Privacy Policy
Effective date: 14/09/2023
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Introduction
We take the protection of the data of the users of our website and our mobile app (the "website" or the "mobile app") very seriously and are committed to protecting the information that users provide to us in connection with the use of our website and our mobile app (together: "digital assets"). Furthermore, we are committed to protecting and using your data in accordance with applicable law. This Privacy Policy explains our practices regarding the collection, use, and disclosure of your data through the use of our digital assets (the "services") when you access the services via your devices. Please read the Privacy Policy carefully and ensure that you fully understand our practices regarding your data before using our services. If you have read this policy, fully understood it, and do not agree with our approach, you must discontinue the use of our digital assets and services. By using our services, you acknowledge the terms of this Privacy Policy. Continued use of the services constitutes your consent to this Privacy Policy and any changes to it. In this Privacy Policy, you will learn:
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How we collect data
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What data we collect
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Why we collect this data
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To whom we disclose the data
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Where the data is stored
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How long the data is retained
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How we protect the data
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How we deal with minors
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Updates or changes to the Privacy Policy
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How do we collect data?
Below are the main methods we use to collect data:
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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.
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We collect data that you provide to us, for example, when you contact us directly through a communication channel (e.g., an email with a comment or feedback).
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As described below, we may collect data from third-party sources.
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We collect data that you provide to us when you sign up for our services through a third-party provider such as Facebook or Google.
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What data do we collect?
Below is an overview of the data that we may collect:
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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 allow any conclusions as to who it was collected from. The non-personal data we collect mainly consists of technical and aggregated usage information.
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Individually identifiable information, i.e., any information by which you could be identified or could reasonably be identified (“personal data”). The personal data that we may collect through our services can include information that is requested from time to time, such as names, email addresses, addresses, telephone numbers, IP addresses, and more. If we combine personal data with non-personal data, as long as they are combined, we will treat them as personal data.
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Why do we collect this data?
We may use your data for the following purposes:
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to provide and operate our services;
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to develop, customise, and improve our services;
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to respond to your feedback, requests, and inquiries, and provide assistance;
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to analyze usage and request patterns;
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for other internal, statistical, and research purposes;
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to improve our data security and fraud prevention capabilities;
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to investigate violations and enforce our terms and policies, as well as to comply with applicable law, regulations, or governmental orders;
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to deliver updates, news, promotional materials, and other information related to our services. For promotional emails, you can decide whether you want to continue receiving them. If not, simply click on the unsubscribe link in these emails.
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To whom do we disclose this data?
We may share your data with our service providers to operate our services (e.g., data storage through third-party hosting services, providing technical support, etc.).
We may also disclose your data under the following circumstances: (i) to investigate, uncover, prevent, or take action against unlawful activities or other misconduct; (ii) to establish or exercise our rights to defend against legal claims; (iii) to protect our rights, property, or personal safety, as well as the safety of our users or the public; (iv) in the event of a change of control in us or one of our affiliated companies (through a merger, acquisition, or purchase of (substantially) all assets, among others); (v) to collect, hold, and/or manage your data through authorized third parties (e.g., cloud service providers), as appropriate for business purposes; (vi) to collaborate with third parties to improve your user experience. To avoid any misunderstanding, we would like to point out that we may transmit or otherwise use non-personal data to third parties at our discretion.
Please note that our services enable social interactions (e.g., posting content, information, and comments publicly and chatting with other users). We would like to point out that any content or data that you provide in these areas can be read, collected, and used by other individuals. We advise against posting or sharing information that you do not want to make public. If you upload content to our digital assets or otherwise provide it in the course of using a service, you do so at your own risk. We cannot control the actions of other users or members of the public who have access to your data or content. You acknowledge and agree that copies of your data may remain viewable in cached and archived pages or if other individuals have copied or stored your content, even after it has been deleted.
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Cookies and similar technologies
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 enable third parties to automatically collect your data to improve the navigation experience on our digital assets, optimize their performance, and ensure a personalized user experience, as well as for security and fraud prevention purposes.
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To learn more about this, please read our Cookie Policy.
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We may provide advertising through our services and our digital assets (including websites and applications that use our services), which may also be tailored to you, e.g., advertisements based on your recent browsing behavior on websites, devices, or browsers.
To deliver these advertisements to you, we may use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or HTML5 Local Storage and/or other technologies. We may also employ third parties, such as network advertisers (i.e., third parties who display advertisements based on your website visits), to serve targeted advertisements. External providers of advertising networks, advertisers, sponsors, and/or traffic measurement services may also use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or Flash cookies and/or other technologies to measure the effectiveness of their ads and personalize advertising content for you. These third-party cookies and other technologies are subject to the specific privacy policy of the respective third party and not this one.
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Where do we store the data?
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Non-Personal Data
Please note that our companies, as well as our trusted partners and service providers, are located all around the world. For the purposes explained in this privacy policy, we store and process all non-personal data that we collect in various jurisdictions.
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Personal Data
Personal data may be maintained, processed, and stored in the United States, Ireland, South Korea, Taiwan, Israel, and, as necessary for the proper provision of our services and/or as required by law (as further explained below), in other jurisdictions.
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How long is the data stored?
Please note that we retain the collected data as long as necessary for the provision of our services, to comply with our legal and contractual obligations to you, to resolve disputes, and to enforce our agreements. We may correct, supplement, or delete incorrect or incomplete data at any time at our discretion.
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How do we protect the data?
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The hosting service for our digital assets provides us with the online platform through which we can offer our services to you. Your data may be stored through the data storage, databases, and general applications of our hosting provider. They store your data on secure servers behind a firewall and offer secure HTTPS access to most areas of their services.
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All payment options offered by us and our hosting provider for our digital assets comply with the regulations of the PCI-DSS (Payment Card Industry Data Security Standard) of the PCI Security Standards Council. This is a collaboration of brands such as Visa, MasterCard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of credit card information (including physical, electronic, and procedural measures) by our store and service providers.
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Despite the measures and efforts taken by us and our hosting provider, we cannot and will not guarantee absolute protection and security of the data that you upload, post, or otherwise share with us or others. For this reason, we would like to ask you to set secure passwords and, if possible, not to transmit any confidential information to us or others, the disclosure of which, in your opinion, could cause you significant or lasting harm. Since email and instant messaging are not considered secure forms of communication, we also ask you not to share any confidential information via any of these communication channels.
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How do we deal with minors?
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The services are not intended for users who have not reached the age of majority. We will not knowingly collect data from children. If you are not of legal age, you should not download or use the services and should not provide us with any information.
We reserve the right to request proof of age at any time so that we can verify whether minors are using our services. In the event that we become aware that a minor is using our services, we may deny these users access to our services and block them, and we may delete all data stored with us about this user. If you have reason to believe that a minor has disclosed data to us, please contact us as explained below.
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We only use your personal data for the purposes set out in the privacy policy and only when we are convinced that:
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the use of your personal data is necessary to fulfill or conclude a contract (e.g., to provide you with the services themselves or customer service or technical support);
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the use of your personal data is necessary to comply with relevant legal or regulatory obligations, or
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the use of your personal data is necessary to support our legitimate business interests (provided that this is always done in a way that is proportionate and respects your privacy rights).
If you are a resident of the EU, you may:
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request confirmation as to whether or not personal data concerning you are being processed, and access your stored personal data and certain additional information;
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request the receipt of personal data you have provided to us in a structured, common, and machine-readable format;
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request the correction of your personal data stored with us;
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request the deletion of your personal data;
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object to the processing of your personal data by us;
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request the restriction of the processing of your personal data, or
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file a complaint with a supervisory authority.
However, please note that these rights are not unrestricted and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal data we collect and how we use it, please contact us as indicated below.
In providing the services, we may transfer data across borders to affiliated companies or other third parties and from your country/jurisdiction to other countries/jurisdictions worldwide. By using the services, you agree to the transfer of your data outside of the EEA.
If you are resident in the EEA, your personal data will only be transferred to locations outside the EEA if we are convinced 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 with our third parties to ensure that appropriate security measures are taken so that the risk of unlawful use, alteration, deletion, loss, or theft of your personal data is minimized and that these third parties always act in accordance with applicable laws.
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Rights under the California Consumer Privacy Act
If you use the services as a resident of California, you may be entitled under the California Consumer Privacy Act ("CCPA") to request access to and deletion of your data.
To exercise your right to access and delete your data, please see below for how to contact us.
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Users of the services who are residents of California and under 18 years of age may request and obtain the deletion of their posted content by sending an email to the address provided in the “Contact” section below. These requests must be labeled "California Removal Request". All requests must include a description of the content you wish to have deleted and sufficient information to allow us to locate the material. We do not accept communications that are not labeled or not properly transmitted, and we may not be able to respond if you do not provide sufficient information. Please be aware that your request does not ensure that the material will be completely or comprehensively deleted. Content you have posted, for example, may be republished or reposted by other users or third parties.
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Updates or changes to the Privacy Policy
We may revise this Privacy Policy at our discretion from time to time, the version published on the website is always current (see “Effective Date” indication). We encourage you to regularly check this Privacy Policy for any changes. In the event of significant changes, we will post a notice on our website. If you continue to use the services after notification of changes on our website, this will be considered your acknowledgment and consent to the changes in the Privacy Policy and your agreement to be bound by the terms of these changes.
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Contact
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If you have general questions about the services or about the data we have collected about you and their use, please contact us at:
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