Privacy Policy

RECOMMENDPRO DIGITAL LTD (Recommend, we, or us) is a company registered in the Republic of Cyprus (with Company No. HE349544).

Our registered office is: Avenue Spyrou Kyprianou, 67, Kyriakides Business Center, 4003, Limassol, Cyprus.

You can contact us by email: info@recommend.pro

Via our site at https://recommend.pro (our site), Recommend provides a service which allows you to purchase retail personalization platform software for your ecommerce site (the Services).

This policy (together with our Services terms (if you use our Services) and our site) sets out the basis on which any personal data (meaning information about an individual from which that individual can be personally identified) we collect from you, or that you or others provide to us, will be processed by us. This includes personal data we use in connection with:

  • the provision of the Services;
  • our site; and
  • you contacting us via the site or by telephone.

For the purpose of data protection laws, the data controller is RecommendPro Digital Ltd.

  1. BASIS FOR PROCESSING personal data – site use and requesting / receiving services from Recommend

    1. Paragraphs 1.2 – 1.7 below explain how and why we process your personal data, as well as the legal basis on which we carry out this processing.

    2. To enter into and perform contracts with you: Where you ask us to provide or express an interest in receiving Services from us via the site (or other contact with us), we will process your personal data to process your order and deliver those Services to you.

      Our use of your personal data in this way includes sharing your personal data with subcontractors, such as payment processors, as well as credit reference agencies for the purposes of assessing fraud, credit and/or security risks. We need to process your personal data in this way to enter into and perform the contract for the supply of the Services. If you do not wish to provide us with your personal data in this way, you will be unable to purchase or use Services from our site.

    3. To make our site better: We will also process your personal data in order to provide you with a more effective user experience (such as by displaying services we believe you will be interested in, based on your browsing habits). This processing means that your experience of our site will be more tailored to you, and that the content you see on our site may differ from someone accessing the same site with a different purchase history or browsing habits. We also use various cookies to help us improve our site (more details are set out in section 5), but we will not share your personal data with third party analytics and search engine providers that assist us in the improvement and optimisation of our site.

      We will also process your personal data for the purposes of making our site more secure, and to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

      The legal basis on which we process personal data in these circumstances is our legitimate interest to provide you with the best customer experience we can, and to ensure that our site is kept secure.

      The use of non-essential cookies is subject to your consent. You can also prevent us from using your personal data in this way by using the 'do not track' functionality in your internet browser. If you enable such do not track functionality, our site may be less tailored to your needs and preferences.

    4. To provide customer services to you: We may also process your personal data in order to provide various supporting customer services to you (such as where you contact us with a question in connection with our services or the Services). The legal basis on which we process your personal data in these circumstances is your consent. If you do not provide us with the personal data we request from you for customer services purposes, we may not be able to fully answer your queries.

    5. For marketing purposes: Where you have opted in via our site to receive marketing communications from us, we will process your personal data to provide you with marketing communications in line with the preferences you have provided.

      In this case, the legal basis on which we process your personal data is your consent. You are not under any obligation to provide us with your personal data for marketing purposes, and you can withdraw your consent to your personal data being processed in this way at any time by contacting us at info@recommend.pro or, where relevant, by following the unsubscribe link in any marketing communication you receive from us.

    6. If our business is sold: We will transfer your personal data to a third party:

      1. in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets (at all times in accordance with data protection legislation); or

      2. if Recommend is, or substantially all of our assets are, acquired by a third party, in which case personal data held by Recommend about its customers will be one of the assets transferred to the purchaser.

      In each case, the legal basis on which we process your data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you object to our use of your personal data in this way, the relevant seller or buyer of our business may not be able to provide services to you.

    7. In certain circumstances we may also need to share your personal data if we are under a duty to disclose or share personal data in order to comply with a legal obligation.

  2. BASIS FOR PROCESSING personal data – supplying the Services

    1. To provide the Services to you: We may also process your customers' personal data, where required to do so in order to provide the Services to you (such as where our obligations under the Services require us to analyse your customers' activity on your ecommerce platform). The legal basis on which we process your customers' personal data in these circumstances is pursuant to our legitimate interest in complying with our obligations under the contract for Services between you and us. Our Service terms will be provided to you separately should you purchase and / or otherwise use our Services. For the avoidance of doubt, these Service terms require that you shall ensure that you are entitled to transfer the relevant customer personal data to us so that we may lawfully use, process and transfer the customer personal in accordance with our obligations under the Services contract.

    2. If you do not provide us with your customer personal data, as required, for the purpose of our providing the Services to you, we may not be able to fully and effectively provide the Services.

    3. If our business is sold:

      1. In the event that we sell or buy any business or assets, the prospective seller or buyer of such business or assets may be granted the rights afforded to us under the Services contract to process your customers' personal data (at all times in accordance with data protection legislation); and

      2. if Recommend is, or substantially all of our assets are, acquired by a third party, access rights to your customers' personal data processed by Recommend pursuant to the Services contract will be one of the assets transferred to the purchaser,

      in each case, the legal basis on which we process your customers' data in these circumstances is our legitimate interest to ensure our business can be continued by a purchaser. If you or your customers object to our use of your customers' personal data in this way, the relevant seller or buyer of our business may not be able to provide the Services to you.

  3. CATEGORIES OF Information we may collect from you

    We will collect and process the following personal data:

    1. Information you give us: This is information about you that you give us by filling in forms on our site, making a purchase from our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site or services and when you report a problem with our site or the Services. The information you give us may include names, addresses, email addresses and phone numbers.

    2. Information we collect about you: With regard to each of your visits to our site we may automatically collect the following information:

      1. technical information, including the Internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and

      2. information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages and methods used to browse away from the page.

    3. Information we receive from other sources: We may receive information about you when you use our site.

    4. We do not process any special categories of personal data, meaning personal data revealing:

      1. racial or ethnic origin;

      2. political opinions; religious or philosophical beliefs or trade union membership;

      3. genetic or biometric data that uniquely identifies individuals;

      4. data concerning an individual's health, sex life or sexual orientation; or

      5. data relating to criminal convictions or offences or related security measures.

  4. Categories of Personal data we may process as part of our provision of the services

    We may process the following personal data:

    1. Information you give us: This is information about your customers that your customers give you by filling in forms on your ecommerce platform. It includes information your customers provide when they register to use your ecommerce platform, purchase via your ecommerce platform or participate in social media functions on your ecommerce platform. The information may include names, addresses, email addresses and phone numbers of your customers.

    2. We do not process any special categories of personal data, meaning personal data revealing:

      1. racial or ethnic origin;

      2. political opinions; religious or philosophical beliefs or trade union membership;

      3. genetic or biometric data that uniquely identifies individuals;

      4. data concerning an individual's health, sex life or sexual orientation; or

      5. data relating to criminal convictions or offences or related security measures,

      6. in relation to your customers.

  5. Cookies

    1. Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

    2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer's browser or hard drive if you provide your consent.

      StorageNamePurposeCookie Expiry
      CookiePHPSESSIDRequired to be able to login and browse the control panel as a logged in user.Session only
      CookieRMTRememberMe encrypted token required for the system to remember the logged in user.8 days
      CookieRMURememberMe encrypted user id required for the system to remember the logged in user.8 days
      Cookierecommend-widgets-dashboardRequired to store the dashboard settings for a particular user.365 day
      HTML5 Web Local StoragerecommendReportsRequired to store the reports section settings for a particular user.Local storage has no expiration time
    3. Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

    4. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

  6. Uses made of the information

    We will combine the information you provide to us with information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

  7. Where we store personal data

    The data that we collect from you will be stored in the European Economic Area.

  8. Period of storage

    1. Where you purchase Services from us we may retain your data to ensure that we are able to assist you should you have any questions, feedback or issues in connection with the Services you have purchased from us. You have the right to know the period for which we will retain your data (which will be no more than six years after we finish providing the Services to you); or the criteria used to determine that period (such as the type of Services purchased from us). To exercise this right at any time, please contact us at info@recommend.pro.

    2. Where we have processed your personal data to provide you with marketing communications, we will contact you at least every twelve months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our lists.

    3. Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with a product) subject to section 8.1 above, we will retain your data for three months.

  9. Your right to object under data protection laws

    1. You have the right to object to us processing your personal data where we are processing your personal data:

      1. based on our legitimate interests (as set out at sections 1.3 and 1.6 above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and

      2. for direct marking purposes. If you ask us to stop processing your personal data on this basis, we will stop.

  10. Your other rights under data protection laws

    You can exercise the rights set out below in this section 10 by contacting us at info@recommend.pro.

    1. Right of access

      Individuals have the right to receive confirmation as to whether their personal data is being processed by us, as well as various other information relating to our use of their personal data. Individuals also have the right to access their personal data which we are processing. If you exercise this right before 25 May 2018, your request will be subject to a £10 fee.

    2. Right to rectification

      Individuals have the right to require us to rectify any inaccurate personal data we hold about them. Individuals also have the right to have incomplete personal data we hold about them completed, by providing a supplementary statement to us.

    3. Right to restriction

      Individuals have the right to restrict our processing of their personal data where:

      1. the accuracy of the personal data is being contested by the individual;

      2. the processing by us of the individual's personal data is unlawful, but they do not want the relevant personal data erased;

      3. we no longer need to process an individual's personal data for the agreed purposes, but the individual wants to preserve their personal data for the establishment, exercise or defence of legal claims; or

      4. we are processing an individual's personal data on the basis of our legitimate interest (as set out at section 1.3 above) and the individual:

        1. objects to our processing on the basis of our legitimate interest under section 9.1.1 above; and

        2. wants processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides the individual's legitimate interest.

    4. Where any exercise by an individual of their right to restriction determines that our processing of particular personal data is to be restricted, we will then only process the relevant personal data in accordance with the individual's consent and, in addition, for storage purposes and for the purpose of legal claims.

    5. Right to data portability

      Individuals have the right to receive their personal data in structured, standard machine readable format and the right to transmit such personal data to another controller.

    6. Right to erasure

      Individuals have the right to require we erase their personal data which we are processing where one of the following grounds applies:

      1. the processing is no longer necessary in relation to the purposes for which the individual's personal data were collected or otherwise processed;

      2. our processing of the individual's personal data is based on their consent, the individual has subsequently withdrawn their consent and there is no other legal ground we can use to process the individual's personal data;

      3. the individual objects to the processing in as set out in section 9.1.1 of this policy and we have no overriding legitimate interest for our processing,

      4. the personal data have been unlawfully processed; and

      5. the erasure is required for compliance with a law to which we are subject.

    7. You have the right to lodge a complaint with the Information Commissioner's Office, the supervisory authority for data protection issues in England and Wales.

  11. Changes to our privacy policy

    Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

  12. Contact

    Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@recommend.pro.

    This privacy policy was last updated in March 2018