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Privacy policy

This Privacy Policy governs the manner in which Esterson Limited, registered address: 75 Prodromou Avenue, Oneworld Parkview House, 4th floor, Nicosia 2063, Cyprus and our subsidiaries and affiliates ("IO", "we" or "us") collects, uses, maintains and discloses information collected from users (each, a "User") of the website ("IO Scout website", "our website", "this website"). This Privacy Policy applies to IO Scout website and all products and services offered by IO on our website and in this regard.

1. Introductory statement

The privacy and confidentiality of your personal data is a top priority for us. This Privacy Policy governs the manner in which IO processes personal data obtained from its website Users. By using our website, providing us with your personal data, and reading this policy:

  • you declare your express consent to our processing of your personal data for contacting purposes;
  • you declare your express consent to our processing of your personal data for internal administrative reasons;
  • you declare your express consent that we may transfer your data for processing outside the country of your residence (including outside EEA);
  • and you are deemed notified and acknowledged of such processing and transfer.

If you do not agree with the processing and transfer of your personal data, please do not provide us with your personal data via the Scout website.

2. The personal data we may collect and how we may use it

We only collect such limited personal data from you that is necessary for us to allow you to use Scout website. Examples of personal data that we may collect from you are the following:

  • email address;
  • information about your devise (computer, laptop, tablet etc.);
  • internet protocol (IP) address;
  • cookies (as defined in Cookies Policy);

If you contact us through Intercom help chat located in the bottom right corner of Scout website or via telephone, we may keep a record of your communication with us to address potential issues you might face.


When using Scout website, we may collect the following non-personal information about your experience with our website for statistical purposes without making any decision based on automated processing, including profiling:

  • login information;
  • the frequency and duration of your website visits;
  • information about searches made on our website;
  • pages you visit on our website.

All of the above collected information is used for organizational, administrative and internal reasons. We do not provide this information to third parties, except as required by law.

The Scout website is not directed at children under the age of 18 and does not knowingly collect any personally identifiable information from children under the age of 18.

3. How we collect your personal data

We use cookies, web beacons, tags and scripts, and other similar technologies including local storage objects such as HTML5. These technologies allow us to manage access to and use of Scout website, recognize you and help us understand how you use this website.

Cookies are files or pieces of information that may be stored on your computer (or other devices, such as smartphone or tablet) when you visit our website. This allows us to distinguish your device from those of other users of Scout website. A cookie will usually contain the name of the website it has come from, how long it will stay on your device, and a randomly generated unique id number.

We use the following types of cookies:

Persistent cookies. We use persistent cookies to improve your experience of using the IO website.

Session cookies. Session cookies are temporary and removed at once from your device after your web browser closes. We use session cookies to help us track the internet usage as described herein.

You may refuse to accept cookies by changing the corresponding settings in your web browser. However, if you choose to do so, you might be unable to access certain content of Scout website. Unless you change your web browser settings regarding cookies, our systems will place cookies on your device when you visit this website.

You may read more about cookies that we use on Scout website in our Cookies Policy.

4. Main purposes of processing

We use your personal data for the following purposes:

  • to personalize the user experience;
  • to operate, provide, improve, and maintain our website and services;
  • to respond to your inquiries and for other customer service purposes;
  • for other administrative and internal business purposes.


5. Security of your personal data

IO uses a variety of security measures to keep your personal data protected from unauthorised access and disclosure. IO has in place a security system that is fully compliant with the EU General Data Protection Regulation (the “GDPR”). IO processes your personal data based on the following principles:

  • Fairness and lawfulness: we process your personal data only after obtaining your consent for the processing, and for a determined specific purpose;
  • Transparency: we process your personal data in a transparent manner, and only with your knowledge;
  • Purpose limitation: your personal data is processed within the purposes outlined above;
  • Data minimization: we only process your personal data to the extent that it is actually needed to achieve the processing purposes;
  • Accuracy: we ensure that your personal data is accurate and kept up to date;
  • Storage limitation: your personal data will be processed for the limited period of 5 years, if no other contractual obligations with you allow a longer time period;
  • Integrity and confidentiality: we secure your personal data with suitable organizational and technical measures;
  • Accountability: we will be responsible for, and be able to demonstrate compliance with the above- mentioned principles.

6. Access to your personal data

Only a limited number of IO employees who are responsible for the maintenance of Scout website and customer relations have access to your personal data.

7. Main processing actions with your personal data

We may process your personal data mostly by way of collection, storing, recording and structuring. However, we cannot exclude other ways of data processing, if necessary for the above-mentioned purposes.

We may also transfer your personal data from the European Economic Area (the “EEA”) outside the EEA (e.g., from our servers located in Germany, the Netherlands and USA to our offices in other countries). If we do so, we reasonably ensure that your rights and freedoms as a data subject are protected in compliance with the GDPR.

8. Where we store your personal data

All your personal data collected by us is stored on our secure servers located in Germany, the Netherlands and USA.

9. Disclosure of your personal data

We use our best efforts not to disclose any confidential information to third parties. IO maintains secure websites, but you should know that computer use may be monitored by third parties such as network administrators, employers, internet providers, and operation system and internet browser vendors, and, thus, we cannot guarantee the security of information you post online. You disclose all information online at your own risk. Please remember that this website may be hosted outside your home country, and your email communications to us may be directed to a server that is hosted outside your home country. Communications over the Internet may not be secure.

10. Third party provided content/links

Users may find content and products of other companies or organizations on our website and/or links to the webpages and services of our suppliers, licensors, or other third parties. Please note that we do not control these websites. Each third party is solely responsible for complying with the laws, rules and regulations applicable to its business and the operation of its own website.

11. Your privacy rights

If the GDPR is applicable for you, you may have the following data subject rights:

  • the right to obtain any information about processed personal data;
  • the right to access your personal data;
  • the right to withdraw your consent for processing of your personal data;
  • the right to correct and erase your personal data;
  • the right to be aware of any correction or erasure of your personal data, restriction of processing, and recipients of your personal data;
  • the right of data portability;
  • the right not to be subject to a decision based solely on automated processing;
  • the right to lodge a complaint with a competent data protection authority.

12. Your California privacy rights (for California residents only)

This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law.

For more details about the personal information we have collected, including the categories of sources, please see “The personal data we may collect and how we may use it” section above. We collect this information for purposes described in the “Main purposes of processing” section above. We share this information with the categories of third parties described in the “Disclosure of your personal data” section above. We do not sell (as such term is defined in the CCPA) the personal information we collect.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at the details provided at the end of this page. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

California also provides its residents with additional access rights. Under Shine the Light law, the residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.

To obtain this information from us, please send an email message to the details provided at the end of this page, which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.