Privacy policy

1. What does this privacy policy govern?

This Privacy Policy ("Policy") applies to all information, including personal information within the meaning of applicable law (collectively, "Personal Information") that S Group International Inc. and/or its affiliates may obtain about you through your use of any websites, programs, information about which you can find on troywell.org, and other sites owned by S Group International Inc. S Group International Inc. may also receive Personal Information from its partners ("Partners") whose sites, programs, products or services you use. Please note that use of any of the Sites may be subject to additional terms and conditions, which may amend and/or supplement this Policy, and/or have special terms and conditions relating to Personal Information posted in the relevant sections of the documents for such Sites.

2. Who Processes Information

To enable your use of the Sites, your Personal Information is collected and used by S Group, including the entity registered at 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex(S Group International Inc.)

3. What is the purpose of this Policy

The protection of your Personal Information and your privacy is extremely important to S Group International Inc. Therefore, when you use the Sites, S Group protects and processes your Personal Information in strict compliance with applicable law. In keeping with our obligation to protect your Personal Information, in this Policy we would like to inform you in the most transparent way possible about the following points:

(a) why and how S Group collects and uses ("processes") your Personal Information when you use the Sites;

(b) what S Group's role and responsibilities are as the legal entity that decides why and how to process your Personal Information;

(c) what your rights are under the processing of your Personal Information.

4. What Personal Information S Group collects about you

Personal information collected in the course of the Sites may vary depending on whether or not you are registered with the service. When you log in to your account, the Personal Information collected about you by S Group during your use of the Sites may be matched and associated with other Personal Information collected by S Group as part of your use of your account (such as product browsing history, contact information, payment information, if provided by S Group). S Group does not verify the Personal Information you provide to S Group other than as required by the user agreement or terms of use for particular services and cannot make any judgment as to its accuracy or whether you have sufficient legal capacity to provide your Personal Information. However, S Group assumes that you provide accurate and sufficient Personal Information and that you update your Personal Information on a timely basis. S Group may collect the following categories of Personal Information about you during your use of the Sites:

(i) Personal Information provided by you when you register (create an account), such as your email or access from Facebook, Google, etc( depending on which type of registration you choose);

(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information, wi-fi network data);

(iii) the date and time you accessed the Sites;

(iv) information about your activity while using the Sites (such as search history, data about purchases through the Services, data about organizations visited, likes and preferences, and files and content stored on S Group systems);

(v) geolocation information;

(vi) other information about you as required to be processed in accordance with the terms and conditions governing the use of specific S Group Sites;

(vii) information about You that we receive from our Affiliates pursuant to the terms of agreements between You and the applicable Affiliate and agreements between S Group and the Affiliate.

S Group also uses cookies and web beacons (including pixel tags) to collect Personal Information and link such Personal Information to your device and web browser (see Section 11 of this Policy). S Group does not knowingly collect sensitive personal information (such as racial origin, political views, health information, or biometric information). S Group does not collect data for the purpose of "profiling" you to an extent that could materially affect your rights and freedoms under applicable law.

5. What is the legal basis and purpose for processing your Personal Information

S Group may not process your Personal Information without sufficient legal grounds. Therefore, S Group processes your Personal Information only if:

(i) the processing is necessary to fulfill S Group's contractual obligations to you, including to operate the Sites (for example, to provide you with search results for your search queries);

(ii) the processing is necessary to comply with statutory obligations;

(iii) where required by applicable law, the processing is necessary to safeguard S Group's legitimate interests where such processing does not materially affect your interests, your fundamental rights and freedoms. Please note that S Group will always seek to maintain a balance between its legitimate interests and the protection of your privacy when processing your Personal Information on this basis.

S Group processes your Personal Information to protect its legitimate interests, such as the following:

(a) to better understand how you interact with our Sites;

(b) to improve, modify, personalize, or otherwise enhance the Sites for the benefit of all users;

(c) to offer you other products from S Group or other companies that we believe may be of interest to you (i.e., to show you advertisements tailored to your interests);

(iv) for specific purposes or as required by applicable law, we may seek your separate consent to process your Personal Information. For jurisdictions where consent is recognized as a separate legal basis, your use of the S Group Sites constitutes your consent to such processing. We hereby inform you, and you acknowledge, that you have no obligation to provide us with any Personal Information when you use the Sites or Services and is based solely on your free will. However, you understand that without providing Personal Information, we will not be able to provide you with the S Group Services and your use of the Sites will be limited.

S Group always processes your Personal Information for specific purposes and only Personal Information that is relevant to achieving those purposes. Specifically, we process your Personal Information for the following purposes:

(i) providing you with access to the Sites (including providing search results in response to your search queries based on your preferences, search history and other Personal Information about you available to S Group);

(ii) providing access to your account;

(iii) communicating with you to send you notices, inquiries and information relating to the operation of the Sites, to fulfill agreements with you, and to handle your inquiries and requests;

(iv) personalizing advertisements and offers based on your preferences, search history and other Personal Information about you available to S Group;

(v) improving the usability of the Sites, including to display the most relevant search results and provide more personalized Sites, and to improve other S Group products, applications;

(vi) creating new S Group products, utilities and offerings;

(vii) protecting your and S Group's rights;

(viii) collecting, processing and presenting statistical data, big data and other research.

6. How S Group protects your Personal Information

In most cases, Personal Information is processed automatically without access to it by anyone at S Group. If such access is necessary, it may be granted only to those S Group employees who need it to perform their tasks. To protect and ensure data privacy, all employees must comply with internal policies and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information. S Group has also implemented sufficient technical and organizational measures to protect Personal Information from unauthorized, accidental or unlawful destruction, loss, alteration, unfair use, disclosure or access, and other unlawful forms of processing. These security measures were implemented taking into account the state of the art, the cost of their implementation, the risks associated with the processing and the nature of Personal Information.

7. Who else has access to your Personal Information and to whom it may be shared

S Group may also share Personal Information with third parties:

(i) to third parties in respect of whom an assignment of rights or obligations, or novation under a relevant agreement, has been made;

(ii) to any national and/or international regulatory authority, law enforcement agencies, central or local executive authorities, other official or public authorities or courts with respect to which S Group is obligated to provide information pursuant to applicable law upon request;

(iii) to third parties if you have consented to the transfer of your Personal Information or the transfer of Personal Information is required to provide you with the relevant Service or to fulfill a specific agreement or contract entered into with you;

(iv) to any third party for the purpose of providing legal defense to S Group or any third party if you are in breach of the S Group Services User Agreement(https://troywell.org/privacy-policy/). of this Policy or the terms governing the use of certain Services, or if there is a threat of such breach.

8. Where your Personal Information is stored and processed

Because our servers are located in various locations around the world, a particular user's information may be processed in a country other than that in which he or she resides. The level of privacy and data protection laws may vary from country to country. Regardless of where your data is processed, S Group International Inc. uses the same data security measures described in this Privacy Policy. S Group International Inc. also adheres to a number of legal standards regarding data transfers.

When we receive a complaint in writing, we contact the sender of the complaint. If we are unable to resolve a complaint regarding the use of personal data directly with you, we will refer it to government authorities who have the authority to do so.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield framework agreements

As stated in our Privacy Shield compliance certificate, the S Group adheres to the principles of the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield framework agreements. These principles are formulated by the U.S. Department of Commerce with respect to the collection, use and retention of personal data from the European Union (including EEA countries) and the United Kingdom and Switzerland, respectively. S Group states that it adheres to the principles of the Privacy Shield agreements. As set forth under "Information S Group provides to third parties," S Group is responsible for maintaining the confidentiality of your personal information which we transmit to our partners for processing for use in our services, in accordance with the information transfer principles set forth in this agreement.

If you have any questions about our Privacy Shield principles, please contact us. S Group is subject to the judicial and executive decisions of the U.S. Federal Trade Commission. You may also contact the data protection organization in your country. If you do, we will work directly with them to resolve your issue. In special cases, Privacy Shield's framework agreement prescribes binding arbitration to resolve disputes that cannot be resolved by other means. See Appendix I of the Privacy Shield agreement principles for more details.

9. How long we keep your Personal Information

S Group will retain your Personal Information for as long as necessary to accomplish the purpose for which it was collected or to comply with legal and regulatory requirements.

Unless otherwise required by law or by agreement with you, emails and documents that you store on S Group systems as part of the Service will be retained for as long as you have an account, but they may be deleted by you at any time.

If you wish to have any of your Personal Information deleted from S Group's databases, you may delete the required Personal Information yourself using your account or through the interface of the Sites and/or Services (where applicable).

10. Your Rights

10.1 What rights do you have?

To the extent required by applicable law, you have the right to access your Personal Information processed by S Group in accordance with this Policy. If you believe that any information S Group holds about you is incorrect or incomplete, you may log into your account and correct your Personal Information yourself. If required by applicable law, you have the right to:

become familiar with the information S Group holds about you;

request the deletion of your Personal Information or part of it and withdraw your consent to the processing of your Personal Information;

request restrictions on the processing of your Personal Information;

request a copy of the Standard Contractual Clauses permitting the transfer of your Personal Information to the U.S. and set forth in Section 8 of this Policy;

object to the processing of your Personal Information if required by applicable law.

S Group will comply with such requests in accordance with applicable law. You may also have other rights not specified above where permitted by applicable law.

10.2 How You Can Exercise Your Rights

To exercise the above rights, please log in to your account, and if there is no special feature in the interface, contact the S Group team (see section 13 of this Policy).

If you are dissatisfied with the way S Group handles your Personal Information, please let us know and we will review your complaint. If you are not satisfied with the S Group team's response, you have the right to file a complaint with the competent authority.

11. How we use cookies and similar technologies on the Sites or when you use the Services

11.1 What cookies are and why S Group uses them

A cookie is a small piece of data that is received and processed by the device you use to access the Sites. Cookies store and send information back to the Sites that helps your experience on the Sites and allows us to remember your preferences over time, such as your browser settings or to recognize your account.

The following types of cookies are used on the Sites:

strictly Necessary Cookies / Technical Cookies: These cookies are essential to the operation of the Sites and to provide the Services to you; among other things, they allow S Group to identify your hardware and software, including your browser type;

statistical/analytical cookies: these cookies allow you to recognize users, count their number, and collect information such as the transactions you make on the Sites and Services, including information about the Web pages you visit and the content you receive;

technical cookies: these cookies collect information about how users interact with the Sites and/or Services, allowing you to identify errors and test new features to improve the performance of the Sites and Services;

functionality cookies: these cookies allow you to provide certain features to facilitate your use of the Sites, such as saving your preferences (such as language and location);

(third-party) tracking/advertising cookies: these cookies collect information about users, traffic sources, pages visited, and the ads displayed to you and that you clicked on to the advertised page. They allow you to display ads that may be of interest to you based on an analysis of Personal Information collected about you. They are also used for statistical and research purposes.

11.2 How long cookies are stored on your device

S Group uses the information contained in cookies only for the purposes specified above, after which the collected data will be stored on your device for a period, which may depend on the type of cookies involved, but no longer than necessary to achieve their purpose, after which they will be automatically deleted from your system.

11.3 Who else has access to the information contained in cookies

Personal information collected through cookies placed on your device may be shared and accessed by S Group and/or third parties described in Section 7 of this Policy. Use of Personal Information outside of the Sites for promotional purposes, if any, may be subject to separate user agreements available on third party websites. S Group and/or third parties may also offer you the opportunity to opt out of personalization of advertisements, which may be subject to the laws and regulations applicable to such products and offerings.

Your consent to the use of cookies may be requested when you first visit the Sites. If, after you have approved the use of cookies, you want to change your mind, you can do so by deleting the cookies stored by your browser (which can usually be done in your browser settings - please refer to your browser's manual or its developer's website). A pop-up window asking for your consent may then be displayed again, and you may be able to make a different choice. If you refuse to use cookies, it may cause some features of the Sites to be unavailable to you and may affect your ability to use the Sites. You can also change your browser settings to accept or reject by default all cookies or cookies from certain sites, including the S Group Sites. If you have approved the use of cookies on one of the S Group Sites, we will assume that you have approved the use of cookies on all S Group Sites.

S Group may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:

(i) detecting your activities on the Sites and while using the Services by accessing and using cookies stored on your device;

(ii) to collect statistical information related to the performance of the Sites, Services or S Group products, utilities and offerings.

12. Updating this Policy

This Policy may be amended. S Group has the right to make changes in its sole discretion, including, but not limited to, where relevant changes relate to changes in applicable law, and where relevant changes relate to changes in the operation of the Sites and Services.

S Group agrees not to make any material changes or impose additional burdens or limitations on your rights under this Policy without notice to you. You will be notified of such changes. Appropriate notices may be displayed on the Site or Services (for example, through a pop-up window or banner) before such changes take effect, or may be sent to you through other communication channels (for example, email, if you have provided us with your contact information).

13. Questions and suggestions

S Group welcomes your questions and suggestions regarding compliance with or changes to this Policy. Contact us at support@troywell.org