Privacy Policy – LiberoGroup 2021
1. Introduction
This Privacy Policy governs the manner in which LiberoGroup, which includes Liberoservices/LiberoAssurance/Libero Hellenic Register (“Us” or “We”) collects, uses, maintains and discloses information collected from users (each, a “User”) of the following websites (“Sites”):
https://eshop.liberoservices.org
https://elearning.liberoservices.org.
This privacy policy applies to these Sites ONLY and all products and services are offered online ONLY by LiberoGroup. LiberoGroup adheres to the European Union Safe Harbor principles as set forth by the United States Department of Commerce regarding the collection, use, and retention of personal information from the European Union.
If you have objections to the Privacy Policy, you should not access our Sites. This online privacy policy applies only to information collected through our Sites and also it does not govern privacy practices associated with other offline activities or other LiberoGroup web sites.
LiberoGroup through its Sites aims to help individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information collection and processing.
2. What Is Personal Data
Personal data means any information relating to an identified or identifiable natural person, for instance your contact information, your order data or your product data.
3. Personal Data Collection processing
LiberoGroup collects and uses Users personal information for the following purposes:
- To personalize user experience
We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site. Your information helps us to better respond to your individual needs
- To improve our Site
We continually strive to improve our website offerings based on the information and feedback we receive from you.
- To improve customer service
Your information helps us to more effectively respond to your customer service requests and support needs.
- To process transactions
We process the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service. Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.
- To administer a content, promotion, survey or other Site feature
To send Users information they agreed to receive about topics we think will be of interest to them.
- To send periodic emails
The email address Users provide for order processing, will only be used to send them information and updates pertaining to their order. It may also be used to respond to their inquiries, and/or other requests or questions. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, they may do so by contacting us via our Site.
LiberoGroup collects your information in order to record and support your participation in the activities you select. If you subscribe to a service, for example, the information is used to register your rights, if any, to technical support or other benefits that may be made available to registered users. As another example, if you enter a contest, information is collected to qualify the entry and contact you regarding the contest or prize awards. Your personal information is also used to keep you informed about product upgrades, special offers, and other products and services of LiberoGroup and selected third parties if you have so opted to receive such communications.
4. Personal identification information
As a visitor to our Sites, you are able to engage in many activities without providing any personal information. When you engage with LiberoGroup activities, such as utilizing online shop, training and software applications, LiberoGroup may ask you to provide certain information about yourself by filling out and submitting an online form. Depending on the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. It is completely optional for you to engage in these activities; however, if you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity
If you elect to engage in LiberoGroup activities we collect and process your personal information. The personal data that we collect and the process can be categorized as follows:
- Your details, such as your email address, name, phone number, address, personal ID-number, passport copy, nationality, date of birth, individual webcam images courses during examination (if applicable) and IP address. You may request from LiberoGroup a list of seminars that face recognition (webcam images) applies.
- Your purchase information, such as your details as specified above, company name (if provided), physical address, your order information, such as course name, date of purchase. Your payment information, such as credit card or similar payment information is stored encrypted on our credit card service provider Stripe.
- Your use information, such as your details as specified above, app usage type, date and frequency, log-in credentials, encrypted credentials for third-party services offered in our app(s), for instance, Google and Yahoo.
- Requests for customer support and technical assistance, containing your details, as specified above, which LiberoGroup may inquire to proceed with your request.
- Information provided when completing surveys, questionnaires and feedback forms, such as your details, as specified above, your feedback on your use of LiberoGroup service(s) and evaluation of the same, your location information.
- Your behavior information collected via the use of cookies and similar technologies like pixels, tags and other identifiers to remember your preferences, to understand how our websites and app(s) are used and to customize our marketing offerings.
5. Non-personal identification information
Our website may include an open forum and live chat utilities. We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
6. Data Security / Protection of Information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Our Site covers vulnerability standards in order to create a secure environment for the Users. We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.
Your details and your credit card details, if you have provided such to LiberoGroup remain encrypted on PayPal’s secure web servers. Credit card information is directed to one or more approved and certified service provider(s), and will not be stored for longer than it takes to process the data. All external transmissions of personal data facilitated by LiberoGroup are protected by encryption. After a transaction, your private information (credit cards, social security numbers, financials, etc.) will not be stored on our servers.
The personal information that you provide in connection with registering yourself as a user of LiberoGroup services or registering for a LiberoGroup product is classified as Registration Information. Registration Information is protected in several ways. Access by you to your Registration Information is available through a password and unique customer ID selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone. In addition, your Registration Information resides on a secure server that only selected LiberoGroup can access to. LiberoGroup encrypts your personal information and thereby strives to prevent unauthorized parties from viewing such information when it is transmitted to LiberoGroup.
If you have reason to believe that your interaction with LiberoGroup is no longer secure (for example, if you feel that the security of any account you might have with LiberoGroup has been compromised), please notify us of the problem immediately by contacting us. Please see Contact details section.
Personal information that you provide that does not constitute Registration Information also resides on a secure server and is only accessible to selected LiberoGroup personnel.
Please note that any information you post to a public bulletin board or chat room, such as the LiberoGroup User to User Forums (the “Forums”), is available to all persons accessing that location. Your e-mail address will not automatically be posted on the Forums unless you modify the default setting to permit that. Your e-mail address would then be available to all persons accessing the Forums. In addition, you should be aware that the Forums offers a service in which subscribers are e-mailed a copy of all messages posted to the Forums on a particular topic. Consequently, if you post a message to the Forums your e-mail address will be sent to those subscribers that have indicated an interest in the topic of your message.
7. Retention of Your Personal Data
We keep your information for no longer than necessary for the purposes for which it is collected. The length of time for which we retain information depends on the purposes for which we collect and use it.
Personal data related to your training sessions are kept and processed for five (5) years from the date of last activity.
Personal data related to your use of our apps and product software update(s) is kept and processed for five (5) years from the date you last have been active in using any of LiberoGroup apps.
Personal data related to your use of your LiberoGroup account is kept and processed for a period of five (5) years from the last use day, unless such data is legitimately processed for other purposes, such as providing you with personal benefits or customized direct marketing upon your consent or for pursuing our legal claims, where maintaining such information is considered necessary.
Personal data related to your feedback on our products and services is kept and processed for five (5) years from the completion date of the given survey, questionnaire or feedback form.
Relevant personal information will be deleted after expiry of the above-mentioned periods unless such data legitimately can be kept and processed for other processing purposes, for which we have a legal basis.
8. Entities Collecting Personal Information
Personal information on this Site is collected by LiberoGroup for the reasons described in this policy. This Site (Liberoservices/LiberoAssurance/Libero Hellenic Register) contains links to other sites at which personal information may be collected. In such instances, unless expressly provided to the contrary, the collection and use of your personal information will be governed by the privacy policy applicable to these sites. That privacy policy identifies the entity that your personal information will be collected.
9. Access and Updating Your Personal Information and Privacy Preferences
You have the right to access and correct your personal information and privacy preferences at any time. We encourage you to update your data provided to LiberoGroup any time there are changes in your data.
This can be done at LiberoGroup E-shop/Platform by logging in and changing the relevant fields. You may correct your privacy preferences (such as whether you wish to receive promotional communications from LiberoGroup) by writing or calling or send an email to LiberoGroup at:
Please include your name, address, and/or e-mail address when you contact us. You have to advise LiberoGroup of changes to your address or privacy preferences if you want to receive updates and information for our services.
10. Withdrawal of Consent
Some of LiberoGroup processing activities may be based on your individual consent. In such case, you will have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of processing conducted prior to the withdrawal.
If you withdraw your consent, LiberoGroup and third parties involved in personal data processing will cease to process your personal data, unless and to the extent the continued processing or storage is permitted or required according to the applicable personal data legislation or other applicable laws and regulations. Please note that as a consequence of the withdrawal of your consent, LiberoGroup may not be able to meet your requests, provide certificates and proof of training or provide you with our services. Note that if your data is provided by your employer, we will first contact your employer before proceeding with removing your data.
11. Right to Complaint
LiberoGroup takes its users’ privacy concerns seriously. If you believe that LiberoGroup has not complied with this Online Privacy Policy with respect to your personal information or you have other related inquiries or concerns, you may write, call or email to the LiberoGroup at:
LiberoGroup
Attn: Customer Information
Tel: +30 210 4100535
In your letter, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the LiberoGroup Online Privacy Policy has not been complied with.
We will acknowledge receipt of your complaint within five (5) business days. We will do our best to resolve it as quickly as possible and within one (1) month from the date of the complaint. In case response would require longer term than one (1) month, we will let you know and inform you of the relevant reason(s).
Please note that if you provide LiberoGroup with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), LiberoGroup cannot guarantee that your most recent privacy preference will be honored.
12. Children’s Online Privacy Protection Act Compliance
LiberoGroup does not target and is not intended to attract children and we are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act). Our online services, including personal accounts on websites and apps provided by LiberoGroup that collect any personal data are not directed at and should not be accessed by individuals under the age of 13 years of age.
Minors must obtain express consent from parents or legal guardians before accessing or providing any personal data. If notified by a parent or guardian or discovered by other means, that a child under age of thirteen has submitted his or her data to LiberoGroup, we will cancel the child’s account, if any, and delete the child’s data in our possession.
13. Web browser cookies
By visiting out the Site, you are able to access important information without revealing your identity. In order to improve our Sites, we may use “‘cookies” to track your visit and enhance User’s experience. A cookie is small amount of data that is transferred to your browser by a Web server, enables the sites or service providers systems to recognize your browser and capture and remember certain information and it can only be read by the server that gave it to you. It functions as your identification card, and enables us to record your preferences. It cannot be executed as code or deliver viruses.
Cookies are used to help us remember and process the items (eg in your shopping cart), understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.
Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. (For some Web pages that require an authorization, cookies are not optional. Users choosing not to accept cookies will probably not be able to access those pages.)
While LiberoGroup uses cookies to track your visit to LiberoGroup, and our Web servers automatically log the IP/Internet address of your computer, LiberoGroup does not generally use this information to identify you personally. However, if you expressly provide consent for LiberoGroup to “remember” the unique identifier that you select when you register for various activities on this Site, that unique identifier will be stored on a cookie on your computer, linked to your registration information, and your navigation path around the Sites will be tracked. We associate this data to understand how our Sites and services are being used so we can understand our customers and offer appropriate services.
14. Sharing personal information
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
LiberoGroup recognizes and appreciates the importance of responsible use of information collected. Without your consent, LiberoGroup will not communicate any information to you regarding products, services and special offers available from LiberoGroup, although we may find it necessary to communicate with you regarding your use of the services on these Sites. Except in the particular circumstances described in this Privacy Policy, LiberoGroup will also not provide your name to other companies or organizations without your consent.
There are other instances in which LiberoGroup may divulge your personal information. LiberoGroup may provide your personal information, if necessary, in LiberoGroup.’s good faith judgment, to comply with laws or regulations of a governmental or regulatory body or in response to a valid subpoena, warrant or order or to protect the rights of LiberoGroup or others.
15. Third party Websites, Plug-Ins and Services
LiberoGroup has established relationships with various service providers whose services are available to you from these Sites or from web sites that are linked to these Sites. Typically, these providers offer services that LiberoGroup customers might find useful, such as those that can be used in conjunction with LiberoGroup services and products. In order to use those services, you may be required to provide personal information to the providers. Unless expressly provided to the contrary, personal information that you provide while you are visiting a provider’s web site will be subject to the privacy policy posted on such site and personal information that you provide while on these Sites in conjunction with a provider’s service will be subject to this Privacy Policy. You should be aware that our agreements, with these service providers often provide that they will share with LiberoGroup personal information collected from you. In such instances, LiberoGroup may use this information in a manner consistent with this Privacy Policy. In the situation where sites have a LiberoGroup “look and feel,” and you reasonably believe you are on a LiberoGroup site, the site is collecting information in a solely intermediary capacity and does not use personal information for secondary purposes.
When you use these Sites, LiberoGroup or third parties authorized by LiberoGroup may also collect certain technical and routing information about your computer to facilitate your use of these Sites and its services. For example, we may log environmental variables, such as browser type, operating system, CPU speed, and the Internet Protocol (“IP”) address of your computer. We use these environmental variables to facilitate and track your use of these Sites and its services. LiberoGroup also uses such environmental variables to measure traffic patterns on these Sites. Without expressly informing you in each particular circumstance, we do not match such information with any of your personal information.
When ordering services from LiberoGroup you will be transferred to other secure sites (like bank sites, pay pal etc.). Using these Sites, you may be asked to provide a credit card number and details for the payment. When you submit personal information to LiberoGroup through these, other than LiberoGroup, Sites, you understand and agree that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which LiberoGroup and its affiliates and subsidiaries maintain offices, including without limitation, the United States. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage and processing of your information may be undertaken by trusted vendors. Such vendors are bound by contract to not use your personal information for their own purposes or provide it to any third parties. One instance where this could occur is in conjunction with framed pages in which the URL for the pages is not visible and the pages are being hosted by a vendor of LiberoGroup.
In order to reduce errors in our database, authenticate our users and prevent abuse of our system we may on occasion supplement the personal information you submit to us with information from third party sources. For example, we may supplement your registration information with address information provided by the U.S. Postal Service or similar agent, to verify/qualify your information and prevent errors in our database.
Personal identification information will be collected from the users only if they voluntarily submit such information to us. Users can always refuse to supply personal identification information; however, as mentioned above, this may prevent them from engaging in certain Site related activities.
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies. Please note that LiberoGroup is not responsible for the content or privacy practices of non-LiberoGroup Web sites to which these sites or any other LiberoGroup Web site may link. You should review the privacy policy of such sites before using the sites.
16. Disclose information to outside parties – Advertising
As mentioned, we do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, as long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Also, we may share your data with the following third parties:
- Our company and authorized LiberoGroup consultants to deliver service and support to you, to enhance our service and your customer experience.
- Third party vendors carrying out services on our behalf, including billing, sales, marketing, IT support, advertising, analytics, research, customer service, service support, shipping and purchase order fulfillment, data storage, validation, security, fraud prevention, payment processing, and legal services. Such third-party vendors have access to perform these services but are prohibited from using your data for other purposes.
- Third parties to establish, exercise or defend legal rights of LiberoGroup.
- Third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of LiberoGroup’s assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
- Other third parties subject to your consent.
Ads appearing on our site may be delivered to Users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile non personal identification information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This privacy policy does not cover the use of cookies by any advertisers.
17. Google AdSense
Some of the ads may be served by Google. Google’s use of the DART cookie enables it to serve ads to Users based on their visit to our Site and other sites on the Internet. DART uses “non personally identifiable information” and does NOT track personal information about you, such as your name, email address, physical address, etc. You may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy at http://www.google.com/privacy_ads.html
18. Changes to our privacy policy
LiberoGroup has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. If we decide to change our privacy policy, we will post those changes on this page. LiberoGroup may modify or update this Privacy Policy when necessary to reflect changes in LiberoGroup products and services, changes in applicable legislation, regulations or practice and to address customer feedback.
All “personal information” (“personal information” is defined as any information that identifies or can be used to identify, contact or locate the person to whom such information pertains) that we collect and maintain will be subject to the version of the Privacy Policy in effect at the time of such collection.
We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.
If as the result of such changes, you want to alter the ways in which LiberoGroup is allowed to use your personal information, you can do so by following the procedure described in this policy in the section entitled “Updating your Personal Information and Privacy Preferences. You will be deemed to have been made aware of, and will be subject to, the changes to the Privacy Policy by your continued use of the Sites after such notice has been posted for thirty (30) days with the following exception: if at the time you provide personal information to LiberoGroup you are given the opportunity (as you currently are) to limit how such information will be used to communicate with you, either by LiberoGroup or by third parties, LiberoGroup will not change your preference in this regard without your expressed consent.
However, if LiberoGroup sells assets (or the assets of a division or subsidiary) to another entity, or LiberoGroup (or a division or subsidiary) is acquired by or merged with, another entity, LiberoGroup may provide to such entity customer information that is related to that part of our business that was sold to or merged with the other entity without your consent.
19. Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website.
20. Contact Details
If you have any queries about this Privacy Policy, the practices of this site, the processing of your data or your dealings with this site, please contact us at:
LiberoGroup
Attn: Customer Information
Tel: +30 210 4100535