If you visit POYATU's web-site, your web-browser automatically discloses, and POYATU's web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.
Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.
Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in'cookies' and submits them each time you request a web-page within a particular domain (such as POYATU.com). This data may or may not be sufficient to identify you.
If you disclose personal data to POYATU in conjunction with an identifier such as your name or your contact details (such as your e-mail address), POYATU will collect Your Data. Moreover, any data that becomes available to POYATU through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data.Subject to the qualifications immediately below, POYATU undertakes to collect Your Data from you and not from other parties.
This undertaking is qualified as follows:
- Where POYATU reasonably considers that the protection of its financial interests requires that it gather Your Data from other sources, or from additional sources. This applies in particular where POYATU has a lending exposure to you, and seeks information about your creditworthiness;
- Where POYATU reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering Your Data from other sources. This applies in particular to consumer profile data.
Where POYATU collects Your Data from sources other than you, it undertakes:
- To do so only by legal means;
- To do so only with your Consent;
- To declare to you what sources it uses, and under what circumstances.
POYATU undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.
POYATU undertakes to store Your Data in a manner that ensures security against unauthorized access, alteration or deletion, at a level commensurate with its sensitivity.
POYATU undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.
POYATU undertakes to transmit Your Data in a manner that ensures security against unauthorized access, alteration or deletion, at a level commensurate with its sensitivity.
POYATU undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behavior by POYATU's staff-members and contractors.
- Training for staff in relation to privacy;
- Access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it;
- Particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
- Reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behavior;
- Declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behavior
- Clear communication of policies and sanctions;
- Processes to audit, to investigate and to impose sanctions.