Last Revised: July 4, 2019
Privacy of our users and customers is really important to us here at Silvester Design.
This policy outlines how we (silvesterdesign.com) may collect and use personal information from our users (each, a 'Visitor or 'User' (respectively), or 'you') regarding such information.
This policy describes our privacy practices and how we abide by the GDPR Regulations. It explains what information we collect on our visitor and users, how we collect it, what we do with it, how we protect it and your rights regarding your information.
We recommend that you should read this policy and make sure you fully understand it before you access or use any of our services
1. Please read carefully
2. What information do we Collect?
2.1 What type of information we collect
We collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, email, password, communications), comments, feedback, product reviews, recommendations, and personal profile
2.2 Users of Users information
We may also collect similar information pertaining to visitors and users of our Clients's websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section 6 below).
3. How & Why do we collect such information?
3.1 Site visitation tracking for visitor and user information
This site uses Google Analytics (GA) to track user interaction.
We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to track their journey through the website.
Although GA records data such as your approximate geographical location, device, internet browser and operating system, none of this information personally identifies you to us.
GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
For your information, our website uses the Wix implementation of GA.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
3.2 Contact forms, Get quote forms and email links
Should you choose to contact us using the contact form on our Contact us page or contact us via Get a Quote page, contact data that you supply will be stored by this website onto WIX CRM and will not get passed to/be processed by any other third party data processors unless specified by the user.
Email links and contact forms data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
3.3 Collect information through our Client Portal System
When you use our Client Portal Area or use any other services associated on this website (silvesterdesign.com). We will gather, collect and record uses and sessions and related information, either independently or with the help of third-party services (including Hotjar, GA), we also use a wide range of cookies and other tracking technologies to help assist and gather the relevant information to assist our Clients.
3.4 Why do we collect such information?
We collect this information for the following purposes:
To provide and operate the Services;
To further develop, customise and improve our Services
To Provide our Clients and Users with ongoing customer assistance and technical support
To be able to contact our Visitors and Users with general or personalised service-related notices and messages
To consider and approve Quotes through Silvester Design Quote System
To comply with any applicable laws and regulations
We will only use your Personal Information for the purposes set out in Section 3 where we are satisfied that:
our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with a completed Quote, Technical assistance through our Support Centre, or having you as a Client with Silvester Design)
our use of your Personal Information is necessary to comply with relevant legal and regulatory obligations that we have.
4. How Do We Store Your Information
4.1 How we store your information
If you have made a purchase or become a Client as a 'Visitors, Silvester Design Clients, and Users-of-Users' your personal information (not including any sensitive financial details) are stored in our WIX CRM and WIX Corvid databases in order that we can fulfil your order(s), subscriptions with Third Party Applications, membership information and also refer back to your email and/or postal details in order that we may track any orders you have queries on. Any financial information is not stored on the WIX CRM Database but is located on a secure internal platform that Silvester Design uses. All our transactions are made within the WIX Payments or selected third party platform (depending on subscription type) which does not retain any financial information once the transaction has been processed.
These are the only occasions where personal data will be stored on this website for example being a member of the Client Portal. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is built on (WIX). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
4.2 WIX LTD - EU-U.S. Privacy Shield & Swiss-U.S. Privacy Shield Disclosure
Silvester Design uses WIX LTD as it's CRM and Database centre so information is stored within their servers for information about where their Servers are located, see Section 5 below.
Wix.com participates in and has certified its compliance with, the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Wix.com is committed to subjecting all Personal Information received from the European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List, here.
Wix.com is responsible for the processing of Personal Information it receives, under the Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on its behalf. Wix.com complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, Wix.com is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, Wix.com may be asked to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and will do so where permitted by local data protection laws.
4.3 Requesting your Data
Upon request, Silvester Design can request WIX to provide you with information about whether we hold any of your Personal Information. You may access, correct, or request deletion of your Personal Information by following the instructions provided in these Help Center articles: “GDPR: Retrieving Your Wix Account Data” or “GDPR: Permanently Deleting Your Wix Account. We will respond to your request within a timeframe imposed by local laws or a reasonable timeframe.
Please note that permanently deleting your data from Wix accounts, erases all of your information from Wix's and Silvester Design databases. After completing this process, you can no longer use any of your Wix or Silvester Design Services, your User Account and all its data will be removed permanently, nor Wix or Silvester Design will not be able to restore your account or retrieve your data in the future. If you contact Wix Support in the future, the system will not recognise your account and Support agents will not be able to locate the deleted account.
5. Website's Server and Third Party Processors
5.1 About this Website's Server
This website is hosted in data centres in the United States and Europe. From time to time, we may transfer hosting from one location to another. Notwithstanding the above, the Wix.com platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles. Wix.com guarantees that the platform will be compliant with the new regulation from May 2018.
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
5.2 Our Third-Party Data Processors
We use three third parties to process personal data on our behalf. The third parties we use are Wix Payments, Dropbox and Wix. In some cases, depending on Client Portal Subscriptions additional Third-Party application will be used.
Wix Payments process payments for any products purchased from our website. Neither we or Wix Payments retain any financial information you may submit as part of the purchasing process. Wix Payments monitor every transaction, 24/7 to prevent fraud, email phishing and identity theft. Every transaction is heavily guarded behind Wix Payment's advanced encryption. If something appears suspicious, their dedicated team of security specialists will identify suspicious activity and help protect you from fraudulent transactions. Wix Payments, WIX or SILVESTER DESIGN will never ask for any sensitive information.
Your data as mentioned below is encrypted before transmission to prevent misuse of the transmitted data by third parties. SSL (Secure Socket Layer) is a security technology which guarantees that your personal data, including credit card information, login data and payment method, are securely transferred via the Internet. The data is encrypted so that is only readable by the PayPal payment system.
Your data which is encrypted is as follows:
· personal data (address data, telephone number, etc.)
· login data (username and password)
· all methods of payment selected, credit card and bank account
WIX provides the Customer Engagement platform we use to manage and fulfil your orders. No personal financial information is ever taken or stored in this system as, during the process, everything is transferred out to PayPal so that neither us nor WIX has access to your financial information.
What WIX do to ensure data protection to all our customers
· WIX employs full-time security consultants, dedicated to the security of our customer information.
· WIX is Payment Card Industry Data Security Standards (PCI DSS) compliant and is accredited as a level 1 service provider and merchant. This standard helps create a secure environment by increasing cardholder data, thus reducing credit card fraud. WIX regularly perform internal security audits to maintain our ISO/PCI security certifications, as illustrated below (please click the links to see the Certificates):
o ISO 27001:2013 and ISO 27018:2014 Best Practices Certificate
o ISO 27108 Certificate
o PCIDDS Compliance Certificate
· WIX's signup and login services are completed through a secure server (HTTPS/SSL).
· WIX uses cryptography hash functions to protect your information. Your password is stored as a hash digest and, in the event of a security breach, your original password cannot be recovered from ours or WIX servers.
· WIX is certified under the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, and therefore adheres to the Privacy Shield Principles.
Three of the following third parties are based in the USA and one is based in the Republic of Ireland and all are EU-U.S Privacy Shield compliant.
6. Sharing Personal Information with Third Parties
6.1 Sharing personal information
At no point will Silvester Design share personal information with third parties without your consent. Though our Service Provider WIX are subject to be law which is outlined below:
6.2 WIX - Law Enforcement, Legal Requests and Duties
Where permitted by local data protection laws, Wix and Silvester Design may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
Silvester Design uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, Users and Clients.
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Cookies are implemented in every site built by Wix.com. Our website is hosted on Wix.com platform and here is a list of the cookies used on Wix websites
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our site, or may otherwise adversely affect your user experience.
7.2 Clear Gifs
We, WIX and certain Third Party Services may employ a software technology called 'Clear gifs' (a.k.a. Web Beacons/Web Bugs), which enables them to and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier similar in function to a cookie, however, are not stored on your devices, but instead embedded within our Services.
8. Communications from Silvester Design
8.1 Quote Communications
Silvester Design will contact you regarding any Quote that you have submitted to us. Upon first time of using our Quote Centre, you will be automatically added to our Client Portal, so you can keep track of Quote Progress. Quotes are submitted, handled and communicated over email and via our 'Your Quotes' section on the Client Portal.
8.2 Client Communications
As a Client with Silvester Design, you will be able to control what you receive in terms of Email or WIX Dashboard Notifications. This is done within the Company Account Notification or each respective Product's Notification Panel.
As a default, all communications with Silvester Design is enabled automatically and the email address of the Company main Contact Isliason is used. You can change the email associated with each communication within your respective Product's Notification Panel.
8.3 Service and Billing Messages:
Client's of Silvester Design will be contacted with important information regarding WIX or any third Party Services that has been applied to any Product that a Silvester Design Client may have. For example, we may send you to notice if a certain Subscription is temporarily suspended for maintenance, reply to a support question or email, send you renewal reminders or warnings regarding an upcoming or late payment for a subscription. We will also inform you of material changes in our Services.
It is important that you are always able to receive such messages. But to comply with GDPR Regulations within your Product's Notification panel you can opt-in or out for any emails or notifications that we may send out.
Note: If you Opt out of subscription renewal and a subscription fails to renewal, Silvester Design cannot hold responsibility for loss of service. We strongly recommend that you Opt-in all notifications and messages from us.
8.4 Timeline Service:
Client's of Silvester Design will be contacted every time an event is taken place on their product. This is when Silvester Design carries out work either upon request of the Client or as part of a legal obligation to comply with a Law requirement.
You can opt-in or out at any time from each respective Product's Notification Panel.
9. Your rights in relation to your Personal information
If you are a user or Client with Silvester Design and you wish to receive a copy, access and /or request us to make corrections to the Personal information that you have stored with us (either yours or your users-of-users), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please contact us. If you would like information from Wix our Service Provider please follow the instructions provided in these Help Center articles: “GDPR: Retrieving Your Wix Account Data” or “GDPR: Permanently Deleting Your Wix Account”. You can also, mail your request to Wix.com, 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel.
We will make all reasonable efforts to honour your request promptly (unless we require further information from you in order to fulfil your request).
Please note that permanently deleting your Silvester Design account erases all of your information from both Silvester Design and WIX databases. After completing this process, you can no longer use any of Silvester Design or WIX's services, your account and all its data will be removed permanently and will not be able to be restored or retrieve any data in the future.
Silvester Design uses implemented security measures via WIX designed to protect the Personal Information you share with us including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry-standard SSL/TLS encrypted connection, and WIX regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We and WIX also regularly monitor our systems for possible vulnerabilities and attacks and regularly seek new ways and Third-Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts are taken by Silvester Design and WIX, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Information or any other User Content you upload, publish or otherwise share with Silvester Design, Wix or anyone else.
We, therefore, encourage you to set strong passwords for your User Account and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, because certain areas are less secure than others (for example, e-mail and instant messaging are not recognized as secure forms of communications) we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at firstname.lastname@example.org
11. Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
12.1 Data Controller
The data controller of this website is:
Christopher Silvester , Owner of Silvester Design, WIX Website Partner
12. Updates and Interpretation