Effective as of 20 September 2021
We ("we," "us," "our(s)") take the privacy of users' ("users" or "you") information on our website and mobile app (the "Website" and the "Mobile App," respectively) very seriously and are committed to protecting the information users provide to us in connection with their use of our Website and/or Mobile App (collectively, "Digital Assets"). Further, we are committed to protecting and using your information in accordance with applicable law.
What data do we collect?
Below is an overview of the data we may collect (pursuant to Article 6(1)(a) of the GDPR):
Non-identified and non-identifiable information that you provide during the registration process or that is collected through the use of our services ("non-personal data"). Non-Personal Data does not identify who it was collected from. Non-Personal Information that we collect consists primarily of technical and aggregate usage information.
Individually Identifiable Information, which is any information that can be used to identify you or could be used to identify you with reasonable effort ("Personal Data"). Personally Identifiable Information we collect through our Services may include information requested from time to time, such as names, email addresses, location, phone numbers, IP addresses, and more. When we combine personal data with non-personal data, as long as you are in combination, we will treat it as personal data.
How do we collect the data?
Below are the main methods we use to collect data:
We collect data when you use our services. So, when you visit our digital assets and use services, we may collect, record and store usage, sessions and related information.
We collect data that you provide to us yourself, for example, when you contact us directly through a communication channel (such as an email with a comment or feedback).
We may collect data from third-party sources, as described below.
We collect data that you provide to us when you sign in to our Services through a third-party provider, such as Facebook or Google.
Why do we collect this data?
We may use your data for the following purposes (pursuant to Art. 5(1)(b) DSGVO):
to provide and operate our services;
to develop, adapt and improve our services;
to respond to your feedback, inquiries and requests and to provide assistance;
to analyze request and usage patterns;
for other internal, statistical and research purposes;
to improve our data security and fraud prevention capabilities;
to investigate breaches and enforce our terms and policies, and to comply with applicable law, regulation or governmental requests;
to provide advertising through our services and digital assets, which may include ads tailored to you, such as ads based on your recent website, device or browser browsing behavior;
To provide you with updates, news, promotional materials and other information related to our Services. For promotional emails, you can choose whether you want to continue receiving them. If not, simply click on the unsubscribe link in these emails.
How do we use your personal data?
the use of your personal data is necessary to perform or enter into a contract (for example, to provide you with the Services themselves or customer service or technical support);
the use of your personal data is necessary to comply with relevant legal or regulatory obligations; or
the use of your personal data is necessary to support our legitimate business interests (provided that at all times this is done in a way that is proportionate and respects your data protection rights).
As an EU resident, you may (pursuant to Article 13(2)(b) of the GDPR):
request confirmation as to whether or not personal data concerning you is being processed and request access to your stored personal data and certain additional information;
request the receipt of personal data that you have provided to us in a structured, commonly used and machine-readable format;
request the correction of your personal data stored by us;
request the deletion of your personal data;
object to the processing of your personal data by us;
request the restriction of the processing of your personal data; or
File a complaint with a supervisory authority.
Please note, however, that these rights are not unlimited and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal information we collect and how we use it, please contact us as indicated below.
In the course of providing the Services, we may transfer data across borders to affiliates or other third parties and from your country/jurisdiction to other countries/jurisdictions around the world. By using the Services, you consent to the transfer of your data outside the EEA.
If you are located in the EEA, your personal data will only be transferred to locations outside the EEA if we are satisfied that there is an adequate or comparable level of protection for personal data. We will take appropriate steps to ensure that we have adequate contractual arrangements in place with our third parties to ensure that appropriate safeguards are in place so that the risk of unlawful use, alteration, deletion, loss or theft of your personal data is minimized and that such third parties act at all times in accordance with applicable laws.
Who do we share this data with?
We may share your information with our service providers to operate our services (e.g., storing data via third-party hosting services, providing technical support, etc.).
We may also disclose your information in the following circumstances: (i) to investigate, detect, prevent, or take action regarding illegal activities or other misconduct; (ii) to establish or exercise our rights to defend ourselves; (iii) to protect our rights, property, or personal safety and the safety of our users or the public; (iv) in the event of a change of control of us or any of our affiliates (by way of a merger, acquisition or purchase of (substantially all of) our assets, et al. a.); (v) to collect, maintain and/or manage your information through authorized third party vendors (e.g., cloud service providers) as appropriate for business purposes; (vi) to work with third party vendors to improve your user experience. For the avoidance of doubt, we would like to point out that we may transfer or disclose non-personally identifiable information to third parties or otherwise use it at our discretion.
We will not share your email address or other personally identifiable information with advertisers or advertising networks without your consent.
When you visit or access our Services, we authorize third parties to use web beacons, cookies, pixel tags, scripts, and other technologies and analytics services ("Tracking Technologies"). These Tracking Technologies may allow third parties to automatically collect your information to improve the navigation experience on our digital assets, optimize their performance and provide a customized user experience, as well as for security and fraud prevention purposes.
Where do we store the data?
Personal data may be maintained, processed and stored in other jurisdictions for the proper provision of our services and/or as required by law (as further explained below).
How long will the data be retained?
Please note that we retain the data we collect for no longer than is necessary to provide our services, to comply with our legal and contractual obligations to you, to resolve disputes, and to enforce our agreements.
We may correct, amend or delete inaccurate or incomplete data at any time at our sole discretion.
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other regulations to which the responsible party is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or performance of a contract.
How do we protect the data?
The hosting service for our digital assets provides us with the online platform through which we can offer you our services. Your data may be stored via our hosting provider's data storage, databases and general applications. It stores your data on secure servers behind a firewall and it provides secure HTTPS access to most areas of its services.
Notwithstanding the measures and efforts taken by us and our hosting provider, we cannot and do not guarantee absolute protection and security of the data you upload, post or otherwise share with us or others.
For this reason, we ask that you establish strong passwords and, whenever possible, do not provide us or others with confidential information that you believe could cause you significant or lasting harm if disclosed. In addition, because e-mail and instant messaging are not considered secure forms of communication, we ask that you do not share confidential information through either of these communication channels.
If you have general questions about the Services or the information we collect about you and how we use it, please contact us at: