Last updated: April 27th, 2020.
Marmara Group (“Marmara Group”, ‘’our’’ or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding how we handle and protect your personal information in relation to Marmara Group’s business activities, customer services, and on websites, and communications that post a link to this Privacy Policy (collectively, “the Sites”), in our capacity as data controllers.
Sections
Information We Collect
Marmara Group collects personal information in the course of its business activities, including in connection with customer services. The personal information collected varies and may include, but is not limited to, your name, last name, mailing address, e-mail address, telephone number, fax number, and background information required to receive our services.
We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with a unique identifier as well as with any other personal information you have provided.
Marmara Group may also collect personal information about you from third parties, in the course of its business activities including in connection with some customer services. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities (e.g., analysis of recruiting practices across an industry, detecting fraud patterns in connection with financial transactions, foot traffic in retail environments). We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like Marmara Group, in compliance with applicable law.
Use of Information
Marmara Group uses your personal information and Non-identifying information to better serve you with personalize content that you view or receive on the Sites. Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Marmara Group customers to attempt to provide you with a better experience, to improve the quality and value of the Marmara Group Services and to analyze and understand how our Site and Marmara Group is being used.
In some situations, the collection of personal data may be required for the operation of the Sites, or we may use it in the course of our business activities, including in connection with some customer services, for example, to provide certain services or products such as our benchmarking products. We may combine and/or analyze personal information to evaluate and offer content and services most relevant to you. We may keep any of your personal information on file and use it to contact you.
Marmara Group and its service providers may use first and third party Cookies and Other Tracking Technologies, including web beacons, to manage our Sites and our services and collect analytics about how you use them. Marmara Group and its service providers may collect information about whether you open or click any links in the knowledge, research or event communications that we send to you. The information provided throughout this Privacy Policy about cookies also applies to these other tracking technologies. Please refer to our Cookie Policy for more details regarding our use of Cookies and Other Tracking Technologies.
Our Sites do not track you by collecting personal information about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.
We may receive information about you from other sources, including through third-party services and organizations, to supplement information provided by you. As used in this policy, the term “Third Party” is any company, natural or legal person, public authority, agency, or body other than you and Marmara Group.
Purposes and Legal Basis for Data Processing
We process your personal data for the purposes mentioned above is based:
- in part, on our legitimate interests in promoting and protecting Marmara Group, building and maintaining relationships and providing our services;
- in part, on your consent, for example if you create a customer account, or to request our business services that support web operations such as understanding and enhancing the quality of your experience on our web-sites;
- in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.
Data Recipients and International Data Transfers
Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your information collected through the Site may be stored and Processed in China or any other country in which Marmara Group maintains facilities.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Marmara Group will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows. Marmara Group may provide access to your personal data to third party service providers engaged by Marmara Group to provide services related to the Sites as well as related to Marmara Group’s business activities, including in connection with some customer services, in the manner agreed upon in our customer services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.
We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, developing technological materials, improvement of Marmara Group’s services, or communicating with you.
In addition, we may disclose information about you:
- If we are required to do so by law or legal process;
- To law enforcement authorities or other government officials;
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
- If disclosure is necessary to protect the vital interests of a person;
- To protect our property, services and legal rights;
- To prevent fraud against Marmara Group, our subsidiaries, affiliates and/or business partners;
- To support auditing, compliance, and corporate governance functions; or
- To comply with any and all applicable laws.
In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
Personal Data Made Available to Public
You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. Marmara Group is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.
Link to Third Party Sites
Marmara Group may provide links to third party websites or information as a service to our customers. If you use these links, you will leave the Sites. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by Marmara Group of the third party, the third party website, or the information contained therein, and Marmara Group shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.
Security
Marmara Group has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized Marmara Group personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, Marmara Group cannot guarantee that unauthorized persons will not obtain access to your personal data.
Data Retention
Marmara Group retains personal data, as necessary, for the duration of the relevant business relationship.
We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, Marmara Group will make reasonable attempts to delete all instances of the information in their entirety.
For requests for access, corrections, or deletion to your personal information please send an email to info@marmaragroup.cn
Children
The Sites are not designed for or directed at children 16 years of age or younger, and Marmara Group does not intentionally collect or maintain personal information about anyone under this age.
Your rights
Where granted by applicable law, you may have the right to request access to the personal information that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal information that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal information.
If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at info@marmaragroup.cn
To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal information. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal information or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.
In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.
Consent; Changes to Privacy Policy
By using the Sites, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Sites.
Social Networking
The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, with Marmara Group.
By associating your social network account with Marmara Group, you give us permission to access information that you have made available in your public profile for that social network account. The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location. We use the information we receive from your social network account in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with Marmara Group and other connected applications and to manage the data that is shared through your account, including information about your activities using our Sites.