Privacy Policy

This Privacy Policy describes the ways we collect, store, use and manage any Personal Data and Anonymous Data (“Information”) you provide to us or we collect in connection with your use of ICOSiren.com website accessible at https://icosiren.com and our other websites on which this Policy appears (the “Site).

BY REGISTERING ON THE SITE AND/OR BY USING THE SITE YOU AGREE TO THIS PRIVACY POLICY and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Site.

  1. Personal Data

    For purposes that will be mentioned further in this Policy we may process and/or collect the following information that can be used to identify you as an individual (“Personal Data”):

    • Email address.

    You may explicitly decline to submit Personal Data through the Site, in which case we will not be able to provide to you our portfolio tracking services, newsletters and other updates via email.

  2. Anonymous Data Collected Automatically

    We collect non-personally identifiable information that alone or in combination with similar information can not be used to identify you (“Anonymous Data”) from your computer, mobile device or browser when you use the Site as a logged in user.The Site automatically collects usage information, such as:

    • Your IP address,
    • The type of device you use,
    • Browser type, version and language,
    • Type and version of your operating system,
    • Your activity on the Site,
    • The number and frequency of visitors to the Site

    We may collect Anonymous Data or use third-party services for that, for example, web analytics services.

    This Anonymous Data is not linked to Personal Data.

  3. Tracking Technologies We Use

    We do not use cookies and other tracking technologies.

  4. Third-Parties Tracking Technologies

    We do not use cookies and other tracking technologies.This Policy does not cover the use of cookies and other similar technologies by third parties. For example, we may use third-party analytic services to collect Information about use of the Site or the Site may contain links leading to other sites.

    We do not control when or how third parties place cookies on your computer. For example, third-party websites to which a link points may set cookies on your computer or analytic services may do the same.

    These cookies or other similar technologies may be used to track your behavior on other websites and we have no control over this.

  5. Why We Collect Information

    The Information is used for:

    • Delivering you the Site and its functionality,
    • Your seamless interaction with the Site,
    • Analytical and statistical purposes,
    • Understanding your interaction with the Site,
    • Improvement and development of the Site or our other services and products,
    • Enforcement of this Policy and the Terms of Use,
    • Sending you related information, including newsletters, special offers, confirmations, updates and security alerts.
  6. How Long We Retain Information

    We will keep your Information for as long as you are a user and, thereafter, for no longer than is reasonably necessary for reporting and reconciliation purposes pursuant to legal requirements.

  7. Your Consent

    You expressly consent to our processing, collection, transfer, storage, disclosure and other uses of your Information as described in this Policy and the Terms of Use at instance when you provide information to us through the Site and/or accept this Policy.In addition, through this use and interactions with the Site you specifically consent to:

    • Our collection of information by automated means and to our subsequent processing and using of information in accordance with this Policy, and
    • The storage and transfer of information to locations wherever we and our service providers have facilities.
  8. Disclosure of Information

    We may release the Information concerning your use of the Site:

    • To provide you with the services and functionality of the Site,
    • In case it is set out in the Terms of Use,
    • When we believe in good faith that such release is appropriate to comply with the applicable law, regulation, legal process or governmental request,
    • To enforce this Policy and/or the Terms of Use, or any agreement between you and us,
    • To detect, prevent, or otherwise address fraud, security or technical issues,
    • To protect against abusive or unlawful use of the Site,
    • To protect the rights, safety, or property of users, or any other third parties,
    • In other ways described in this Policy and the Terms of Use.
  9. With Whom We Share Personal Data

    We may share Personal Data only under any of the circumstances mentioned in this Policy and/or the Terms of Use.We will not share any Personal Data provided by you except with service providers under contract who help with our business operations, such as providers of marketing automation, information management and analytics services and products.

  10. Business or Asset Transfer

    In the event that we, a line of our business, or substantially all our assets are transferred, sold or merged with another business, Information may be one of the transferred assets.

  11. Security of Personal Data

    We will take commercially reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.We process all Information using industry-standard techniques.

    We implement the following administrative, technical, and physical measures for the protection of Personal Data:

    • Administrative measures. Access to your Personal Data is limited to authorized personnel who have a legitimate need to access it based on their job descriptions. In case third-party contractors process Personal Data on our behalf, similar requirements are imposed.
    • Technical measures. Personal Data is transmitted in encrypted format using SSL technology. We use up-to-date firewall protection and high-quality antivirus and anti-malware software.
    • Physical measures. We store Personal Data on our own servers, no third party can have access to this data.

    However, we do not guarantee or warrant that such techniques will prevent unauthorized access to Information, including Personal Data that we store.

  12. Modifications

    We may modify or revise this Policy at any time by posting the amended Policy on the Site. Please check the most current Policy.

  13. Changing or Updating Your Personal Data

    We rely on you to advise us about any changes to your Personal Data.Please contact us as soon as possible if there are any changes to your Personal Data or if you believe the Personal Data we hold about you is not accurate, complete or up-to-date so that we can update our records accordingly.

  14. Privacy Related Inquiries

    If, for any reason, you are concerned with the way that we may be using your Personal Data, you have questions about the privacy aspects of the Site, please, contact us at hello@icosiren.com.

Last updated: June 7, 2018