This Policy outlines the types of Personal Information that we gather about individuals, how we collect and make use of such data, including saving, processing and sharing the data with third parties (including those located in the United States), etc.
You are aware that your Personal Information, may be stored on Company’s database and you are not under any statutory or contractual obligation to provide us with your Personal Information. If you do not want us to collect, use, or share your information in the ways described in this Policy, you should not access or use the Services. If you do not provide us with your Personal Information as set out in this Policy, we may not be able to offer the Services to you.
By accessing or using the Services, you expressly acknowledge and agree to the terms of this Policy and that we will collect, use and share your Personal Information with third parties including, third parties located outside of the territory in which you reside or from which you contact us, in accordance with the provisions of this Policy.
By using the Services, you further acknowledge and agree that we will process and use your Personal Information in […][country of operations] and any other country where we operate. Please be aware that the privacy laws and standards in certain countries may differ from those that apply in the country in which you reside.
What is Personal Information?
"Personal Information" means any information that specifically identifies an individual such as a name, address, telephone number, mobile number, or e-mail address, or information about an individual that could be directly linked to such identifying information such as device IP address. Personal Information does not include “Usage Information” (meaning anonymous site usage information such as visit statistics, page views, device type, etc.), unless such information is connected to your Personal Information.
1. Information Collected on Our Services
1.1 Information you provide to us such as e-mail address;
1.2 Information collected by automated means on the Services.
2. How We Use your Personal Information
When you access or use the Services, we collect, use, share, and otherwise process your Personal Information as described in this Policy. We will use Personal Information and other information we collect through the Services:
2.1 to provide the Services and information you request;
2.2 to contact you about your use of the Services;
2.3 to respond to your emails, questions, comments and complaints;
2.4 to improve the Services;
2.5 to monitor and analyze usage information and otherwise measure the effectiveness of the Services;
2.6 to send you updates, security alerts, and support and administrative messages, to detect and prevent fraud, and to otherwise facilitate your use of, and our administration and operation of, the Services;
2.7 to deliver advertisements, content, or features to you;
2.8 to share information with business associates and partners, or other third parties.
If you are located in the EU, or where otherwise the GDPR is applicable, we collect Personal Information when we have legal bases as required under the GDPR. We may rely on a number of legal bases to use your Personal Information in these ways. These legal bases include where:
2.9 necessary to perform the contractual obligations in our Terms of Service;
2.10 necessary in order to provide the Services to you;
2.11 you have consented to the processing, which you can revoke at any time;
2.12 necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;
2.13 necessary for the purposes of our or a third party's legitimate interests;
2.14 you have made the information public;
2.15 necessary in the public interest; or
2.16 necessary to protect your vital interests, or those of others.
3. What Personal Information do we share with third parties?
We may share your Personal Information with third parties in the following circumstances:
3.1 Third Parties Providing Services on Our Behalf.
We may share your Personal Information with third parties that perform services on our behalf, such as companies that host or operate our Services; provide IT service, legal advisers, accountants, data analysis, marketing services, social media services, etc.
3.2 Legal Disclosure
We may transfer and disclose information, including your Personal Information, to third parties to comply with any legal obligation; at the request of governmental authorities conducting an investigation or otherwise requiring disclosure (including without limitation to meet law enforcement requirements and for the purposes of national security); to verify or enforce our Terms of Service; or to otherwise protect the rights, property, safety, or security of us, the public and/or other users and visitors of our Services.
3.3 Business Transfers
We may also share your Personal Information with our affiliated entities, business associates and partners or other third parties.
As we continue to develop our business, we may sell or purchase assets.
If another entity acquires us or all or a portion of our assets, Personal Information and any other information that we have collected through the Services may be disclosed to such entity as part of the due diligence process, and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours, and as such, may be sold or transferred to third parties.
4. Your Rights as Data Subject
You, the data subject, have the following rights:
If you are located in the EU, or where otherwise the GDPR is applicable:
· Right of access – you have the right to request a copy of the Personal Information that we hold about you.
· Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
· Right to restriction of processing – where certain conditions apply you may have a right to restrict the processing.
· Right of portability – you have the right to have the data we hold about you transferred to another organization.
· Right to object – you have the right to object to certain types of processing such as direct marketing.
· Right to withdraw consent - if you have given us your consent for the processing of your personal data, you may withdraw your consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If you withdraw your consent, we will only continue processing your Personal Information where there is another legal ground or where we are legally required to do so.
· Right to judicial review- in the event that we refuse any of your above-specified requests, we will provide you with a reason as to why. You have the right to complain as outlined in this Policy.
· Right to lodge a complaint with a supervisory authority - if you are not satisfied with our response or believe we are not processing your personal data in accordance with applicable privacy laws you have the right to lodge a complaint with the competent data protection supervisory authority.
If you are located outside of the EU and the GDPR is not applicable, your rights to review and amend your Personal Information will be in accordance with the provisions of privacy laws applicable in […] [country of operations].
5.2 We also use targeting cookies, including third-party service providers targeting cookies, to permit us and them to learn about what ads you see and click when you visit the Services, or to show you ads on and off Services.
5.3 Some cookies help provide performance data on how the Services are functioning in order to improve the Services and help us understand how the Services are used by our visitors.
The amount of time we will retain your Personal Information depends on why we collected it and how we use it. We won’t retain your Personal Information for longer than we are allowed under applicable law, and otherwise, will not generally retain your Personal Information for longer than is necessary to accomplish our business purposes and protect our legal rights.
7. Links to Other Sites
The Service may provide links to other websites that we do not own or operate. We do not control, recommend, or endorse, and are not responsible for, these websites or their content, products, services, or privacy practices.
8. How We Protect Personal Information
We implement reasonable administrative, organizational and technical safeguards and security measures to protect Personal Information. Please keep in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secured. As a result, we cannot promise or guarantee that such information will be immune from any wrongdoing, malfunction, unlawful interception or access, or other kinds of abuse and misuse. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section, below.
9. International Operations
The Services are operated globally. Please be aware that information we collect may be transferred to and processed in the United State or other territories. By using the Services or by providing us with any information, you acknowledge and agree to the collection, processing, maintenance, and transfer of such information in and to the United States and other territories in which the privacy laws may not be equivalent to those in the country where you reside and/or are a citizen.
11. Contact Us
If you have any concerns or questions about this Policy or about how we process your Personal Information, please contact us at […][link].
12. Governing Laws
Use of the Services, your interaction with us, and this Policy, is subject to the laws of […][territory]. The sole jurisdiction for any matter and/or dispute relating to issues of privacy regarding the Services, any content available through the Services and this Policy will be exclusively subject to the jurisdiction of the competent courts in […], […] [city, country].
Last Updated: April, 2023