This Privacy Policy was last modified on July 10th, 2019.

SCOPE

1. This Privacy Policy describes the practices of Andorra, Inc. (“Andorra”, “we”, “our” or “us”) regarding the collection, use, and disclosure of Personal Information (as defined below) of online visitors or users of https://www.andorraii.com and the Products located thereat. This Policy describes (i) the types of Personal Information collected (ii) the manner of collection, (iii) the purposes of the collection, (iv) its disclosure and/or transfer, (v) the measures we take to protect the security of Personal Information and (vi) your rights regarding Personal Information. This Policy does not apply to information which does not qualify as Personal Information.
2. This Policy does not apply to the collection, use, and disclosure of Personal Information by third parties, where Andorra does not have any control over the collection of Personal Information or their privacy practices.
3. Except for legal and regulatory requirements applicable to Andorra and for the Purposes outlined in Section 8, Andorra, its employees and service providers do not have access to any Personal Information.
4. By “Personal Information” we mean, except to the extent provided by applicable law, any information about an individual that allows such individual to be identified. Personal Information may include but is not limited to the first name, last name, address, telephone number, credit card number, date of birth, and email address.
5. Andorra is committed to privacy and the protection of Personal Information and to complying with applicable personal information and privacy laws and regulations.

COLLECTION OF PERSONAL INFORMATION

6. Andorra may collect the following types of Personal Information:

(a) name, postal address, email address, telephone number, date of birth
(b) information relating to professional skills, credentials and experiences

7. Personal Information may be collected in the following manner:

(a) when contacting us or communicating with us via the telephone, by mail, email or facsimile regarding one of our products, services, or online initiatives
(b) online while visiting our website
(c) online via one of our online websites or online initiatives in data forms and/or fields queries
(d) when using one of our electronic or mobile devices, application or tools
(e) when submitting your resume to us for employment purposes

PURPOSES

8. Personal Information may be collected and used for the following purposes (the “Purposes”):

(a) payment processing and fraud prevention
(b) to respond to your inquiries on our products or services
(c) occasionally, as permitted by applicable laws and regulations or if you have given us your consent, to communicate with you (via phone, mail, email or online) about our products and services
(d) to fulfill registration for one of our products or services
(e) to enable us to customize and personalize the content, tools and resources available to you as a user of our products and services
(f) to permit us to improve our products, services, website, online resources, applications or tools
(g) to allow us to enhance the quality of our services
(h) to allow us to assess your employment application

9. Information may be consolidated and aggregated in an anonymous manner in order to generate statistics in relation to our products, services, website, online resources, applications or tools.
10. Any other collection and use of your Personal Information will be solely with your consent, for the purposes disclosed to you at the time of collection, or as permitted or required by law and regulations. Only the amount of Personal Information necessary to fulfill the intended purposes is collected and/or retained.

INFORMATION WE SHARE

11. We do not disclose Personal Information except as described herein, unless otherwise authorized and required by applicable law or relevant court proceedings.
12. Personal Information about you will be accessible only to authorized employees of Andorra and/or of its affiliates who need to have access to the Personal Information in order to perform their duties in relation to the Purposes.
13. Andorra may retain agents, consultants and/or suppliers (collectively “third-party service providers”) to assist and support our business and services. These third-party service providers may have access to Personal Information within the scope of the Purposes if it is required for the performance of their services. When we transfer or provide access to Personal Information to third party service providers, we contractually require that such providers put in place adequate security measures to protect Personal Information against unauthorized access and disclosure, including requiring that they respect this Privacy Policy and be responsible for the security of the Personal Information disclosed.
14. Your Personal Information may be consolidated, aggregated and rendered anonymous for internal research or reporting to governmental authorities purposes and disclosed to third parties as such (i.e. in an unidentifiable manner).
15. The collection, use, and disclosure of information contemplated in this Policy may involve a transfer of the information to jurisdictions located outside your country of residence that may not have equivalent laws and rules regarding Personal Information. The reasonable contractual other measures we may take to protect Personal Information while processed or handled by these third parties are subject to applicable foreign legal requirements, for example lawful requirements to disclose Personal Information to government authorities in those countries.
16. We reserve the right to transfer any Personal Information we have about you in connection with the sale or transfer of all or a portion of our business or assets or rights relating thereto. In such case, we will do our best efforts to obtain guarantees that your Personal Information will continue to be protected as per the applicable personal information and privacy laws and regulations.

RECORDS RETENTION

17. Andorra will only retain Personal Information as long as needed to fulfill the relevant Purposes. The Personal Information will be held primarily in an electronic database located on our premises or those of our service providers. The file containing your Personal Information will be made available to the authorized employees, third-party service providers of Andorra and/or its affiliates who need to access the information in connection with the Purposes.

SECURITY

18. We maintain appropriate administrative, technical and physical safeguards and use appropriate commercially reasonable efforts to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and all other unlawful forms of processing of the Personal Information in our possession.

PERSONAL INFORMATION DATA BREACH

19. In the event of a Personal Information data breach that Andorra has determined to pose a “real risk of significant harm” to any individual or institution, Andorra has in place a procedure that involves (a) notifying those individuals and institutions affected by the breach, (b) notifying any organizations that Andorra has determined could help mitigate any harm resulting from the breach and (c) conducting an investigation as to the cause of the breach and insuring further risk to any Personal Information has been mitigated.

YOUR RIGHTS

20. You have certain rights to access and rectify your Personal Information; in order to exercise this right, or if you have any questions, comments or concerns about this Privacy Policy, to contact us about withdrawing consent to our use or disclosure of Personal Information or to obtain information on our practices relating to the use of foreign service providers, you may contact us at info@andorraii.com. If the Personal Information collected is incorrect, inaccurate or outdated, we will correct such information within a reasonable period of time.
21. You have the right to request the deletion of any of your Personal Information stored by Andorra. Such requests can be made to Andorra by contacting us at info@andorraii.com. Andorra will comply with your request within a reasonable period of time once we have reasonably verified your identity. During the processing of such a request, Andorra will ensure that your Personal Information will be removed from any Andorra database that contains the information. However, due to securities laws, Andorra must continue to maintain some information.
22. Andorra respects and observes the provisions set forth in applicable legislation regulating the protection of Personal Information. To the extent there is additional protection afforded to an individual pursuant to such applicable privacy legislation, and same is not set forth herein, Andorra agrees to take such measures to give full effect to such additional protection. Andorra reserves the right to modify this Privacy Policy at any time.
23. You have the right to opt-out of any marketing-related communications sent by Andorra at any time. A link to unsubscribe will be provided in each of our marketing-related email communications. Additionally, opt-out requests may be emailed to info@andorraii.com. All such requests will be processed within a reasonable period of time.

COOKIE POLICY

24. Cookies are tiny files stored on your computer, created when you visit a website, that provide a website the ability to help improve your browsing experience. This section will explain how and why Andorra, and any third-party services we use, use cookies as part of our website and how these cookies will affect your experience on our website(s).
25. Andorra uses cookies to help improve a user’s browsing experience in the following ways:

(a) Andorra creates a cookie when you visit our website and are prompted with our cookie-policy message. We use this cookie to track your choice (accept or decline) so that for subsequent re-visits to our website, you are no longer prompted for the same choice. Without this cookie, you will always be prompted with our cookie-policy prompt.
(b) Andorra creates a cookie when you log into our website with a valid username or password. This cookie is used to track the fact that you are logged in and ensures that as you navigate and browse through our website – you continue to remain logged in throughout your browsing session. Without this cookie, you will not be able to use the website as a logged in user.
(c) It is possible to disable cookies on your browser via your browser’s settings, which will prevent our website or any third-party service we use from creating or using cookies. However, disabling cookies will significantly impact the use and experience of our website(s) and you will not be able to use any of our member-only services. We recommend that you DO NOT disable cookies.

26. Andorra also uses third-party services that will create cookies on behalf of Andorra:

(a) Andorra uses website analytics services that helps track, anonymously, your browsing activity on our website. Such tracking involves, but is not limited to, information such as: the duration of time you spent visiting a page, the number of times you have visited a page, how many pages you have visited during your browsing session, as well as information such as your browser and geographical location. Andorra uses this information to help improve your browsing experience by determining which of our pages are performing well and which are not via the collected metrics. We then use this information to implement new features and content.
(b) The following are the third-party services Andorra uses that create cookies on your browser:

(i) Google Analytics
(ii) Mailchimp
(iii) WordPress