For the purposes of this Privacy Policy "We", "Our" and "Us" refers to Empora ltd.

Summary

A key part of Our commitment to protecting your privacy is to explain how We collect and use your personal information and the choices you have about its use. We collect this information when you give it to Us or when you interact with any of the websites and services owned, affiliated or operated by Us. This policy does not apply to the practices of third parties that We do not own or control, or to individuals that We do not employ or manage.

The main types of information We collect online about you:

• The information you provide to Us (e.g. registration details)
• Technical information on how you use Our site (tracked through 'cookies' and server logs)
• Email communications (e.g. when you open a marketing communication from Us)
• Information from other sources (e.g. from Our retail partners)

The main ways We use this information:

• For analysis about how each of Our customers use the site
• To tailor Our site to better suit your needs
• To fulfill your shopping requirements
• To improve your experience on Our sites
• To treat you more personally
• To maintain your records
• To send you appropriate marketing communications

The main way We let other selected companies use this information:

• To provide you with a better experience on their own websites

Your choices:

• You can stop Us sending you marketing communications
• You can delete or change the information which you have given Us

By visiting Our websites, submitting information or using any of Our products and services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. Please note – this privacy policy applies to Our use of your information from 13 January 2010.

Privacy Policy in full

This website is owned and operated by Us. In the provision of the web based sites, pages, services and software, We and other data processors acting under Our control may collect, process, store and use aggregate information, and any information which may identify you (your "Personal Information") including any information provided to Us by you within your dedicated password protected section of our website (your “Personal Account”) in various different ways and for different purposes. We collect this information when you give this to Us or when you interact with Our websites.

You are in control of what information We collect about you. However, if you choose not to share your information, you may not be able to take advantage of some of Our website’s special features, such as creating a user profile or receiving email alerts. Access to some of Our services may require you to register with Us and open an account. We control the personal information you provide to Us when you register and when you use Our websites. We will process your Personal Information in accordance with this Privacy Policy and applicable law, and We take responsibility for the processing, disclosure, and use of that information, including use by a third party on Our behalf.

There are 10 sections which underline Our commitment to your privacy.

1. What data We collect from you
2. How We use the data We have collected
3. Your choices and marketing preferences
4. Who can your data be disclosed to?
5. Private online communications
6. How We keep your data secure
7. Links to partner websites
8. Amending your data
9. Personalising your experience with Us

Our Privacy Policy is subject to the following important provisions:

We (or data processors acting under Our control) will only disclose your information to third parties if you have consented (or not objected) to Us doing so. However, We may be obliged to disclose information about your Personal Account in the following circumstances:

• If We or an entity processing your information on Our behalf is compelled to do so by law
• In response to a valid, legally compliant request by a competent authority
• In special cases such as a physical threat to you or others
• Otherwise in accordance with applicable laws and regulations

Our commitment to your privacy:

1. What data We collect from you.

Depending on how you use Our websites, Personal Information may include:

A. Information provided by you when you register for a Personal Account, enter competitions or promotions, or take part in market research

B. Information about your online activities such as, your browsing patterns, click paths, searches you perform when using Our websites, and when you order products from Our online merchants/advertisers. Web usage data is received from your browser and recorded on Our server logs, including but not limited to, your Internet Protocol address, information about your geographic location, and "cookie" technology (visit Our Cookie Policy for more information on Our use of cookies and how to decline them). We may combine this web usage data with other information collected about you, for example, whether you arrived at Our site through a marketing email or promotional campaign, data about your user registration, or previous web usage data stored against a previous cookie set on your machine.

C. We may receive confirmation when you open an email sent by Us, such as news or promotions. It is clearly stated on each email how you can opt out of receiving further emails from Us (see section 3 to read more about your choices and marketing preferences)

D. Records of your communications with Us (whether in writing, by email or by telephone)

E. Information from other sources for example purchases from retailers that you were referred to by Us.

F. Technical and diagnostic information gathered or received when you use Our websites. Some of the technical information that may be collected or received includes: the type of browser you are using (e.g., Internet Explorer, Firefox), the type of operating system you are using (e.g., Windows XP or Mac OS), CPU type (e.g. Pentium), the manner in which you connect to the Internet (e.g., your Internet Service provider and your connection speed through dial-up or broadband access) or data relating to computer malfunctions or problems occurring when you use your computer to access Our websites. Additionally, We may collect information about other software on your computer for protecting your security or improving your online experience.

2. In order to enhance your online experience with Our websites, We use your Personal Information to analyse and constantly improve the operations and services We offer.

How We use the data We have collected:

A. Information provided by you, as outlined in 1A. This helps Us build up a picture of your preferences and interests so that when you visit Our websites We can accurately respond to your requests by customising the offers and relevant information you see. We will also use this information to undertake sales and marketing research and to tailor Our marketing campaigns and email communications specifically to you, and your recent activity on Our site. We retain your registration information so that you can return to saved lists or content generated by yourself which provides you with a more personalised experience. We may contact you to ask for feedback on your experiences whilst using Our websites.

B. Information provided when you interact with Our websites as in 1B. We try to ensure that Our website offers visitors exactly what they are looking for. Web usage data is used for statistical purposes and helps Us to measure the success of Our advertising campaigns, sales and marketing research, tracking page usage and targeting content for Our audience. It is not used in a manner that would identify you personally. It enables Us to understand how useful you find different sections of Our websites to be, so We can make Our websites and associated advertising/marketing appealing and relevant to as many users as possible. In addition, We may provide this type of statistical information to Our partners so that they too understand how people interact with their areas on Our websites, and may also provide you with an optimal Web experience. See section 4 to read more about who your Personal Information can be disclosed to.

Collection of the cookie data also helps save you time, for example if you are halfway through making a product selection, Our cookies will allow you to browse other areas of the website and return back to your search page and previous product selections.

C. Email confirmation as in 1C. If your computer supports this type of programme We use this information to help Us make emails more interesting and helpful. See section 3 to read more about your choices and marketing preferences

D. Communications with Us as in 1D are used to improve Our service to you and on occasion for the training and monitoring of Our staff. We may keep records in your account history of your complaints about other registered users online behavior, and any reported violation of Our Terms and Conditions of Usage that you or someone using your account may have committed.

E. Information from other sources as in 1E is used to enable Us to improve the personalisation of Our service and improve the product offering within Our websites.

F. Technical and diagnostic information as in 1F may be used to help diagnose problems with Our servers, to analyze trends, for system administration and to improve your online experience on Our websites. We don't link these addresses to any person's name or identity.

3. Your choices and marketing preferences

You can tell Us about your preferences regarding how your Personal Information is used for marketing purposes, and review and change your marketing preferences at any time by visiting your Personal Account or emailing help@empora.com. As stated previously, if you decide to not disclose some information, you may be unable to use certain features on Our websites for example, in order to receive an email alert for a product price watch you are required to submit your email address.

We offer you the opportunity to receive information about exclusive promotions, special offers and other news from Us. Unless you tell Us otherwise We may use your purchase history to communicate information We think may interest you. We'll only do this by email, SMS and other similar forms of communication where We're letting you know about Our services and promotions or promotions and news from Our partner merchants if you've told Us that you'd like this to happen.

You can sign up for direct marketing by registering on this website. You will also be asked if you want to receive direct marketing if you set up a Personal Account or if you enter a competition or register for a promotion with any of Our websites. Your details may be shared within Our group websites. We will normally send direct marketing by email if We have your email address. We may send you offers on behalf of other businesses such as Our partner merchants. However, when We do so, We do not give the other business your name and contact details. If you do not wish to receive these offers, please notify Us by e-mail at help@empora.com. See Section 4 to read more about who your data can be disclosed to.

If you would like Us to stop sending direct marketing to you, We offer simple ways to do this. Whenever you receive direct marketing you will be told how to unsubscribe. In addition, if you have a Personal Account you can change your marketing preferences at any time by amending your membership profile online, or by telephoning or writing to Us (Contact Us). As the choices you make about your preferences and settings may not take effect immediately, it is possible you may receive a communication which you have requested not to receive during the period in which your request is being processed.

If you consented to receive marketing communications when you entered a competition or registered for a promotion you can tell Us that you do not wish to receive any more by writing, with your full name, address and other contact details (Contact Us)

If you tell Us that you do not wish to receive further direct marketing, We will continue to send you important information about your Personal Account and any relevant legal notices. Please note that if you do not wish to receive any legal notices from Us, such as this Privacy Policy, those legal notices will still govern your use of Our websites, and you are responsible for reviewing such legal notices for changes.

From time to time We may run optional surveys. Surveys by or on behalf of Us are conducted in accordance with the Market Research Society and ICC/ESOMAR guidelines. These guidelines ensure that participation in any research is confidential and voluntary and that results do not identify individual respondents. For the purpose of surveys We may combine cookie or other data with your answers but We will ensure that this does not affect the anonymity of the results.

4. Who can your data be disclosed to?

We neither rent nor sell your Personal Information to anyone. We may pass on your Personal Information (including contact details) to other companies whose products and services may be of interest to you but We will only do this where you've clearly indicated that you'd like this to happen. We share your personal information only as provided herein or with your consent, to the entities that are controlled by Us or to the entities described below:

A. Disclosure of your data to other businesses may be necessary to ensure the smooth provision to you of the products, services and information you request, such as Our merchant partners you may have been referred to from Our site. We work closely with a variety of such businesses that operate within Our websites or sell items to you within Our services. You can easily recognize when a third party business is associated with your transaction, as a new window will open to their site. For all online purchases that you may make from third parties when referred from Our websites, ensure that you review their privacy policies and contact them directly if you have any questions. They may have privacy policies that differ from Us, and they may therefore use Personal Information which you provide to them differently.

B. We employ other companies and people to perform tasks on Our behalf and need to share your information with them to provide products or services to you. Examples include sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, and providing marketing assistance. We may also provide your personal information to agents who will use it to verify aggregate usage data that We provide to Our partners. You hereby consent to Our sharing of your personal information for all the above purposes.

C. If We purchase or sell business units, take over other companies, (or are taken over) or carry out corporate reorganizations, your Personal Information may be disclosed or transferred along with other business assets, to actual or potential purchasers. However the Privacy Policy will remain binding and your Personal Information will be subject to appropriate confidentiality obligations.

D. We may release personal information when We believe in good faith that release is necessary to comply with the law; enforce or apply Our Terms and Conditions of Usage and other agreements; or protect the rights, property, or safety of Our websites, Our employees, Our users, or others.

E. Any personal information or content that you voluntarily disclose online (on discussion boards, in blogs, comments, messages and chat areas, within your public profile page, etc.) becomes publicly available and can be collected and used by others. Your display name may be displayed to other users when you upload text, images or videos, leave comments or send messages through the Website and other users can contact you through messages and comments. Any images, captions, physical descriptions, personal interests or other content that you submit to the Websites may be redistributed through the Internet and other media channels, and may be viewed by the general public.

F. Accordingly, in operating this site, as outlined in this privacy policy, We may send data about site visitors through or to other countries, both inside and outside Europe.

5. Private online communications

We do not read your private online communications. We honour the confidentiality of your private online communications in private chat rooms or email (including downloads). We do not read, or disclose to third parties, private communications when you use Our websites, without your consent, except where We or an affiliate processing your data on Our behalf is compelled to do so by law, or in response to a valid, legally compliant request by a competent authority, or during emergencies when We believe physical safety is at risk. Of course, what you write or post in public or member chat rooms and message boards is available to the public.

6. How We keep your data secure

To help protect your Personal Information =,We use a variety of safeguards, including:

• technical, administrative, and physical controls (such as restricted access facilities, intrusion prevention and detection systems, and dedicated security personnel and incident response teams)
• encryption and authentication systems
• passwords, and other methods including Account Security Questions and
• agreements with contractors and vendors requiring them to protect the confidentiality, safety, and security of your information

Each and every one of Our employees must comply with Our Privacy Policy. We authorise Our employees to obtain access to your Personal Information only to perform their particular functions, and use technological and other control procedures to help limit such access. Employees who violate Our policies and practices are subject to disciplinary action.

We have established these safeguards to help prevent unauthorised access to or misuse of your Personal Information, but cannot guarantee that your Personal Information will never be disclosed in a manner inconsistent with this Privacy Policy (for example, as a result of unauthorised acts by third parties that violate applicable law or Our policies).

We are a global organisation, and some of the computers and companies that process information on Our behalf are based in the USA and other countries outside the European Economic Area (the "EEA"). This means that your Personal Information (which may include information you provide about your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or concerning health or sex life) may be transferred to, processed and held both inside and outside the EEA. These countries may not have similar data protection laws to the EEA. However, if We transfer your information outside of the EEA in this way, We will take steps to ensure that your privacy rights continue to be protected in compliance with applicable data protection law and this Privacy Policy.

If you choose to create one, your Personal Account information is protected by a password for your privacy and security. You need to work to protect against unauthorized access to your password and to your computer by logging off once you have finished using a shared computer.

You post information at your own risk. Although We allow you to set privacy options that limit access to your pages, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you may choose to share your pages and information. Therefore, We cannot and do not guarantee that information you post on the website will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the website. You understand and acknowledge that, even after removal, copies of your information may remain viewable in cached and archived pages or if other users have copied or stored your information.

7. Links to and from partner websites

We use links to other Internet sites to improve your experience of Our website. We will always seek to make these links clear by opening them in a new window of your web browser. However, please be aware that these websites may be owned and run by other companies and organizations and are not under Our control. We do not endorse any such websites and We are not responsible for the information, material, products or services contained on or accessible through those websites. Your access and use of such websites remains solely at your own risk.

It is also likely that other websites may contain links to Our websites. Again, links to Our websites do not constitute an endorsement by Us of the website or the services offered through them. The privacy and security practices of websites linked to or from Our websites are not covered by this Privacy Policy, and We are not responsible for the privacy / security practices or the content of such websites, and cannot accept responsibility for any information you divulge to them.

8. Amending your data

You can access your personal information through your Personal Account to correct, amend, or delete information that is inaccurate online or email help@empora.com . Please note that some information may remain in Our records after editing or deleting your account information.

If you cancel your Personal Account, or We cancel your Personal Account (see Our Terms and Conditions of Usage), unless and until you indicate otherwise, your name and contact details may: be used by Us during and for a reasonable period of time after your Personal Account is cancelled for the purposes described in this Privacy Policy; and passed to selected third party suppliers of goods and services in accordance with this Privacy Policy until 6 months after your Personal Account is cancelled.

If you require any further guidance on updating the details We hold about you, please contact Us. Contact Us

9. Personalising your experience with Us

We may use both Personal Information and other aggregated information to personalise your experience. This may include tailoring the content, communications, advertisements or promotions you receive. We may do this based on the details you have submitted, your expressed preferences and your online activity, how often you use the service, or the type of computer system you use, together with the activities and experiences of Our other users who We believe may have similar interests and preferences to you. We may supplement this data with publicly available consumer data, including demographic information, to help Us decide how to make your experience more relevant.

We may use navigational information about where you go on Our websites to better understand how they are used, and what content and advertisements Our users enjoy so that We can make Our sites better.

We may use cookies, web beacons or similar technologies to enhance and personalise your online experience and to enable Us to recognise you as a previous visitor to Our websites. (For more information on cookies please see Our Cookie Policy.) The benefits and personalization provides the following

• memory of the preferences and registration data that you give Us
• authenticates your Screen Name before you can access your Personal Account for added security
• enables you to participate in certain online activities, such as making sure that each person only votes in an online poll once
• personalises features such as customised content (e.g. saved favourites)

We may retain your Personal Information as long as is necessary for the purposes for which We collected it, or as is otherwise required by applicable law. We may process your Personal Information for a reasonable period after your use of Our websites ceases.

There may be developments in how We use your data - all such developments will be notified to you by updating this policy, which can be amended from time to time at Our discretion. Whenever We materially change the Privacy Policy, We will notify you by posting an announcement on Our websites or by sending you an email so you are always aware of what information We collect, how We use it, and under what circumstances if any, it is disclosed. Use of information We collect now is subject to the Privacy Policy in effect at the time such information is used.

If We collect any sensitive Personal Information, (for example about your health or lifestyle) We will not use this information without your explicit consent.

If We propose to use your Personal Information in a way which is not covered by this Privacy Policy, We will tell you how We propose to use it at the time We collect it.

If you have any questions about this Privacy Policy or its implementation, or if you have a concern or policy violation you wish to tell Us about, or wish to see the Personal Data We keep about you (as defined in the Data Protection Act 1988) you may Contact Us

By visiting Our websites, submitting information or using any of Our products and services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. If you have any questions or concerns regarding your privacy, please send a detailed message to help@empora.com. Your privacy is important to Us and We will make every effort to resolve your concerns. Please note – this privacy policy applies to Our use of your information from 13 January 2010.