Privacy Policy
Website Privacy Policy
AOL International, is committed to protecting the online privacy of all website users. As, mainly this Privacy Policy has been written to allow you understand AOL’s policy regarding your privacy, beside the way we handle your personal information when using the Website. This Privacy Policy also provides you with extra information to enable you to consent to the processing of your personal information and data in an explicit, informed manner, and where Suitable. Generally, any data information you provide to AOL over the Website, or which is gathered through the Website, in the context of the use of AOL’s services, will be processed by AOL in a transparent, fair lawful manner. To this end, and as more described below, AOL takes into consideration internationally recognized principles governing the processing of personal data, such as storage limitation, purpose limitation, data quality , data minimization and confidentiality.
1. Personal Data processed
On using the Website, AOL will process and collect information regarding you (as an individual) which allows you to be identified either together or by itself with other information which has been collected. AOL can also collect and process information regarding other persons in this same manner, if you decided to choose to provide it to AOL. This information can be arranged as “Personal Data”, and can be collected by AOL both when you choose to provide it (e.g., on signing up for an account, to receive AOL’s Services) or simply by analyzing your behavior on the Website. Personal Data that can be processed by AOL via the Website are as follows: a. Name, contact details and other Personal Data In different sections of the Website – including, in particular, in case you decide to create an account on the Website – you will be asked to submit some pieces of information such as your name, mobile / phone numbers, gender, e-mail address, date of birth, addresses and country of residence, as well as, in some cases, information related to your position the company you currently work for. When signing up or subscribing to receive Services, you will need to provide information as to your better payment mode – PayPal or credit card – that can be set as a default payment option (where available). b. Beside, whenever you participate in promotions and other surveys or even contests that may be available on the Website, also whenever you communicate with AOL by telephone with customer service or via the contact details provided in the Website, AOL may collect more information which you choose to provide. As well as this is the case regarding any information you choose to disclose in certain sections of the Website which allow you to participate contact AOL directly or participate in a public forum. c. Job applications When you register applying for a position within AOL, in the “Careers” section of the Website (where available), Also you will be asked to add various types of Personal Data, like professional / employment details (resume, cover letter, availability to start, professional qualifications, professional social media URLs, etc.). As well as You will be asked to provide other job-specific information, which includes your gender , date of birth, and marital status, which probably help to provide more insight into you as a candidate – although, this is actually optional and not mandatory (unless otherwise provided by the applicable law). c. Special categories of Personal Data Some areas of the Website include free text fields to be able to write messages to AOL, or otherwise allow you to post on the website different types of content, which may include Personal Data. Where these fields are totally free, you are able to use them to disclose, or may post content that discloses (inadvertently or not) more sensitive categories of Personal Data, ex: data revealing your racial or political opinions, ethnic origin, philosophical or religious beliefs, or trade union membership. In these fields the content you upload may also (inadvertently or not) include other types of sensitive information touching you, as your biometric data ,genetic data, or data concerning your health, sexual orientation or sex life. In your posts on the Website or in these free text fields, AOL asks that you do not show any sensitive Personal Data, unless you consider this to be a must. If happened, then you will be counted as having consented to AOL processing of this Personal Data, which means being rightful and lawful also due to the fact of having publicly disclosed it on the Website. Accordingly, AOL should stress the importance of providing your explicit consent in order to process this sort of Personal Data ( by declaring that you consent to processing in the message you write in the free text posts or fields), if you decide, nevertheless, to share it. On registering to apply for a position within AOL, in the “Careers” section of the Website (where available), you are also optionally asked to submit more Personal Data. By this, you can decide to share information, e.g., regarding any disabilities you may have. As it is completely optional to give this information, if you do, then you will be considered as having consented to AOL’s processing of this Personal Data that will be considered lawful also because of the fact that you have publicly disclosed it on the Website. d. Other persons’ Personal Data In the previous section, we mentioned specific areas of the Website include free text fields where you can write us messages, or allow you to post different types of content on the Website. Both messages and content may (inadvertently or not) include Personal Data associated to other persons. You are asked in other sections of the Website to submit Personal Data related to third parties, as your relatives who are employees of AOL or other contact persons in your company. You will be considered as an independent data controller if you decide to share Personal Data related to other persons regarding that Personal Data, and must assume all inherent legal responsibilities and obligations. Meaning, among other things, that you must fully indemnify AOL against any claims, complaints or demands for damages for compensation which may arise from this Personal Data processing brought by the third parties whose information you provide via the Website. As AOL does not bring this information directly from these third parties (but rather collects them, indirectly, from you), before providing any information you must make sure that you have these third parties’ consent regarding them to AOL; if not, then you must make sure there is some other suitable grounds on which you can rely to lawfully provide AOL this information. e. Browsing data The operation of the Website as is standard with any websites on the Internet, involves the use of software procedures and computer systems, which collect website’s users’ information as part of their routine operation. While AOL does not collect this information to link it to certain users, it is still possible to identify those users either by using other information collected – as such, this information must also be considered Personal Data. Or directly via that information This information includes many parameters related to you IT environment and operating system including your IP address, the domain names of your computer, location (country), the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the method used to submit requests to the server, the time of requests made, the numerical code indicating the status of the response sent by the server (successful, error, etc., the dimensions of the file obtained in response to a request, and so on. These data are used to ensure its correct operation and identify any faults and/or abuse of the Website, as well as to compile statistical information on the use of the Website. f. Cookies - Definitions, characteristics, and application of standards By the websites you visit, Cookies are small text files that may be registered and sent to on your computer, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your preferences and actions (e.g., login data, font size, language, other display settings, etc.), so that you do not need to reconfigure them when you change pages within a website, or when you next visit the website. Cookies are used for monitoring of sessions, electronic authentication and information storage regarding your activities when accessing a website. They may also contain a unique ID code which allows browsing tracking of your activities within a website, for advertising or statistical purposes. Within a website some operations may not be able to be performed without cookies use which, in certain cases, is technically necessary for the website operation. You may also receive cookies from websites or web servers When browsing a website other than the website being visited (i.e., “third-party cookies”). There are different types of cookies, depending on their functions and characteristics, which can be stored on your computer for different time periods: “session cookies”, that are deleted automatically when you close your browser, and “persistent cookies”, which will remain on your device till their pre-set expiration period passes. According to the law that can be applicable to you, your consent can not always be necessary for cookies to be used on a website. Specially, “technical cookies” – i.e. cookies that are needed to provide services you request or only used to send messages via an electronic communications network, – typically do not require this consent. This includes browsing or function cookies (used to remember choices made by a user on accessing the website, such as products selected for purchase or language).and session cookies (used to allow users to login). On the other hand, “profiling cookies” – i.e., cookies used to profiles creation on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require certain consent from users, however this can vary according to the applicable law. Cookies types used by the Website The following types of cookies used by the website: • Browsing or session cookies, which are strictly necessary for the operation of the Website, and/or to allow you to use the Website’s services and content. • Analytics cookies, which enables AOL to track traffic to and from the Website, and to understand how users make use of the Website. • Function cookies, which are used to configure the Website according to your choices (e.g., language), in order to improve your experience and to activate specific Website functions • Profiling cookies, which are used to send you advertising messages in line with those preferences and to observe the preferences you reveal through your use of the Website. AOL also uses third-party cookies – i.e. cookies from websites / web servers other than the Website, owned by third parties. These third parties will either act as data processors for AOL (processing personal data on AOL’s behalf) or independent data controllers from AOL regarding their own cookies (using the data they collect for their own purposes and under terms defined by them) For further information on how these third parties may use your information, please refer to their privacy policies - Cookie settings You can delete or block cookies used on the Website through your browser options. Your preferences of cookie will be reset in case different browsers are used to access the Website. For more information on how to set cookies’ preferences via your browser, please refer to the following instructions: • Internet Explorer • Firefox • Chrome • Safari • CAUTION: If you delete or block technical and/or function cookies used by the Website, the Website can become impossible to browse, certain website functions or services may become unavailable or other malfunctions may happen. In this case, you may have to manually enter some information or preferences every time you visit the Website or to modify. • On the Website AOL uses Google Analytics. This is a tool developed by Google and used to collect information, which permits analysis of your behavior and improvement of your experience with the Website, evaluation of the use of the Website. You can obtain more information about how to opt out of Google Analytics at: https://tools.google.com/dlpage/gaoptout.
2. Purposes of processing
AOL intends to use your Personal Data, collected via the Website, for the following reasons: • To assist and verify your identity, in case you forget or lose your login / password details for any registration of AOL’s services, in order to allow you to participate in the Website’s discussions and forums by maintaining a registered user profile, as well as registering your participation and managing and to provide any other Services that you may request (“Service Provision”); • To examine resumes of applicants / CVs and to get in contact with applicants who have submitted their application through the Website (“Recruitment”); • For marketing in the future, publicity and promotional purposes, including to allow participation in promotions and contests available through the Website, as well as to carry out direct marketing, market surveys and research , via e-mail, SMS, push notifications, over the phone, through an operator, through AOL’s official social media pages (“Marketing”); • As a Website user to create a profile of you, through the use of profiling cookies and by analyzing and collecting information on your preferences selection and your general activities on the Website, as well as choices you make in the Website. This profile can be used to give you information about other websites / services which AOL believes you probably may be interested in, and to show you advertisements and information which may be relevant your interests and to you. In this processing all algorithms involved are regularly tested, to ensure control for bias and the processing’s fairness. (“Profiling”); • For compliance with laws which impose upon AOL the collection and/or further processing of specific kinds of Personal Data (“Compliance”); • For administration and development of the Website, in particular by use of data analytics regarding how both you and other users use the Website, also the feedback and the information you provide, to improve our offerings (“Analytics”); • To detect and prevent any misuse of the Website, or any fraudulent activities carried out via the Website (“Misuse/Fraud”).
3. Grounds for processing and mandatory / discretionary nature of processing
AOL’s legal bases how to process your Personal Data, according to the purposes identified, are as follows: • Service Provision: for processing to these purposes is a necessary to offer the Services and, therefore, is necessary for a contact performance with you. It is not mandatory for you to provide AOL your Personal Data for these purposes; however, if you do not, AOL will not be able to provide you any Services. • Recruitment: processing for this purpose is needed for AOL to consider offering you a position and, therefore, is important to take steps at your request before (potentially) entering into an employment contract. It is not compulsory for you to provide AOL your Personal Data for these purposes; although, if you do not, AOL will not be able to consider your candidacies. • Marketing: processing for these purposes is based on your consent. It is not required for you to provide consent to AOL for use of your Personal Data for these purposes, and no consequence will be suffered by you if you choose not to (aside from not being able to receive more marketing communications from AOL). • Profiling: processing for this purpose is based on your consent, if you accept the use of profiling cookies. It is not required for you to provide consent to AOL for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (apart from not being able to benefit from greater personalization of your user experience the Website). • Compliance: processing for this purpose for AOL is necessary to comply with its legal obligations. When you give AOL any Personal Data, AOL must process it togetherness with the laws applicable to it, which can include reporting and retaining your Personal Data to official authorities for compliance with tax, customs or other legal obligations. • Analytics: Information collected for this purpose is used to allow AOL to improve the Website accordingly, with the aim to providing a better user experience and to understand how users interact with the Website. • Misuse/Fraud: Information collected for this purpose is used exclusively to detect and prevent fraudulent activities or misuse of the Website (for potentially criminal purposes).
4. Recipients of Personal Data
Your Personal Data may be shared with the following list of entities/ persons (“Recipients”): • Persons, professional firms or companies providing AOL with consultancy and advice regarding accounting, legal, administrative, , financial, tax and debt collection matters related to the provision of the Services; • Entities engaged to provide the Services (e.g., e-mail platform providers or hosting providers); • Entities engaged as data processors, in order to carry out processing activities related to Marketing on AOL’s behalf, where you have consented to processing of your Personal Data for these purposes (e.g., SMS engines); • Persons authorized to perform technical maintenance (including maintenance of electronic communications networks and network equipment); • Persons authorized by AOL in order to process Personal Data needed to carry out activities directly related to the provision of the Services, who are subject to an appropriate legal obligation of confidentiality (e.g., employees of AOL);or have undertaken an obligation of confidentiality and • Public entities, authorities or bodies to whom your Personal Data may be disclosed, in accordance with the binding orders of those entities, authorities or bodies; or the applicable law.
5. Transfer of Personal Data
Considering AOL’s worldwide business operations and presence, your Personal Data may be transferred to Recipients located in various countries. AOL implements appropriate safeguards to ensure the security and lawfulness of these Personal Data transfers, as by relying on adequacy decisions from the European Commission, also standard data protection clauses followed by the European Commission, or other conditions or safeguards considered adequate to the transfer at hand.
6. Retention of Personal Data
Personal Data processed for Service Provision will be kept by AOL for the period deemed hardly needed to achieve such purposes – in any case, as these Personal Data are processed for the Services provision, AOL may continue to store this Personal Data for a longer period, as may be necessary to protect AOL’s interests related to potential liability related to Services provision. Personal Data processed for Recruitment will be kept by AOL till the vacancy for which the CV was submitted is still available or, in case of open positions, for up to 1 year. AOL may contact applicants before the expiration of this period to request retention period extension. Personal Data processed for Marketing and Profiling will be kept by AOL from the moment you agreed till the moment you withdraw the consent given. Once consent is withdrawn, Personal Data will be no more used for these purposes, however it may still be kept by AOL, especially as may be necessary to protect AOL’s interests connected to potential liability related to this processing. Personal Data processed for Compliance will be kept by AOL for the period required by the applicable law or by specific legal obligation. Personal Data processed for Misuse/Fraud and Analytics will be kept by AOL as long as considered strictly necessary to achieve the purposes for which it was collected, except you validly object to the processing of your Personal Data for these purposes
7. Data subjects’ rights
Under the Regulation, you, as a data subject, are entitled to exercise these rights before AOL, at any time: • Access your Personal Data being processed by AOL (and/or a copy of that Personal Data), also the information on the processing of your Personal Data; • Update or correct your Personal Data processed by AOL, where it may be incomplete or inaccurate; • Request erasure of your Personal Data being processed by AOL, where you feel that the processing is unlawful or otherwise unnecessary; • Request the restriction of the processing your Personal Data, where you feel that the processed Personal Data is unnecessary, inaccurate or unlawfully processed, or where you have objected to the processing; • Exercise your right to portability: the right to receive a copy of your Personal Data provided to AOL, in a commonly , structured used and machine-readable format, beside the transmission of that Personal Data to other data controller; • Object to the processing of your Personal Data, based on appropriate grounds related to your unique situation, which you believe must prevent AOL from processing your Personal Data; or • Withdraw your consent to processing (for Profiling and Marketing). • Please note that, as a data subject, for the protection of Personal Data you are entitled to file a complaint with the competent supervisory authorities, if you believe that the processing of your Personal Data carried out via the Website is unlawful.
8. Amendments
This Privacy Policy entered into force on March 27, 2019. AOL has total right to fully or partly amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. AOL will inform you of such changes when they are introduced, and they will be binding as soon as they are published on the Website. Therefore, AOL invites you to regularly visit this Privacy Policy in to acquaint yourself with the updated, latest version of the Privacy Policy, so you may remain constantly informed on how AOL uses and collects Personal Data.