principals and other individuals and contracting parties etc, you shall be considered as having provided the data, with due and received authority to have done so as their agent and as having obtained any required consents.

All correspondence files and records (other than statutory corporate records) and all information and data held by us on our computers/servers are the sole property of ours and you shall have no right of access thereto or control there over, however you shall be free to request by written instructions, details of your personal information data held by us, you may demand the correction of any wrong or inaccurate information in our data records and ask for any copies of data maintained by us which you or any authorized representative of yours have furnished us with.

The maintenance, use storage, use etc. of personal data shall be kept by us to the extent and as long as the relevant law/s or any regulation/s provide. Should any law require the keeping and maintenance of certain date for a longer period of time we undertake to arbitrarily or on your request remove from our data system upon the lapse of the period provided by the GDPR, data relating to you which may be irrelevant or unnecessary for keeping for the purposes of compliance with any such law/s or regulation/s.

We are providing you herein below with the following information in addition to the above information which include the purposes of processing of personal data the legal basis for doing so, the recipients of personal data, our legitimate interests and transfer of such data. As a data subject you may address any concern of yours on a matter relating to your data protection rights to the company’s Data Protection Officer below.

Data Protection Officer (DPO): Mr. Nikita Snigirev
Contact details of DPO: legal@nmore.com

Any complaints you may have with regards to any violation of your rights under the GDPR may be lodged with the relevant supervisory authority whose details are as follows:

Officer of the Commissioner on Personal Data Protection
1, Iasonos Str., 1082 Nicosia
P.O.Box 23378, 1682 Nicosia
Tel: +357 22818456, Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy
Website: http://www.dataprotection.gov.cy

If you should wish to have your name and address removed from our specific purposes mailing list, you should provide us with clear Instructions in this respect or click on the unsubscribe link in any of such mailings. However, in such a case we shall not be held liable and you hereby relieve us of any liability with respect to any information of essence which may not reach you.

We remain at your disposal for any clarification on the above, whilst we assure you that our firm is aiming to be duly compliant with the GDPR and other laws/regulations/directives in force.

1. Definitions and interpretations

In this Policy the following terms shall have the following meanings:

“Account“	means an account required to access and/or use certain areas and features of Our Site;
“Cookie“	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
“Our Site“	means this website, www.nmore.com;
“UK and EU Cookie Law”	means the relevant parts of the EU General Data Protection Regulation 2016/679 (GDPR);
“We/Us/Our”	means NMORE GROUP LTD, a limited company registered in the Republic of Cyprus with registration number HE 355502, whose registered address is 159 Leontiou A street, Maryvonne Building, Office 202, Limassol, 3022, Cyprus.

2. Information about us

Our Site, www.nmore.com, is owned and operated by NMORE GROUP LTD, a limited company registered in the Republic of Cyprus with registration number HE 355502, whose registered address is 159 Leontiou A street, Maryvonne Building, Office 202, Limassol, 3022, Cyprus.

3. Scope – what does this policy cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). 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.

4. What data we collect?

Some data will be collected automatically by Our Site (for further details, please see section 12 on Our use of Cookies), other data will only be collected if you voluntarily submit it, for example, when signing up for an Account or filling up the contact form. Depending upon your use of Our Site, We may collect some or all of the following data:

• your full name;
• business/company name;
• your  job title and/or profession;
• IP address (automatically collected);
• operating system (automatically collected);
• contact information such as email addresses and telephone numbers;
• demographic information such as post code, preferences and interests;
• web browser type and version (automatically collected);
• a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);

5. How do we use your data?

All personal data is stored securely in accordance with the principles of the EU General Data Protection Regulation 2016/679 (GDPR). For more details on security see section 6, below. We use your data to provide the best possible products and services to you. This includes:

• Providing and managing your Account;
• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying Our services to you;
• Personalising and tailoring Our products and services for you;
• Responding to communications from you;
• Supplying you with email alerts, newsletters and announcements that you have subscribed to automatically by providing us with your details (you may unsubscribe or opt-out at any time by clicking the “Unsubscribe” button at the bottom of any promotional email;
• Market research;
• Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

With your permission and where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and telephone and text message and post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the EU General Data Protection Regulation 2016/679 (GDPR).

6. How and where do we store your data?

We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.

Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. 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 EU General Data Protection Regulation 2016/679 (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 and the use of the EU-approved Model Contractual Arrangements. If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand.

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 Site.

Steps We take to secure and protect your data include:

• Strong 2048-Bit SSL Extended Validation Certificate Encryption by Comodo.
• We use Alphabet’s (Google) email services, which are highly secured.
• We follow strict internal procedures when handling any sensitive data.

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.

7. Do we share your data?

We may share your data with other companies in Our group. This includes Our holding company and its subsidiaries.

We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. 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 the law.

We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What Happens if Our Business Changes Ownership?

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

In the event that any of your data is to be transferred in such a manner, you will  be contacted in advance and informed of the changes. When contacted you will not, however,be given the choice to have your data deleted or withheld from the new owner or controller.

9. How can you control your data?

When you submit information via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails).

10. Your right to withhold information

• You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
• You may restrict your internet browser’s use of Cookies. For more information, see section 12.

11. How can you access your data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at legal@nmore.com.

12. Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for online marketing and advertising services. In addition, Our Site uses analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site.

“Cookies” are small pieces of information that are transferred to your browser and stored on your computer’s hard drive. Our cookies enable us to provide you with more personal service. Cookies also allow us to track usage patterns, trends and other aggregate visitor information. Most web browsers automatically accept cookies, but you can usually change your browser to prevent that if you would rather not store the information for future use. We may also collect certain technical and routing information about your computer to facilitate your use of the site and its services (such as browser type, operating system and the Internet Protocol (“IP”) address of your computer). Without expressly informing you in each particular instance, we do not match such information with any of your personal information.

13. Your consent and changes to this privacy policy

By using this web site (www.nmore.com) and any of its sub-domains (*.nmore.com), you consent to the collection, use and processing of this information by NMORE GROUP LTD. If we decide to change our privacy practices, we will post those changes on this page. Please check this page for changes from time to time to make sure you are aware of our latest privacy practices.

14. Updates questions and feedback

Our goal is to respect your privacy. You may at any time update or change your personal information or privacy preferences. To change your information, simply send an email to info@nmore.com and we will respond with an information update form. If you have any questions or doubts about our Privacy Policy or in case you have feedback to help us improve our policies, please contact us by email at legal@nmore.com or call us directly at +357 25 030 010.