I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)
When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data. It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.
For the purposes of the GDPR, we are the data controller, unless otherwise stated.
IF YOU ARE A CALIFORNIA RESIDENT PLEASE READ THE FOLLOWING IMPORTANT NOTICE
Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request:
- the categories of personal information that is processed;
- the categories of sources from which personal information is obtained;
- the purpose for processing of user personal data;
- the categories of third parties with whom we may share your personal information;
- the specific pieces of personal information that we might have obtained about particular user provided that the data given in the request is reliable enough and allows us to identify the user.
Please mind that according to CCPA personal information does not include de-identified or aggregated consumer information.
Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.
If you don’t want us to collect and/or process your information any more please contact us at firstname.lastname@example.org. Note that if you decide to opt out of data collection and processing this can affect some Website functions and you may not be able to use all features of the Website to the fullest extent possible.
To submit a verifiable consumer request for access, portability or deletion of personal data please contact us at email@example.com. Please include in the text of your appeal the wording “Your rights to maintain confidentiality in the state of California”.
When submitting a verifiable request, you should be ready to:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request. We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.
Nothing in the way we deal with your request shall be interpreted as discrimination, which means that we will not set up different pricing or products, or different level or quality of services for you, if you choose to exercise your rights. However, in some circumstances, we may not be able to provide services if you choose to delete your personal information from our records.
SALE OF DATA
We do not sell any of your personal data to third parties.
II. INFORMATION WE PROCESS
There are several categories of information that may be processed when you access and/or use the Website.
Information that you voluntarily provide to us
We may collect, store and process some information about you when you use the form available within the “Contact us” section on the Website (hereinafter, “Contact us” form). In particular, if you decide to make a request via the “Contact us” form, the following categories of information are voluntarily provided by you: your name, email address, the text of your message and/or any files that you optionally choose to attach to your request. We use the services of Amazon Web Services, Inc. (a subsidiary of Amazon.com Inc.) or of Advanced Hosters B.V. in order to collect, store and process the information that you provide us via the “Contact us” form. We use the information submitted by you via the “Contact us” form solely for the purpose of considering and responding to your requests (if necessary).
Information that is processed automatically
When you access and/or use the Website, some information about your device and your user behavior may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our Website and giving our users the best experience. If we do not access such data we may not be able to provide you with all features of the Website.
We use third-party automatic data processing technologies to analyze certain information sent by your device via our Website (analytics or advertising tools). Some of them may launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first time access the Website.
Device Details. When you use a device (computer, laptop / tablet / phone) to access our Website, some details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your device, which uniquely identify your device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.
What data can be processed:
- Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.
- Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser and version, browser language.
- Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone.
- Device identifiers: advertising identifiers, Identity For Advertisers for iOs devices/ Advertising ID or Android ID for Android devices.
Log file information. Log file information is automatically reported each time you make a request to access the Website. When you use our Website, analytics tools automatically record certain log file information, including time and date when you start and stop using the Website, and how you interact with the Website.
Information provided automatically to analytics or advertising tools does not generally come to our control, therefore, we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility.
III. THE PURPOSES OF PROCESSING YOUR DATA
Our mission is to constantly improve our Website and provide you with better user experiences. As part of this mission, we use your information for the following purposes:
(a) To improve, test and monitor the effectiveness of our Website. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our Website.
(b) To communicate with you. We may use information that you voluntarily provide to us via the “Contact us” form available on the Website for the purposes of processing and responding (if necessary) to your requests, receiving your feedback, comments or suggestions about the Website or on other matters.
IV. SHARING YOUR INFORMATION
We will not rent or sell your personal data to third parties, but we may share your information obtained via tools like cookies, log files, and device identifiers with third-party organizations that provide automatic data processing technologies for the Website. We do not control or influence these third parties’ tracking technologies or how they may be used.
Please note that while we partner solely with third parties that gave us assurance of application of necessary technical and organizational measures to protect your data, we cannot guarantee the security of any information transmitted from the Website directly to such third parties. We are not responsible for any accidental loss or unauthorized access to your data through a fault of third parties.
We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of our Website:
|Advanced Hosters B.V.||Cloud service provider||Netherlands||https://advancedhosting.com/en/documents/privacyPolicy|
|Amazon Web Services, Inc. (a subsidiary of Amazon.com Inc.)||Cloud storage provider||U.S.A.||https://sell.amazon.com/privacy.html?ref_=asus_soa_rd& |
Data Privacy FAQ:
|Facebook Inc.||Analytics and marketing service provider||U.S.A.||https://www.facebook.com/privacy/explanation|
|Google LLC||Google Analytics (tool for analysing Website traffic)|
Google reCAPTCHA (analytics engine for protection the Website from fraud and abuse, protection of Website users from bots)
How Google uses information from sites or apps that use its services:
https://support.google.com/analytics/answer/6004245 (see section ‘Information for Visitors of Sites and Apps Using Google Analytics’)
Yandex.Metrica Data Processing Agreement:
As it is indicated above we use such services as Google Analytics and Yandex.Metrica that track and report the Website traffic. Both services use different types of cookies to analyze user activity. If you want to learn more about the categories of data collected and processed by analytics service providers please consult the corresponding websites of Google Analytics and Yandex.Metrica as well as their privacy policies and other documents concerning data protection. Note that we are not responsible for any usage of your data by the abovementioned third-party service providers in violation of our instructions.
Our Website may contain links to third party sites/services. You also may visit the Website following a link from a third party site. We are not responsible for the privacy practices of these third-party sites or services linked, including for the information or content contained within them (unless we are the providers of those sites and/or services).
We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:
- as required by law;
- when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;
- in some cases, we may share your information with our affiliates, subsidiaries, contractors, business partners or other third parties who perform services on our behalf.
V. INTERNATIONAL DATA TRANSFERS
We work in the cross-border area and provide our Website to Users around the world.
We and third-party organizations that provide automatic data processing technologies for the Website or our third-party partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that may not have the same data protection laws as in your home jurisdiction. We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information.
By using the Website, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.
VI. HOW DO WE STORE YOUR DATA
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data – if possible – before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.
In particular, we recourse to the services of Amazon Web Services, Inc. (a subsidiary of Amazon.com Inc.) and/or of Advanced Hosters B.V. that have adopted technical and organizational measures to protect your personal data against unauthorized/unlawful processing and accidental loss, destruction or other damage.
VII. HOW LONG WE USE YOUR PERSONAL DATA
However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) with a purpose of compliance with certain legal obligations (such as taxation, accounting, audit), maintenance of safety and data backup settings or prevention of fraud or other malicious acts.
VIII. EXERCISING YOUR RIGHTS
Applicable data protection laws give you certain rights regarding your personal information. You have the following rights in relation to your personal information that was collected:
- Data Access and Portability. You can request copies of your personal information.
- Change or Correct Data. Where you cannot update data by yourself, you have the right to ask to correct, change, update or rectify your data.
- Data Retention and Deletion. Specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
- Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.
To exercise any of the rights described above, you can contact us at firstname.lastname@example.org. Please bear in mind that we ensure the above mentioned rights only with respect to the information that we physically access and store. We also would like to draw your attention to the fact that in order to process your request we first have to identify you as a user of our Website.
If you are located in the European Union, you may address our representative when you have questions on privacy issues:
Albina Gulevich Apolskaya, Office: 35, 205 Holland Park Avenue, W11 4XB, London, e-mail: user.data.protection @ gmail.com
IX. HOW TO OPT OUT
You may prevent and/or manage the collection and processing of data related to your use of the Website following the instructions provided below.
Google Analytics. If you want to opt-out of being tracked by Google Analytics you can install and enable Google Analytics Opt-out Browser Add-on. Additionally, you can manage cookies and/or delete cookies already set by Google Analytics through your browser settings. Further information on Google Analytics’ data practices and relevant instructions can be found at https://support.google.com/analytics/answer/6004245 (see section ‘Information for Visitors of Sites and Apps Using Google Analytics’).
Bear in mind that if you choose to disable all cookies, this can affect the Website functions, some of the features that make the Website more efficient may not function.
The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information provided to us, both during transmission and once we receive it.
We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.
If you have any questions about the security of our Website, you can contact us at email@example.com.
XI. CHILDREN’S PRIVACY
Our Website is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under the age of 18 may provide any personal information to the Website. If you are under 18, do not use or provide any information on this Website or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under the age of 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.
In case we change our Policy, we will post the changes on this page. Please check our Website regularly for any changes.
XIII. HOW TO CONTACT US