Version 1.0. Effective Date: March 18th 2019
1. Who We Are and What this Policy is
This Policy applies to our website https://www.atayapartners.com, the global website of Ataya and Partners Partners, trading under the name of “Ataya and Partners” – Avenue Louise, 479/58 – 1050 Brussels – VAT BE 0719.976.659 (“our Site”),
Hereafter commonly referred to as “Ataya & Partners,” “A&P” “we,” “us” and “our” etc.
We are a management consulting company in the domains of IT and digital management and governance, cybersecurity and data protection.
We provide a variety of management consulting, education, certification, forensic and other value added services in these domains, to our clients and other parties (collectively, our “Services”). For additional information on our Services please visit http://www.atayapartners.com.
The cookies we use can be categorized as follows:
- Session Cookies: These are cookies that allow our Site to collect information about what you do during a browsing session each time you visit the Site. When connecting to our server, your device will be allocated a session ID, which enables our server to identify your device during the session and facilitates Site usability. These cookies are temporary and are set to be deleted when you leave the Site;
- Persistent Cookies: These are cookies that are stored by your Internet browser for more than a session and are set to expire within a defined time period. Persistent cookies enable us to remember your settings and information, so you do not have to keep re-entering them whenever you visit our Site. They also measure how you use and interact with the Site and enable us to personalize the Site. For example, they may allow us to alter the rotation of images on the Site so that different images will be displayed on your next visit;
- First-Party Cookies: These are cookies that we store and access on your device in our capacity as Controller of your Personal Information when you visit our Site. They might include cookies related to third-party service providers, provided that we control and determine the purposes and means of the Processing of your Personal Information logged by such cookies. As a result, first-party cookies might log user-related Personal Information accessible to and Processed by third parties on our behalf and subject to our instructions.
- Third-Party Cookies: These are cookies that are stored and accessed on your device by third parties determining the purposes and means of the Processing of your Personal Information logged by such cookies.
However, please be aware that this might render certain functions of our Site inoperable or more difficult to use. Depending on the Internet browser you use, you might also be able to specifically reject third-party cookies. In this context, please note, however, that third parties might still have access to your Personal Information to the extent that such information is logged by first-party cookies.
For additional information on first-party and third-party cookies used on our Site in the context of third-party services and for information on how you might stop such cookies from being stored on your device, please see “Third-Party Services” below.
Our Site uses Google Analytics, a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help analyse how users use the Site.
The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. The United States has not been found by the European Union to provide an adequate level of protection of personal data, i.e. a level of protection of fundamental rights and freedoms that is essentially equivalent to that guaranteed within the European Union. Similarly, the United States may not be found to provide an adequate level of protection by jurisdictions outside of the European Union.
On our behalf, Google will use the information collected for the purpose of evaluating your use of the Site, compiling reports on website activity for us and providing other services relating to website activity and Internet usage to us. Google will not associate your IP address with any other data held by Google. Neither will we match, link or otherwise connect any information received from Google with Personal Information collected through other components of the Site.
Lastly, you can refuse the use of Google Analytics by clicking on the following link: Disable Google Analytics.
In the latter case, an opt-out cookie will be set on your device, which prevents the future collection of your data when visiting this Site. Be aware, however that the opt-out cookie will only be effective within the Internet browser you used to access the above link and only for as long as you do not delete the opt-out cookie.
Our site uses also AddThis tools that provide website owners with the capability to enable users to instantly share webpages, blogs, news, photos, videos, and other content to the most popular social networks and other destinations via a browser plug-in or website plug-in.
AddThis is provided by Oracle Inc. and includes the following key components:
AddThis Tools: Oracle provides an AddThis suite of technologies to website publishers for use on their websites or mobile device applications (‘AddThis Tools’). With AddThis Tools, publishers can (i) enable users to share, follow, view, recommend and interact with the publisher’s content, and (ii) collect information from those users as a result of their visit.
AddThis Platform: Oracle also provides publishers with a platform where they can perform analytics and customize their websites and/or applications to provide users with more relevant advertising (“AddThis Platform”).
When you interact with our website or mobile device application on which we have installed AddThis Tools, your direct interactions are primarily with us.
AddThis Data will be treated as personal information to the extent required under applicable law.
When an End User visits our Site, AddThis receives AddThis Data via Cookies and Pixels. “Pixels” are small strings of code that provide a method for delivering a graphic image on a webpage or other document. Pixels allow us, to set, read, and modify Cookies on, and to transfer other data to, the browser used to view the webpage or other document. Cookies and Pixels allow the AddThis Tools to receive AddThis Data. When an End User uses the AddThis Tools on our site to share information and content that we make available on the Site (“Content”), the End User is redirected through the AddThis Site before the End User is directed to their destination website where they want to publish or share the Publisher Content (e.g., to share Publisher Content to a social media site such as Facebook).
Oracle may also receive End Users’ email addresses on our behalf on ourSite and transfer those emails addresses to our’s email service provider. The email addresses collected on our behalf are excluded from the definition of “AddThis Data” and these email addresses are not retained or used by Oracle to provide interest-based advertising, or to provide Oracle marketing or other Oracle purposes.
We retain the only the information about the visits to our websites for statistical purpose, and do not retain visitor IP addresses or similar user related information.
However, in “Cookies” and “Third-Party Services” above, we describe how you may use mechanisms similar to the “Do Not Track” technology of certain Internet browsers in order to effectively prevent us or third parties from collecting your Personal Information through online tracking. To the extent that you make use of these mechanisms, your preference not to be tracked or to be tracked only to a limited extent will be honored by us and the third parties providing services to us