SIRTEMED LTD (hereinafter “we”, “us” or “our”) operates the websites adoreo.com and is the controller of the information collected or provided via the Websites.
If you have any questions about our privacy practices, please see “Contact Information” below for information on how to contact us.
your email communications with the Websites
The Data We Collect About You
We may collect different kinds of personal data about you, depending on whether you chose to create an account with us.
Persons who visit the Websites without logging in or registering (“unregistered users”):
Contact Information: We collect email address or any other information which you voluntarily provide to us at your direction for a specific function, for example a contest or survey.
Website activity data: We collect information about how you use our Websites, products and services and interact with our content and advertisements, including the pages you visit in our Websites, search history, and the referring web page from which you arrived at our Websites. We collect browser and operating system information, devices you use to access the Websites and your time zone setting. We also collect online identifiers. Specifically, we collect internet protocol (IP) address information and we set cookies as explained below in the section on Cookies and Automatic Data Collection Technologies
Persons who choose to create an account on adoreo.com (“registered users”).
We collect from registered users the same categories of information described above for unregistered users.
Contact Information: We collect username or similar identifier, and email address. We also collect details about payments to and from you and details of products and services you have purchased or received from us.
User Submitted Personal Information: We collect information you submit in order to personalize your account or for a specific function, for example date of birth, age, gender, your interests, preferences, feedback, survey responses, your preferences in receiving marketing from us and our third parties, and your communication preferences, as well as any other information which you voluntarily provide to us at your direction for a specific function.
User Contributions including Audio/Video Information: We provide areas on our Websites where you can post information about yourself and others, communicate with others, upload content (e.g., pictures, video files, etc.), and post comments. Please use caution in providing user contributions. By providing user contributions you are making that content and information publicly available.
We may use your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.
Our Websites are not directed to persons under the age of 18 or the applicable age of majority in the jurisdiction from which the Websites are accessed (“minors”), and we prohibit minors from using the Websites. We do not knowingly collect personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, then please contact us at [email protected] to have that minor’s personal information deleted.
The Sources from Which We Collect Personal Information
We collect Personal Information in the following ways:
Directly from you: We collect the categories of information listed above directly from you.
Automated technologies or interactions. As explained in the section below on Cookies and Automatic Data Collection Technologies, we set cookies and other automatic techniques to collect website activity data when you visit the Websites or other websites owned by our corporate group.
Purposes for Which We Use Your Personal Information
We use personal information for the purposes described below.
Provision of services: We use identifiers, website activity data, and, additionally, for registered users, contact information, and payment and commercial information and user contributions to present our Websites and their contents to you, including any interactive features on our Websites, to provide you with information, products or services that you request from us, and to verify your eligibility and deliver prizes in connection with contests and sweepstakes.
Customer management: We use identifiers and contact information, and payment and commercial information to manage a registered users’ account, to provide customer support and notices to the registered user about his account or subscription, including expiration and renewal notices, and notices about changes to our Websites or any products or services we offer or provide through them.
Customization of content and marketing (Unregistered Users and Registered Users Only): We use identifiers and contact information, website activity data, user submitted personal information and user contributions to analyze your use of, or interest in, our Websites’ content, products, or services, in order to develop and display content and advertising tailored to your interests on our Websites.
Analytics: We use identifiers and website activity data to determine whether users of our Websites are unique, or whether the same user is using the Websites on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns.
Functionality and security: We may use any of the categories of data we collect to diagnose or fix technology problems, to verify your payment information, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
Compliance: We may use any of the categories of data we collect to enforce our terms and conditions and to comply with our legal obligations.
Our Legal Bases Under EU Law
We have the following legal bases under EU law for processing your personal data for the purposes described under Section Purposes for Which We Use Your Personal Information:
We process personal data for the purposes of providing the services, customer management, certain customization of content (e.g., based on your selected preferences, favorites and ratings), and functionality and security because the processing is necessary for the performance of a contract, specifically it is necessary to provide the services or products you have requested, or to provide our Websites and services in a manner consistent with our terms and conditions and any other contract that you have with us.
We process personal data for the purposes of customization of advertising, marketing and analytics for our legitimate interests.
We process personal data for functionality and security because it is necessary for our legitimate interests, and in certain cases because the processing is necessary for us to comply with a legal or regulatory obligation.
We process personal information in specific circumstances where you have provided your consent to such processing.
Disclosure of Your Personal Information
We disclose personal information:
To the public: When you submit user contributions including audio/video content, you are using our Websites and services to make that information public.
Within our corporate group: We may disclose any of the categories of personal information to members of our corporate group (including affiliates and related entities) to the extent this is necessary for our purposes listed in the sections above.
Service providers: We disclose the categories of personal information we collect to our authorized service providers that perform certain services on our behalf. These services may include payment processing and fulfilling orders, risk and fraud detection and mitigation, customer service, marketing and advertising, customization of content, analytics, security, or hosting our Websites or supporting our Websites’ functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
Legal successors: We may disclose all of the categories of personal information we collect to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.
Cookies and Automatic Data Collection Technologies
As you navigate through and interact with our Websites, we use automatic data collection technologies to collect website activity data.
We currently use the following types of cookies, which are set by the Websites’ domains, or by other domains we own or control:
Strictly necessary cookies: These are cookies that are required for the operation of our Websites. These include, for example, cookies that enable a user to log in to our Websites and to check if a user is allowed access to a particular service or content.
Functionality cookies: These cookies help us to personalize and enhance your online experience on our Websites. This type of cookies allows us to recognize you when you return to our Websites and to remember, for example, your choice of language.
Analytics cookies: These cookies allow us to recognize and count the number of users and to see how users use and explore our Websites. These cookies help us to improve our Websites, for example by ensuring that all users are able to find what they are looking for easily.
Targeting and Advertising cookies: These cookies record visits of a user on our Websites, the pages a user visits and the links a user follows in order to enable us to make our Websites more relevant to the user’s interests and to help us serve ads that might be of interest to the user. Targeting and advertising cookies are only used for unregistered users and registered users.
Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires or you delete your cookies.
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use the Websites, including by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only for the purpose of providing Google Analytics services to us, and will not use this information for other purposes. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU. You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page.
You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
Your Rights Related to Your Personal Information
You have certain rights regarding the personal information we collect, use or disclose and that is related to you, including the right:
to receive information on the personal information we hold about you and how such personal information is used (right to access);
to correct inaccurate personal information concerning you (right to data rectification);
to delete/erase your personal information (right to deletion, “right to be forgotten”);
to receive the personal information provided by you in a structured, commonly used and machine-readable format and to transmit the personal information to another data controller (right to data portability)
to object to the use of your personal information where such use is based on our legitimate interests or on public interests (right to object);
in some cases, to restrict our use of your personal information (right to restriction of processing); and
to withdraw your consent at any time where our processing is based
You may exercise your right to access and deletion using the buttons at the bottom of this page. Additionally, you may, at any time, send us an e-mail at [email protected] to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area or the UK, you have a right to lodge a complaint with your local data protection authority.
Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be in a position to respond to your request. Additionally, in some cases in order to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.
Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the use of certain personal information (e.g., your e-mail address).
Transfers of Your Personal Information to Other Countries
Where the laws of your country allow you to do so, by using the Websites you consent to the transfer of information that we collect about you, including personal information, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer personal information to countries outside of the European Economic Area (“EEA”) or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws. Where relevant, our transfers outside the EEA are made pursuant to standard contractual clauses approved for use by the European Union.
Retention of Personal Information
We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider a number of factors, including what personal data we are processing, the risk of harm from any unauthorised disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.
Where permissible, we will also delete your personal information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.
Jurisdiction and choice of Law
The material and all other content in and on this Site are presented solely for the purpose of providing entertainment and information.
You agree that the Services shall be deemed solely based in Cyprus and the Services shall be deemed a passive website that does not give rise to personal jurisdiction over the Site, either specific or general, in jurisdictions other than Cyprus.
In the event that You or the Site commences any claims, actions, formal legal action, or arbitration to interpret and/or enforce any of the terms and conditions of this agreement, or relating in any way to this Agreement. Including without limitation asserted breaches of representations and warranties, the prevailing party in any such action or proceeding shall be entitled to recover, in addition to all other available reliefs its reasonable attorneys' fees and costs incurred in connection therewith, including attorneys' fees incurred on appeal.
We make no representation(s) of any kind whatsoever that the Site or any of the material located on the Site are appropriate or available for use in other locations, and access to them from territories where their subject matter may be illegal or is otherwise prohibited. Those who choose to access the Site from any such location(s), do so at their own risk shall be solely responsible for compliance with all applicable local laws and regulations.
Third-Party Links and Sites
Our Data Protection Officer can be contacted at the following email address: [email protected]