Privacy policy

EFFECTIVE DATE 3 April, 2024

Click to review the previous version.

Note: The Privacy Policy has been updated. Please review the updated document carefully before using the Website. By using the Website, you consent to the terms of the updated Privacy Policy.

RESPONSIBLE

Responsible for the collection, processing and use of your personal data within the meaning of Art. 4 No. 7 GDPR and US data protection laws is –

hereinafter – “Company”, (more info about Us You can find by following this link).

If you wish to object to the collection, processing or use of your data by us in accordance with these data protection regulations as a whole or for individual measures, you can address us your objection.

Also, you can save and print out this Privacy Policy at any time.

GENERAL CONDITIONS

Our Company (“We,” “Us,” and “Our”) profoundly cares about the safety of its Users (“Clients,” “You,” and “Your”), as well as about the security of their private information. The Privacy Policy section here is destined to give You an overview of the information we need from you and about how it is protected from illegal use. We urge Our Clients to study the following Privacy Policy section before they pass on to the cooperation with Us.
You accept the following information about the Privacy Policy, as well as the Terms and Conditions. If You need additional information about the Privacy Policy issues, find Our Company’s contact information on the Website and get in touch with one of Our online specialists.

All personal data is collected and processed in compliance with the applicable data protection regulations of the United States of America, as well as the General Data Protection Regulation (GDPR).

AGE LIMITATIONS

We have no official right to collect any private information from persons who are not 18 yet. It is strictly prohibited to the Users under 18 to use Our Website and any of the Services offered by Our Company. As soon as We find out that the information presented by the User is not eligible because of the age limits, it will promptly be erased. We bear no responsibility in case if You’re not old enough to use the Website. You must be of legal age to be in line with Our Privacy Policy, as well as with Our Terms and Conditions.

Alert Us in case one of Your children under 18 is using Our Website trying to get access to our services. We’ll take measures to block access to Our Website from Your IP address. All affiliate websites cooperating with Our Company will be blocked for your child as well.

TYPES OF INFORMATION WE COLLECT

Our Privacy Policy is a part of the agreement between the User and Our Company that implies thorough protection of the data You share with Us. You agree with Our Privacy Policy, as well as with the Terms and Conditions in the process of registration. We protect personal information in Your account following the rules and regulations mentioned in this section.

Our Users must accept the conditions included in the current Privacy Policy section, thus giving Us their consent to:

• Track Your activity on Our Website;
• Collect the statistics about Your most preferred services;
• Use Your personal information to make Our Website safer and more productive.

Your acceptance of the Privacy Policy will become a legal basis for Us in case any inconveniences occur. We need certain types of information, which will be sufficient and in line with the Terms and Conditions of Our Website.

INFORMATION IN CONTACT FORM

You are obliged to share this data with Us in the process of communication with Us and in case any alterations are applied to the Privacy Policy or the Terms and Conditions. The necessary information We need includes the following:

• Your name;
• Relevant email address;
• Phone number;
• Your web-site.

The list can be longer depending on your wish to find the potential matching Services. The better the description You provide Us within your message, the more efficient our cooperation will be.

GEOLOCATION

We need the relevant information about Your geographical position to facilitate the process of order and payment for Our Services. When you enable Your geographic location, You start receiving more convenient and personalized offers with promotions, additional payment methods, and personalized advertisements for a more satisfying experience.

TECHNICAL INFORMATION

Technical information usually includes the following:

• The IP address and the name of your device, as well as the name of your browser and your device operating system;
• Times and dates of your online sessions;
• Activities on Our Website;
• Age and gender.

DATA OPTIMIZATION AND PERSONAL INFORMATION RENEWAL

The personal information that we collect and store can be accessed by the users and changed when needed. You can do the following to optimize and add new details to Your existing data:

• Make changes in Your personal information;
• Delete Your personal information or partially extend it;
• Contact our Support Team in case if you need help;
• Subscribe and unsubscribe from Our email notifications.

Note that in case If You unsubscribe from Our marketing offers sent via email, You will still be able to communicate with Our Management for marketing unrelated informational purposes.

PERSONAL INFORMATION USE AND DISCLOSURE

We do not use Your personal information for any other purposes except for the ones mentioned in this Privacy Policy section. We also never share Your data with third-party companies or people. This is considered illegal, and We have no rights to enforce the rules that do not correspond with the legislation of the state.

No one will be able to make changes in it except for You. Our Support Team can also access your personal information to verify your age, as well as the legacy of Your activity on Our Website and the online platforms of Our affiliates.

We rely on Your personal information to provide you with the marketing information and offers depending on your preferences.

We partially scan your data with the analytics tools and advertising services to find out about the effectiveness of Our work and the functionality of Our Website. We do this to improve our Customer Service and not to identify Our Clients personally.

We can use Your geographical location to help Our marketing and advertising partners post relevant advertisements on Our Website that will correspond with Your place of residence and Your needs.

We use Your contact information only for communication with Our Support Team. We will never share Your contact information with anyone who can use it for marketing or promotion purposes.

PERSONAL INFORMATION PROTECTION

We use HTTPS/TLS encryption to protect the personal information of Our Users. This technology guarantees 100% protection of Your data so that it will never be stolen or transferred anywhere without your permission.

Remember that We are not responsible for the breaches of security caused by Your irresponsible actions or Our service suppliers.

STORAGE TIME

We only store personal data for as long as is necessary to fulfill the purposes pursued. In some cases, the legislator provides for the storage of personal data, for example in tax or commercial law. In these cases, the data will only be stored by Us for these legal purposes but will not be processed in any other way and deleted after expiry of the legal retention period.

YOUR RIGHTS AS A DATA SUBJECT

According to the EU and US applicable laws, you have various rights regarding your personal data. If you wish to assert these rights, please send your request by e-mail or by post to the address specified in the section on the bottom of this Policy, clearly identifying yourself.

Right to acknowledgement and access

You have the right to receive confirmation from Us at any time as to whether personal data relating to you will be processed. If this is the case, you have the right to request from us free of charge information about the personal data stored about you together with a copy of this data. 

If personal data are transferred to a third country or an international organization, you have the right to be informed of the appropriate guarantees in accordance with GDPR and US data protection laws in connection with the transfer.

Right to correction

You have the right to request Us to correct any inaccurate personal data concerning you without delay. 

Right for cancellation (“Right for oblivion”)

As a pursuant under GDPR and US data protection laws, you have the right to demand that we delete personal data concerning you without delay, and we are obliged to delete personal data without delay if one of the following reasons applies:

1. personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
2. you file an objection to the processing pursuant to GDPR and US data protection laws, and there are no overriding legitimate grounds for the processing, or you file an objection to the processing pursuant under conditions of GDPR and US data protection laws.
3. you withdraw your consent, on which the processing was based pursuant according to GDPR and US data protection laws, and there is no other legal basis for the processing.
4. the deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which we are subject.

Right to limitation of processing

You have the right to request Us to restrict processing if one of the following conditions is met:

1. you dispute the accuracy of your personal data for a period of time that enables us to verify the accuracy of your personal data;
2. the processing is unlawful, and you have refused to delete the personal data and have instead requested the restriction of the use of the personal data;
3. We no longer need the personal data for the purposes of processing, but you do need the data to assert, exercise or defend legal claims, or
4. you have filed an objection against the processing pursuant according to GDPR and US data protection laws, as long as it is not yet clear whether the justified reasons of our company outweigh yours.

Right to transferability of data 

You have the right to receive the personal data concerning you that you have provided to us in a structured, current and machine-readable format, and you have the right to transmit this data to another person in charge without our interference, provided that:

1. processing is based on consent or on a contract pursuant according to conditions of GDPR and US data protection laws and
2. processing is carried out using automated methods. When exercising your right to data transferability in accordance with paragraph 1, you have the right to request that the personal data be transferred directly by us to another person responsible, insofar as this is technically feasible.

Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you on the basis of GDPR and US data protection laws; this also applies to profiling based on these provisions. We no longer process personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If We process personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising.

You have the right to object to the processing of personal data concerning you, for scientific or historical research purposes or for statistical purposes in accordance with GDPR and US data protection laws, for reasons arising from your particular situation, unless the processing is necessary to fulfill a task in the public interest.

Automated decisions including profiling

You have the right not to be subject to a decision based exclusively on automated processing – including profiling – that has legal effect against you or significantly impairs you in a similar manner. An automated decision making based on the collected personal data does not take place.

Right to revoke consent under data protection law

You have the right to revoke your consent to the processing of personal data at any time.

Right of appeal to a supervisory authority

You have the right of appeal to a supervisory authority.

In particular, if you have US residence, in the Member State where you are staying, working or suspected of having infringed the law, if you believe that the processing is unlawful.

Or, if you have EU/EEA residentship, and have a concern about our practices concerning the processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside or in which you work, or in which the alleged infringement occurred, each as applicable, or by contacting the authority for such issues by following the link.

NOTICE TO INDIVIDUALS IN THE STATE OF CALIFORNIA (USA)

Your Rights as a California Resident

As a California resident, you may have certain rights in relation to your personal information.

Right to Know

You may have the right to know how we have collected, used and disclosed your personal information. Specifically, you may have the right to know:

The categories of personal information we have collected about you.

The categories of sources from which we have collected your personal information.

The business or commercial purpose for which we collect, sell or share your personal information.

The categories of third parties to whom we have disclosed your personal information.

The categories of personal information that we disclosed for a business purpose and the categories of third parties to whom your personal information was disclosed for a business purpose.

The categories of personal information we have “sold” to or “shared” with  third parties and the categories of third parties to whom we have “sold” or “shared” your personal information.

You may have the right to know the specific pieces of personal information we have collected about you. 

Right to Make a Deletion Request

You may have the right to request that we delete your personal information that we have collected about you. Subject to certain exceptions, we must delete your personal information and direct any service provider or contractor to delete your personal information.

Right to Correct Inaccurate Personal Information

You may have the right to request that we correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Opt-Out of Sales of Personal Information

You may have the right to opt-out of the sale of your personal information.

Right to Opt-Out of Sharing of Personal Information

You may have the right to opt-out of us sharing your personal information for cross-context behavioral advertising purposes.

Right to Limit Use and Disclosure of Sensitive Personal Information

Subject to certain exceptions, you may have the right to limit our use and disclosure of your sensitive personal information. We do not use or disclose sensitive personal information in a manner that gives rise to this right.

Right to Non-Discrimination

You have the right to not be discriminated against by us for choosing to exercise your rights under the CCPA.

Other Rights: Notice to California Consumers

You have other rights under California’s “Shine the Light” law. California Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above, if you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes, please contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N 112, Sacramento, California 95834 or by telephone at (800) 952-5210 or (916) 445-1254.

Categories of Data that We Hold about You

As mentioned above, We maintain data about you in only pseudonymized form, which means that we do not know your identity because we do not process your name, email address, or other identifiable information. Instead, we only process digital identifiers such as cookie IDs, IP addresses, mobile advertising IDs on your device, network browsing history and associated preferences, and in some limited circumstances, your hashed email address.

Why We Collect Your Personal Information

We process your Personal Information in order to provide Services and personalized advertisements to You.

Where do We Collect Your Personal Information

We automatically collect User Information when Users interact with our Services that appear on our Customers’ websites and digital properties. Like most other web-based services, we collect this User Information through cookies and other technologies. We may also obtain Information about you from our data partners.

We collect Information either directly from you during your use of our Sites and Services or from third parties that independently collect this Information from you, and we may combine the Information that we collect from these various sources. For more information about these collection methods, please see Sections above.

How do We Share Your Personal Information

We may disclose or make available your pseudonymous Personal Information to our trusted partners. In most cases when we do so, we have contractually restricted their uses of this data for only Our business purposes. Under the CCPA, such disclosures of Personal Information to service providers are not deemed to be a “sale” and thus are not prohibited after you exercise your right to cease or restrict disclosures or sales of your Personal Information to third parties. In any instances where we have not entered into a service provider relationship with such third parties, we will stop sharing your Personal Information when you instruct us not to “sell” your Personal Information.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. 

According to CalOPPA we agree to the following: 

• Users can visit our site anonymously;
• Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website;
• Our Privacy Policy link includes the word ‘Privacy’, and can be easily found on the page specified above.

Users will be notified of any privacy policy changes on our Privacy Policy Page.

Users are able to change their personal information by emailing us.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.We do not specifically market to children under 13.

Fair Information Practices

• The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
• In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur
• We will notify the users via in site notification
• Within 7 business days

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

NOTICE TO INDIVIDUALS IN THE STATE OF VIRGINIA (USA)

Your Rights as a Virginia Resident

As a Virginia resident, you may have certain rights in relation to your personal data.

Right to Confirm

You may have the right to confirm whether we process your personal data and to access such personal data.

Right to Delete

You may have the right to request that we delete your personal data that we have collected about you. Subject to certain exceptions, we must delete your personal data.

Right to Correct Inaccurate Personal Data

You may have the right to request that we correct inaccurate personal data about you, taking into account the nature of the personal data and the purposes of the processing of your personal data.

Right to Opt-Out of Processing of Personal Data for Targeted Advertising

You may have the right to opt-out of the processing of your personal data for purposes of targeted advertising.

Right to Opt-Out of the Sale of Personal Data

You may have the right to opt-out of the sale of your personal data.

Right to Opt-Out of Profiling

You may have the right to opt-out of the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Obtain a Copy of Your Personal Data

You may have the right to obtain a copy of your personal data that you previously provided to us.

Right to Non-Discrimination

You have the right to not be discriminated against by us for choosing to exercise your rights under the VCDPA.

NOTICE TO INDIVIDUALS IN THE STATE OF COLORADO (USA)

Your Rights as a Colorado Resident

Right to Access

You have “the right to confirm whether a controller is processing personal data concerning the consumer and to access the consumer’s personal data.”

Right to Correction

You have “the right to correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data.”

Right to Delete

You  have “the right to delete personal data concerning the consumer.”

Right to Data Portability

You have “the right to obtain personal data in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hindrance.”

Right to Opt-Out

Consumers have “the right to opt-out of the processing of personal data concerning the consumer for purposes of:

• targeted advertising
• the sale of personal data
• profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.”

Right to Appeal

According to the Colorado Privacy Act regulations, Your request must be responded to within 45 days of receipt. The covered entity may subsequently extend that deadline by an additional 45 days if they are able to show reasonable necessity. However, when the deadline is extended, You must be notified by Us within the initial 45-day response period.

NOTICE TO INDIVIDUALS IN THE STATE OF UTAH (USA)

Your Rights as a Utah Resident

Right to access, including confirming whether a controller is processing their data, and the ability to request and receive that data;

Right to deletion of personal data, if the data subject directly provided the data to the controller;

Right to portability, obtaining a copy of their personal data that they provided to the controller, in a format that is:

• portable to a technically reasonable extent
• readily usable to a practical extent
• enables the consumer to transmit the data to another controller reasonably easily, where the processing is carried out by automated means.

Right to opt out of certain processing, specifically for the sale of the personal data or the purposes of targeted advertising;

Some rights that are present in other US state-level laws, but absent from the UCPA, include the right to opt out of profiling and the right to correct (to request and have omissions or inaccuracies in one’s personal data corrected).

We under the Utah privacy law are not required to recognize “universal opt-out signals” as a method for consumers to opt out of data processing.

NOTICE TO INDIVIDUALS IN THE STATE OF CONNECTICUT (USA)

Your Rights as a Connecticut Resident:

Right to access. You have the right to confirm whether or not a controller is processing Your personal data and access such personal data. However, there is an exception to this right where such confirmation or access would require the controller to reveal a trade secret.

Right to correct. You have the right to correct inaccuracies in Your personal data, taking into account the nature of the personal data and the purposes of the processing of Your personal data.

Right to delete. You also have the right to delete personal data provided by or obtained about You.

Right to data portability. You have the right to obtain a copy of Your personal data processed by the controller, in a portable and, to the extent technically feasible, readily usable format that allows You to transmit the data to another controller without hindrance, where the processing is carried out by automated means, provided such controller shall not be required to reveal any trade secret.

The type of data You have a right to obtain a portable copy of is particularly notable. The Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”) allows You to obtain a copy of the data a controller has processed about You regardless of how the controller acquired it.  

Right to opt out. You have the right to opt out of the processing of the personal data for the purposes of:

• targeted advertising,  
• the sale of personal data, or
• profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions;
• Process orders and to send information and updates pertaining to orders;
• We may also send you additional information related to your product and/or service.

To be in accordance with CAN-SPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses;
• Identify the message as an advertisement in some reasonable way;
• Include the physical address of our business or site headquarters;
• Monitor third party email marketing services for compliance, if one is used;
• Honor opt-out/unsubscribe requests quickly;
• Allow users to unsubscribe by using the link at the bottom of each email.

NOTICE TO THE CITIZENS OF CANADA

Data subjects with a residentship in Canada  have the following rights under the Privacy Act:

The right to access information – the right to both:

confirmation as to whether (or not) an agency holds information about that person; and access to such personal information, where such personal information may be readily retrieved.

The right to correction of information – the right to request correction of information. The agency must, on request or of its own initiative, take steps that are reasonable in the circumstances to ensure (having regard to the purposes for which the information may lawfully be used), the information is accurate, up to date, and not misleading.

In addition to the access and correction rights you may be entitled to exercise the right to:

object to the processing of your personal data (for instance, where we base the processing on our legitimate interests and we will stop processing your data. Except for processing related to direct marketing, we may resume processing if we can show legitimate grounds that override your rights;

request the restriction of processing of your personal data (for instance, if the data is not accurate and needs to be updated). This can also be done for data where the purposes of processing no longer apply, but you still need the data and do not want us to erase it;

request erasure of your personal data (for instance, if it’s no longer necessary for the purposes for which it was collected, if you have withdrawn consent or there is no other legal basis for processing, or if you have objected to the processing and our legitimate interests do not override your rights). Certain data may not be erased if we have a requirement to retain it for legal purposes;

request portability of your own personal data (the transfer of information you have provided to us, to another controller, in a structured, commonly used and machine-readable format), if such a request is technically possible to complete.

Also, according to Canadian legislation and specifically under both the Privacy Act (R.S.C., 1985, c. P-21) and the Personal Information Protection and Electronic Documents Act (PIPEDA) (S.C. 2000, c. 5, Assented to 2000-04-13), We collect personal information as defined by section 3 of the Privacy Act.

NOTICE TO THE CITIZENS OF NEW ZEALAND

Data subjects with a residentship in New Zealand have the following rights under the 2020 Act:

The right to access information – the right to both:

confirmation as to whether (or not) an agency holds information about that person; and access to such personal information, where such personal information may be readily retrieved.

The right to correction of information – the right to request correction of information. The agency must, on request or of its own initiative, take steps that are reasonable in the circumstances to ensure (having regard to the purposes for which the information may lawfully be used), the information is accurate, up to date, and not misleading.

Object to direct marketing – while there is not a specific right to object to direct marketing under the 2020 Act, it is worth noting that the Unsolicited Electronic Messages Act 2007 (‘UEMA’) prohibits the sending of unsolicited electronic messages (such as SMS or e-mail) for direct marketing purposes. Additionally, under the Telecoms Code, telecommunication information may only be used for direct marketing if the individual has been advised that such authorisation may be withdrawn at any time (Rule 10 of the Telecoms Code).

Rights not included in the 2020 Act

There is no express right to object to processing in New Zealand. If the information had yet to be provided by the individual, then she/he may refuse to provide the relevant information (provided it is being collected directly), or otherwise complain of an interference to privacy to either the OPC or the agency itself. 

Note that there is no broad right to data portability in New Zealand. For completeness, there is ‘number portability’ whereby local and mobile numbers may be transferred, which is regulated under different legislation outside the scope of this Guidance Note (the Telecommunications Act 2001).

Similarly, there is not a ‘right to be forgotten’ or ‘right to erasure’ in New Zealand. It is arguable that an individual may request their information to be corrected (as described above), and such a correction may constitute deletion of information, but this is not typically what is thought of when referring to a right to be forgotten. However, of note in this area is the Harmful Digital Communications Act 2015, which aims to deter, prevent, and mitigate harm to individuals caused by digital communications (often known as ‘cyber-bullying’), and provide victims with efficient means of redress. This can involve a court takedown order, requiring harmful digital communications to be removed.

The key legislation in New Zealand in relation to data protection that we use is Privacy Act 2020 (‘the 2020 Act‘). The 2020 Act empowers the Office of the Privacy Commissioner (‘OPC’) to issue codes of practice, which comprise part of the privacy law in New Zealand. The intention of these codes is to modify the operation of the act for specific types of information, or for certain industries. Separate to the 2020 Act, privacy principles can be found within New Zealand’s common law. The New Zealand courts have developed a tort of privacy (i.e. the right of one person to sue another for breach of privacy). The tort of privacy relates to the public disclosure of private facts, where such disclosure would be considered to be highly offensive to a reasonable person of ordinary sensibilities, balanced against the wider public interest (Bradley v. Wingnut Films Ltd [1993] 1 NZLR 415).

NOTICE TO THE CITIZENS OF AUSTRALIA

The Australian Privacy Principles (or APPs) are the cornerstone of the privacy protection framework in the Privacy Act 1988 (Privacy Act). They apply to any organization or agency the Privacy Act covers.

There are 13 Australian Privacy Principles and they govern standards, rights and obligations.

The Privacy Act regulates the way individuals’ personal information is handled.

As an individual, the Privacy Act gives you greater control over the way that your personal information is handled. The Privacy Act allows you to:

• know why your personal information is being collected, how it will be used and who it will be disclosed to;
• have the option of not identifying yourself, or of using a pseudonym in certain circumstances;
• ask for access to your personal information (including your health information);
• stop receiving unwanted direct marketing;
• ask for your personal information that is incorrect to be corrected;
• make a complaint about an organization or agency the Privacy Act covers, if you think they’ve mishandled your personal information.

NOTICE TO THE CITIZENS OF BRAZIL

The provisions contained in this section apply to all Users who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

• your consent to the relevant processing activities;
• compliance with a legal or regulatory obligation that lies with us;
• the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymized personal information;
• the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
• the exercising of our rights in judicial, administrative or arbitration procedures;
• protection or physical safety of yourself or a third party;
• the protection of health – in procedures carried out by health entities or professionals;
• our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
• credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

You have the right to:

• obtain confirmation of the existence of processing activities on your personal information;
• access to your personal information;
• have incomplete, inaccurate or outdated personal information rectified;
• obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
• obtain information on the possibility to provide or deny your consent and the consequences thereof;
• obtain information about the third parties with whom we share your personal information;
• obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• revoke your consent at any time;
• lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
• when the transfer is necessary to protect your life or physical security or those of a third party;
• when the transfer is authorized by the ANPD;
• when the transfer results from a commitment undertaken in an international cooperation agreement;
• when the transfer is necessary for the execution of a public policy or legal attribution of public service;
• when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

COOKIES

We use so-called session cookies to optimize our website. A session cookie is a small text file that is sent by the respective servers when you visit a website and stored temporarily on your hard drive. This file as such contains a so-called session ID, with which you can assign various requests of your browser to the common session. This will allow your computer to be recognized when you return to our website. These cookies are deleted after you close your browser. 

We also use persistent cookies to a small extent, which remain on your terminal device and enable us to recognize your browser the next time you visit. These cookies are stored on your hard disk and are deleted automatically after the specified time. Their life span is 1 month to 10 years. This enables Us to present our services to you in a more user-friendly, effective and secure manner and, for example, to display information on the site that is specifically tailored to your interests.

Our legitimate interest in the use of cookies pursuant to GDPR is to make our website more user-friendly, effective and secure.

The following data and information are stored in the cookies:

• Language settings;
• Geo-data;
• Age;
• Gender;
• Device and operational system of device you use to enter Our website;
• Entered search terms
• Information about the number of visits to Our website and use of individual functions of the website.

When the cookie is activated, it is assigned an identification number and your personal data is not assigned to this identification number. Your name, IP address or similar data that would allow the cookie to be assigned to you will not be placed in the cookie. Based on the cookie technology, we only receive pseudonymous information, for example about which pages of our website were visited, which products or offers were viewed, etc.

You can set your browser so that you are informed in advance about the setting of cookies and can decide in individual cases whether you want to exclude the acceptance of cookies for certain cases or in general, or that cookies are completely prevented. This may limit the functionality of the website.

GOOGLE-ANALYTICS

We use Google Analytics, a web analysis service of Google Inc. “(“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about the use of this website by page visitors is usually transferred to a Google server in the USA and stored there.

This is also our legitimate interest pursuant to GDPR and US data protection laws.

Google has signed and certified itself under the Privacy Shield Agreement between the European Union and the USA. By doing so, Google undertakes to comply with the standards and regulations of European data protection law.

The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, note that if you do this you may not be able to use the full functionality of this website.

You can also prevent the transmission to Google of data generated by the cookie and relating to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing the browser plug-in.

VISITORS BEHAVIOR PATTERNS

We study the behavior patterns of Our Users and track the number of people in different parts of the Website. We do not identify the Users in any way, and this process is performed to analyze Our work and the work of the Website elements.

PRIVACY POLICY POSSIBLE CHANGES

We reserve the right to change the Privacy Policy section and add more information to it. We are not obliged to notify the Users about the changes applied to the current Privacy Policy. It means that the Users are to check this section for themselves to find out more about the way their personal information is protected.

CONTACT US

Click here to contact us regarding this Privacy Policy or other related Privacy issues.