Privacy Policy
1.General information
2.Definitions
3.The subject of the agreement
4.Principles of data processing
We follow all necessary principles to protect your Personal Data.
4.1 According to the current legislation of United states of America and Art. 5 of the General Data Protection Regulation (GDPR), we adhere to the following principles to protect your privacy:
4.1.1 Principle of lawfulness, fairness, and transparency – we process Personal data lawfully, fairly, and transparently concerning the data subject.
4.1.2 Principle of purpose limitation – we collected personal data for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
4.1.3 Principle of data minimization – we collect adequate personal data, relevant and limited to what is necessary concerning the purposes for which we are processed personal data.
4.1.4 Principle of data accuracy – we accurate personal data and, where necessary, keep up to date. We take every reasonable step to ensure that inaccurate personal data, having regard to the purposes for which they are processed, are erased or rectified without delay.
4.1.5 Principle of storage limitation – we keep personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
4.1.6 Principle of integrity and confidentiality – we process personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical or organizational measures.
5.Personal data that we collect and process
6.Lawful basis of data processing
We process your Personal Data in accordance with the current legislation of the united states of america, the rules applicable to you and the generally recognized principles and norms of international law.
6.1 The personal data of the Subjects are processed in accordance with the generally recognized norms of international law, the laws of the united states of America, as well as the norms applicable to you, including but not limited to:
6.1.1 If you are located in the European Union (EU) privacy rights are granted and all processing of Personal Data is performed by regulations and rules following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”).
6.1.2 If you are located in the United Kingdom, all processing of Personal Data is performed in accordance with regulations and rules following the Data Protection Act 2018 (“DPA 2018”) and UK General Data Protection Regulation (“UK GDPR”).
6.1.3 If you are located in Australia, all processing of Personal Data is performed in accordance with regulations and rules following the Privacy Act 1988.
6.1.4 If you are located in Canada, all processing of Personal Data is performed in accordance with regulations and rules following Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”).
6.1.5 If you are located in New Zealand, all processing of Personal Data is performed in accordance with regulations and rules following Privacy Act 2020.
6.1.6 If you are located in California, all processing of Personal Data is performed in accordance with regulations and rules following the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”).
6.1.7 If you are located in Brazilia, all processing of Personal Data is performed in accordance with regulations and rules following the Lei Geral de Proteção de Dados (“LGPD”).
6.2 Children’s Online Privacy Protection Act («COPPA») applies to the online collection of personal information by persons or entities under U.S. jurisdiction about children under 13 years of age, including children outside the U.S. (affected person). Data Subjects need to obtain parental consent before providing Personal Data on the Site. If you are a parent or a guardian of a COPPA affected person, you may consent to the collection and use of your COPPA affected person’s information. You may withdraw your consent, review your COPPA Personal Data of your subject, ask for it to be deleted and/or not to allow further collection or use of your COPPA data subject at any time by contacting us at: [email protected].
6.3 We process Personal Data as an Operator as specified in Art. 4 GDPR.
7.The purpose of data processing
8.Consent to personal data processing
We obtain your consent before personal data processing
8.1 Consent to Personal Data Processing
8.1.1. By accepting this Privacy Policy, you approve to have reached the age of majority or the legal age in your jurisdiction (generally 18 or older), are solely responsible for all your actions, and fully understand the statements, outlined in this Privacy Policy.
8.2 EU Persons Consent to Personal Data processing
8.2.1 If you are an EU Person and to process your Personal Data We need to receive your consent, as it is prescribed by GDPR, We will process your Personal Data only in the case We have received from you a freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data (“Consent”).
8.2.2 You may give your consent by ticking the respective box when you register for an account with our Service. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that We shall be entitled to process your Personal Data as it is indicated by your Consent.
8.2.3Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, your Consent should be deemed given for all of them.
8.3 Non-EU Persons Consent to Personal Data processing
8.3.1 If you are not an EU Person, by transferring to Us your Personal Data via the Software or otherwise, you irrevocably and unconditionally consent and agree that We shall be entitled, in accordance with this Policy:
to process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), your Personal Data so provided to Us, as well as your Personal Data collected from your use of the Service (i.e. your Personal Data which We collect automatically and/or from other sources); and
to use cookies and web beacons (pixel tags) to collect your Personal Data.
9.The rights of subjects
Please read this chapter carefully. To exercise any of the above-mentioned rights, You should primarily send a request to our Support Service. We may request additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.
9.1 Right to access. You may contact us to get confirmation as to whether or not we are processing your personal data. When we process your personal data, we will inform You of what categories of personal data we process regarding You, the processing purposes, the categories of recipients to whom personal data have been or will be disclosed, and the envisaged storage period or criteria to determine that period.
9.2 Right to withdraw consent. In case our processing is based on the consent granted, You may withdraw the consent at any time by contacting us or by using the functionalities of the Website. You can withdraw your consent at any time by replying to the email with your withdrawal and your Personal Data will be deleted immediately. Withdrawing consent may lead to fewer possibilities to use the Website and/or the Services
9.3 Right to object. In case our processing is based on a legitimate interest to run, maintain and develop our business, You have the right to object at any time to our processing. We shall then no longer process your personal data unless for the provision of our services or if we demonstrate other compelling legitimate grounds for our processing that override your interests, rights, and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, You have the right to prohibit us from using personal data for direct marketing purposes, by contacting us or by using the functionalities of the Website, or unsubscribe possibilities in connection with our direct marketing messages.
9.4 Right to restriction of the processing. You have the right to obtain from us restriction of processing of your personal data, as foreseen by applicable data protection law, e.g. to allow our verification of the accuracy of personal data after you contest the accuracy or to prevent us from erasing personal data when personal data are no longer necessary for the purposes but still required for your legal claims or when our processing is unlawful. Restriction of processing may lead to fewer possibilities to use the Website and/or the Services.
9.5 Right to data portability. You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format and to independently transmit those data to a third party, in case our processing is based on your consent and carried out by automated means.
10.Data storing and deletion
We store your Personal Data for as long as needed to provide you with our Service and/or opportunity to use our Website.
10.1 We store your Personal Data for as long as needed to provide you with our Service and/or opportunity to use our Website. We may store Data longer, but only in a way that it cannot be tracked back to you. When Personal Data is no longer needed, we delete it using reasonable measures to protect the Data from unauthorized access or use.
10.2 EU Territory. We store Personal Data as long as it is needed for the provision of our Services and/or opportunity to use our Website. Traffic information is erased or made anonymous when it is no longer needed for the transmission or, in the case of payable Services, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Direct marketing and provision of value-added Service information (including traffic information used for these purposes) are stored as long as the same is necessary for the provision of these activities, or up to the time when a User opts out from such use under this Privacy Policy. Other information is stored for as long as we consider it to be necessary for the provision of our Service and/or opportunity to use our Website. This Section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary for us to provide the Service you requested. As explained in the GDPR statement, We strive to anonymize the data when possible. If you decide to exercise your right to erasure, We will also inform our providers to delete all your data.
10.3 US Territory. We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.
10.4 Storing might be different depending on the territory of collecting the information and the applicable legislation, but We always strive to store the information only as long as it is needed to provide, improve, or personalize our Service.
10.5 We do not intentionally collect or maintain information from persons under the age of 13. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. If you believe that we may have any information about children under the age of 13, please contact our Support Service [email protected] .
11.Data security
We care to ensure the security of Personal Data.
11.1 We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When We or our contractors process your information, We also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is done through appropriate administrative, technical, and physical measures.
11.2 You agree that there is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, We cannot guarantee its absolute security.
11.3 We never process any kind of sensitive data such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data processed solely to identify a human being, health-related data, data concerning a person’s sex life or sexual orientation, criminal offense data.
12.Contractors
We work with third-party services providers, who provide website, application development, hosting, maintenance, and other services for us. All data transfers are performed in accordance with the highest security regulations.
12.1 We work with third-party services providers, who provide website, application development, hosting, maintenance, and other services for us. They may be located outside of the EEA. These contractors may have access to, or process Personal Data on behalf of Us as part of providing those services for Us. We limit the information provided to these Service providers to that which is reasonably necessary for them to perform their functions.
12.2 All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the European Union may be possible only in the case when We have obtained your consent for it.
12.3 All data processed by Us is stored exclusively in secure hosting facilities located in the EU.
12.4 We use a third-party payment processor, currently <Paddle, Stripe> (“Payment Processors”) to assist in securely processing your payment information. If you pay with a credit card the payment information that you provide through the Services is encrypted and transmitted directly to the Payment Processor. We do not store your Payment Information and do not control and are not responsible for the Payment Processors or their collection or use of your information. You may find out more about how the Payment Processors store and use your Payment Information by accessing the Payment Processors Privacy Policy.
12.5 We may share your personal data with our insurers, our professional advisors (lawyers, bankers, auditors, corporate financiers, and brokers) in connection with the services they provide to us. If we share your personal data with those processors, we will require the recipient to keep it confidential and secure. To provide you (or your organization) with our services, we may provide personal data to the courts, to lawyers advising the other parties to a matter, or other professionals (such as overseas law firms, patent agents, forensic accountants, or barristers).
12.6 We use Facebook. to measure and increase the effectiveness of our advertising campaigns. For more information on the privacy practices of the Facebook, please visit the Privacy Policy: https://www.facebook.com/business/m/privacy-and-data.
12.7 We use Google Analytics to create detailed statistics of website users. The statistics are collected on Google’s server; the User only places JS code on the pages of his or her site. The tracking code is triggered when the User opens the page in his or her web browser. For more information on the privacy practices of Google Analytics, please visit the Privacy Policy: https://policies.google.com/privacy?hl=en-US s-privacy-policy/.
12.8 We use Yandex Metrika to evaluate website traffic and analyze User’s behavior. For more information on the privacy practices of Yandex Metrika, please visit the Privacy Policy: https://metrica.yandex.com/about/info/privacy-policy.
13.Other provisions