EFFECTIVE DATE 2 May, 2022
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 can find at: https://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspx ).
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.
Our Company (“We,” “Us,” and “Our”) profoundly cares about the safety of its Users (“Members,” “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).
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.
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:
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.
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:
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.
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 usually includes the following:
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:
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.
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.
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.
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.
According to the 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.
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.
You have the right to request Us to correct any inaccurate personal data concerning you without delay.
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:
You have the right to request Us to restrict processing if one of the following conditions is met:
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
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.
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.
You have the right to revoke your consent to the processing of personal data at any time.
You have the right of appeal to a supervisory authority.
In particular, if you have US residentship, 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, at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
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:
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.
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.
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.
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.
California residents have the right to request that We (i) provide you with access to the Personal Information that we hold about you, (ii) correct your Personal Information, (iii) delete your Personal Information, and (iv) cease or restrict disclosures or sales of your Personal Information to third parties. You also have a right against discrimination for exercising any of these rights, which We are committed to upholding and honoring at all times.
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.
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.
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.
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 will be notified of any privacy policy changes on our Privacy Policy Page.
Users are able to change their personal information by emailing us.
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
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.
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:
To be in accordance with CANSPAM we agree to the following:
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:
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.
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).
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).
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:
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).
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
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:
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
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.
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: