The section of the Site is owned and operated by Fairdos Online Services Limited, Reg No. C387234, having registered address at Achilleos,21 Flat/Office B, Agios Dometios 2370, Nicosia, Cyprus.

When this policy mentions “we”, “us”, “our”, all of the following terms refer to Cornbow Limited and our associated companies.

The Data Protection Officer is responsible for data protection. You can contact by emailing at [email protected]

We may update, amend or modify this policy from time to time. Any change in this policy will depend on current and future applicable data protection laws, business requirements and any modification to this website including the addition of new features.

This policy is translated into some languages to provide information to users. From a legal point of view, the English version is original and gives priority to other language versions.

This policy was last updated on 01/07/2020

The objective of this policy is to give clear indications on how we process your personal data when you visit this website and become a partner with us.

It also gives you the necessary information with regards to the way your personal data is being processed when:

• You submit a request to be contacted
• You submit a request for a call-back
• You join Kabuki Partners partnership
• You visit/browse the website

We process your personal data in line with current applicable legislation

If you are located overseas, your personal data will also be processed in line with the above regulations and regardless of your geographical location.

Under the General Data Protection Regulation, consent should be given in a positive and affirmative way by individuals who share their personal data with organisations. According to the European Data Protection Directive, consent means: “any freely given specific and informed indication of his wishes by which the data subject signifies his agreement to personal data relating to him being processed.”

When you submit your personal data on the website to become a Kabuki partners, you must accept the terms and condition agreement. With regards to marketing content, you will have the option to opt-in for such communications. Please note that you are free to opt-out from marketing at any time if you do not wish to receive marketing communications anymore. Your data will be retained according to our data retention policy and it will only be processed for the purposes that we have detailed in section 6 of this policy.

We gather a certain amount of personal data from the website. This data is the data that you submit to us on the “Join” section when you decide to become a Kabuki partners. Please note that only certain fields are mandatory (those marked with a red star). However, if you decide to input data in a field that is not mandatory, we will also collect and process that data.

In order to become a Kabuki partners, we have a business requirement to collect and process the following data:

Account information:

• Website account
• First name
• Last name
• Affiliate / business name
• Email address
• Country dial code
• Contact number
• MSN
• Skype
• Full address
• City
• Zip code
• Country
• Preferred language

Payment Details:

• Payee name
• Payment method
• Swift code
• Bank name
• Branch address
• Branch Name
• Account number
• ecoPayz ID

Login details:

• Username
• Password
• Confirm password

There are currently a number of cookies installed on the website. Those cookies collect information with regards to the way you use this website. This data is technical data and it does not contain any personally identifiable information. We would recommend that you read the cookie policy to understand what data is collected when you use this website.

The following information give details on the purposes for which your personal data is processed:

• Contact you with regards to the query you have submitted
• Contact you because you have requested a callback name
• Create a partner account with the data that you have submitted on the “Join” section of the website
• Administer your account and troubleshoot any issues
• Issue you commission payments in line with our agreement
• Contact you with regards to our agreements

The data that you have submitted to us will never be sold to third parties, marketing or analytics companies or used for any other purposes than those listed in this section.

Should any of the above purposes change, we will update this section accordingly and indicate the date of the when the update was done in Section 1 of this policy.

When your personal data needs to be transferred to an overseas country that is not part of the EEA (European Economic Area), we will always ensure that there are adequate levels of protection and a similar legislation with regards to data protection. Each country might have different laws and regulations with regards to data protection, however there are some agreements in place, e.g. the privacy shield for the United States of America.

We use the services of various third parties and service providers for our business operations. We have carefully conducted our due diligence to ensure that those third parties are compliant with current applicable data protection legislations and that they have implemented appropriate organisational and technical controls to safeguard your data. Those third parties will only process your data according to our directions that we have provided them as the “data controller”.

We have implemented a number of organisational and technical controls to ensure that the confidentiality, the integrity and the availability of your data is always safeguarded.

Our staff members are aware of the current data protection laws and we ensure that best security practices are always followed. All our systems processing data are protected with antivirus and firewall protection. We have implemented different levels of access for our systems to ensure that access to data is restricted to authorised staff only. All our datasets are regularly backed up to ensure that they are available in the event of a technical issue or disaster recovery. This website has an SSL certificate installed to ensure that network communications are encrypted and to avoid any interception of data.

You have several rights with regards to your personal data under the General Data Protection Regulation. You can submit a “Subject Access Request” if you wish to obtain a copy of all the personal data we hold about you. You can request to have your personal data updated and you can also require to have your data deleted and not be further processed. You can also request to have your personal data transferred to another controller. Please refer to Section 11 of this privacy policy for more information with regards to submitting a Subject Access Request.

You also have all of the following rights:

• The right to rectification
• The right to access (also known as Subject Access Request)
• The right to erasure
• The right to restriction
• The right to object
• The right to lodge a complaint

If you wish to exercise your rights, please contact our data protection officer who will answer your query in due time. If at any point in time you decide to exercise your right to erasure, please note that we might not be able to deliver our services to you to their full extent.

You have the right to ask us to provide you a copy of the personal data we hold about you. Before we are able to answer your request, we must verify certain elements about your request including your identity before any data is transmitted to you. This is necessary to comply with our internal policies and for obvious security related reasons. We will aim to get to answer your request within 30 calendar days.

Please note that we reserve the right to charge a small administrative fee to answer a subject access request for repetitive requests.

We do not knowingly collect any data categorized as “sensitive”, including children data or criminal data. This website and the services we provide are not designed or directed to children. You must be at least 18 years of age to become a partner with Kabuki Partners. In the event that such type of data is accidentally collected, we will ensure that it is securely deleted as soon as we aware of such occurrence.

If you have any questions with regards to this policy, the way your data is processed or if you would like to exercise any of your rights under the General Data Protection Regulation, please contact our Data Protection Officer at [email protected]

You can submit a complaint to the Information Commissioner’s Office if you have any concerns with regards to the way we process your personal data. However, we would prefer that you contact us before doing so.

If you would like to learn more about the General Data Protection Regulation, you can find more information on the following links:

General Data Protection Regulation: https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/