1. ALURA GROUP’S COMMITMENT TO YOUR PRIVACY

We are committed to protecting the privacy of your business and its employees, while providing you and your business with the opportunity to receive products and services that enhance your ebusiness activities and the benefits you receive from the Alura-XL and CEMarking.Net Websites.

This On-Line Privacy Policy (the “Policy”) describes the ways in which we collect information from or about you as part of your use of the Alura-XL website and the CEMarking.Net website, and what we may use this information for. Capitalised terms not defined in this Policy have the meanings given to them in the Terms of Business.

If you have any questions or need further information about our privacy practices, please contact us at info@alura-group.com.

2. WHAT DATA DO WE COLLECT?

We collect data from or about you (“User Data”) in various ways:

· by our use of cookies (see section 3 below);

· during the course of your use of Alura-XL Website and the CEMarking.Net Website (including, without limitation, all material you upload to the Website) (“Your Material”);

· as part of the subscription process by which you have been granted access to the Website; and

· when we request further information from time to time following on from subscription.

Much of this data comprises business information. Some of it will inevitably comprise personal information about individuals, to which the Data Protection Directive 95/46/EC and the respective national regulations implementing the Directive apply. This Policy describes how we fulfil our obligations under those data protection laws in relation to the personal information comprised in the User Data.

3. USE OF COOKIES

We use cookies to identify users when they visit the Website. Cookies also enable us to build up a personalised profile of our users and to develop personalised versions of the Website. For more information about cookies, please see the website www.allaboutcookies.org.

Information generated by the use of cookies is only disclosed to third parties in aggregate form so that no individual can be identified (see also 4(c) below).

4. OUR USE OF USER DATA

We will use the User Data in accordance with the following guidelines:

· To provide the Newchange Documents Product and the Website to you

· We will use User Data to provide and improve the Alura-XL Website and our other ebusiness products (together the “Ebusiness Products”), to invoice you for use of the Ebusiness Products, to enable our help desk to deal with any queries you have about the Ebusiness Products and to notify you of any changes to the Ebusiness Products.

· To send you information about other products & services

· From time to time, we, or third parties acting on our behalf, may wish to send you information about other products and services which we offer and we believe you may be interested in. We may use User Data for this purpose. If you decide that you do not wish to receive this information, please email us at info@alura-group.com.

· To include User Data in anonymous statistics

· We may provide anonymous statistics about our users, sales patterns and related usage information, to reputable third parties, but these statistics will not enable any third party to identify individuals or individual businesses.

· To provide data to third party providers

· We may pass User Data to third party providers of products and services to enable us to provide you with the CEMarking.Net Website. We do not permit those third parties to use your User Data to make their own products or services, or information about them, available to you.

· We may make User Data available to any company, partnership or other entity which directly or indirectly controls, is controlled by, or is under common control with Alura Group to enable them to provide you with information about hold products or services which they believe would be of interest to you. If you decide that you do not wish to receive this information, please email us at han@alura-group.com.

· If Alura Group ceases to trade or goes insolvent

· If we cease to trade, or become insolvent, enter into receivership or any similar or equivalent event occurs, those acting on our behalf may sell the business or parts of it to a third party, in fulfilment of legal or business requirements. In these circumstances, we shall use reasonable endeavours to contact you in advance of disclosing your personal data to that third party, but you acknowledge that this might not be technically or commercially feasible in all the circumstances.

5. TRANSFER OF USER DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (“EEA”)

The Internet is a global environment. We may sometimes need to transfer User Data to locations outside the EEA. By accepting this Policy you hereby consent to such transfers, provided that they are limited to the purposes set out in section 4 above.

6. LEGAL REQUIREMENTS

While it is unlikely, we may be required to disclose your User Data by a court order or to comply with other legal or regulatory requirements. We will use reasonable endeavours to notify you before we do so, unless we are legally restricted from doing so.

7. WE DO NOT SELL OR EXPLOIT USER DATA COMMERCIALLY THROUGH THIRD PARTIES

We will not sell, rent, distribute or otherwise make User Data commercially available to any third party, except as described above, or except with your prior permission.

8. CHANGES TO THE POLICY

This Policy may be amended by us at any time.