Privacy Policy
Last revised: May 2nd, 2023
We are committed to protecting your privacy. This Privacy Policy is an integral part of the Terms of Use and applies to personally identifiable information that we collect and process through our Website, as well as any other related sites and applications, and how we use, disclose, and protect the data gathered via our Service. The Policy also applies to personal information that we collect and process when you use or interact with our Services through any correspondence made with us by e-mail, phone, or otherwise. The Policy aims to inform you about the type of information we gather, who we share it with, what we use it for, how we keep it secure, and what your data privacy rights are.
The processing of personal data, such as the name, address, e-mail address, telephone number, or billing information of a data subject, shall always be in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to Company. Through this Privacy Policy, we aim to inform the general public of the nature, scope, and purpose of the personal data we collect, use, and process. Data subjects are hereby informed, by means of this Privacy Policy, of the rights to which they are entitled.
If the processing of personal data is necessary, we generally obtain consent from the user as a data subject, except in cases where personal data processing is permissible under other grounds.
It should be noted that the data on our Services is encrypted to protect the privacy of the device user. Therefore, we will not be able to monitor or disclose this data to any third parties, nor read it from the server side.
Information We Gather About You
We may collect personal data such as your name, email, phone number, residence address, and IP address through various means, including correspondence with us by post, phone, email, or otherwise. This includes personal information you provide when you:
- Apply for our Services.
- Use our App or Services
- Request professional or promotional materials to be sent to you.
- Provide us with feedback.
- Contact customer support.
- Subscribe to our Services or make a purchase of one of the offers made to you via the Services.
The functionality of the Application may depend on geographical information that requires sharing location data, such as the geographical position of the User’s mobile device. If one of the features such as SMS/MMS, calls, location, photos, applications, calendar, contacts, website history, clipboard, notifications, social network messages, audio recording of calls, and audio/environmental video, etc., is enabled, these may also be collected.
If you do not agree to provide the abovementioned information, you should not use the App. You are entitled to withdraw your consent at any time by informing us that you withdraw your consent. This may result in the termination of your use of the App.
We Will Use the Information You Provide Us to:
- Provide you with the Service as intended by the App.
- Contact you on matters related to the Services, including, without limitation, to request any additional information and/or documentation.
- Tailor the products and Services offered to you.
- Maintain administrative records relating to our business according to all applicable laws.
- Process payments.
- Provide you with notices related to your needs, general updates, and other marketing materials, including, without limitation, the services and products offered by us and our affiliates.
- Conduct other legitimate or lawful matters.
Sharing Personal Information with External Parties
Third-party disclosures may include sharing such information with our group companies, affiliates, or non-affiliated companies that perform data processing and support services for your purchased services. Third parties are required to maintain the confidentiality of such information and to use your personal information only for the purposes within the ambit of the applicable law.
Additionally, we may share personal information with any competent law enforcement body, regulatory agency, government agency, court, or other third party where we believe disclosure is necessary: (i) as a matter of applicable law or regulation, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
Our Legal Basis for Using Your Personal Information
By using the App and by explicitly giving your consent to the Service, you agree to grant the necessary permissions to ask for and receive your information, subject to applicable laws, in order for the Services to function properly.
Cookies
Our Website may use "Cookies" and "Pixel Tags". "Cookies" are text files stored in a computer system via an Internet browser for record-keeping purposes. "Pixel Tags" (also known as transparent GIFs, clear GIFs, or web beacons) access Cookies and count users who visit the Website or open our HTML-formatted email messages. By showing how and when visitors use the Website, Cookies help us track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Website where you have previously entered preference information. Cookies contain a so-called cookie ID, a unique identifier of the cookie allowing Internet pages and servers to be assigned to the specific internet browser in which the cookie was stored. This enables visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
The use of cookies allows us to provide users of this Website with more user-friendly services that would not be possible without the cookie setting. Cookies enable the optimization of the information and offers on our Website with the user in mind.
The data subject may, at any time, prevent the setting of cookies through our Website by using a corresponding setting of the Internet browser used and may thus permanently deny the setting of Cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of Cookies in the Internet browser used, not all functions of our Website may be entirely usable.
If you do not wish to receive Cookies you may be able to refuse them by adjusting your browser settings to reject Cookies. If you do so, we may be unable to offer you some of our functionalities, services, or support. If you have previously visited our Website, you may also have to delete any existing cookies from your browser.
Security
The Company is obligated by law to implement high-standard security measures. However, you should be aware that no transmission method over the Internet is 100% reliable and secure. Therefore, we cannot guarantee the total security of data at all times.
Legal
We consider your use of our Services to be private. However, we may disclose your personal information
to:
(1) Comply with the law or legal process served on us;
(2) Enforce and investigate potential violations of this Privacy Policy, Terms of use; including use of
this Service to participate in, or facilitate activities that violate the law;
(3) Investigate potential fraudulent activities; or
(4) Protect the rights, property, or safety of us, our employees, customers, or the public.
You may always ask us to change or delete your personal data or opt-out by contacting us at [email protected].
Children Privacy
The Services are not aimed at or intended for use by children under the age of 18. We do not knowingly collect information from children and minors. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide information on our Website without their permission.
Our Website and Service are not directed to, nor do we knowingly collect personal data from, children under the age of 13. If we obtain actual knowledge that we have collected personal data from a child, we will comply with industry guidelines and applicable laws and promptly delete it unless we are legally obligated to retain such data.
Rights of the Data Subject
Under the applicable legislation, you are entitled to certain rights, some of which are detailed below:
a) Right of Confirmation
Each data subject shall have the right, granted by the European legislator, to obtain from the
controller confirmation as to whether or not personal data concerning him or her are being processed. If
one of the aforementioned reasons applies, and a data subject wishes to exercise this right and request
the erasure of personal data stored by us, they may contact us at any time, as instructed at the end of
this Privacy Policy, and we will comply immediately.
b) Right of Access
Eah data subject shall have the right, granted by the European legislator, to obtain from the controller
free information about his or her personal data stored at any time, along with a copy of this
information. Furthermore, the European directives and regulations grant the data subject access to the
following information:
- The purposes of the processing.
- The categories of personal data concerned.
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly recipients in third countries or international organizations.
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period.
- The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing.
- The existence of the right to lodge a complaint with a supervisory authority.
- Where the personal data are not collected from the data subject, any available information as to their source.
- The existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
The data subject also has the right to obtain information as to whether personal data are transferred to a third country or an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If one of the aforementioned reasons applies, the data subject may contact us at any time, as instructed at the end of this Privacy Policy, and we will comply immediately.
c) Right to Rectification
Each data subject shall have the right, granted by the European legislator, to obtain from the
controller without undue delay the rectification of inaccurate personal data concerning him or her.
Considering the purposes of the processing, the data subject shall have the right to have incomplete
personal data completed, including by means of providing a supplementary statement.
If one of the aforementioned reasons applies, the data subject may contact us at any time, as instructed
at the end of this Privacy Policy, and we will comply immediately.
d) Right to Be Forgotten
Each data subject shall have the right, granted by the European legislator, to obtain from the
controller the erasure of personal data concerning him or her without undue delay, and the controller
shall have the obligation to erase personal data without undue delay where one of the following grounds
applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and the data subject wishes to request the erasure of personal data stored by us, he or she may contact us at any time, as instructed at the end of this Privacy Policy, and we will comply immediately.
e) Right of Restriction of Processing
Each data subject shall have the right granted, by the European legislator, to obtain from the
controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR, pending the verification of whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned reasons applies, the data subject may contact us at any time, as instructed at the end of this Privacy Policy, and we will comply immediately.
f) Right to Data Portability
Each data subject shall have the right, granted by the European legislator, to receive the personal data
concerning him or her, which was provided to a controller, in a structured, commonly used, and
machine-readable format. He or she shall have the right to transmit those data to another controller
without hindrance from the controller to which the personal data have been provided, as long as the
processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article
9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing
is carried out by automated means, as long as the processing is not necessary for the performance of a
task carried out in the public interest or in the exercise of official authority vested in the
controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR,
the data subject shall have the right to have personal data transmitted directly from one controller to
another, where technically feasible and when doing so does not adversely affect the rights and freedoms
of others.
If one of the aforementioned reasons applies, the data subject may contact us at any time, as instructed
at the end of this Privacy Policy, and we will comply immediately.
g) Right to Object
Each data subject shall have the right, granted by the European legislator, to object, on grounds
relating to his or her particular situation, at any time, to the processing of personal data concerning
him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to
profiling based on these provisions. If one of the aforementioned reasons applies, the data subject may
contact us at any time, as instructed at the end of this Privacy Policy, and we will comply immediately.
h) Automated Individual Decision-Making, Including Profiling
Each data subject shall have the right, granted by the European legislator, not to be subject to a
decision based solely on automated processing, including profiling, which produces legal effects
concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not
is necessary for entering into, or the performance of, a contract between the data subject and a data
controller, (2) is not authorized by Union or Member State law to which the controller is subject and
which also lays down suitable measures to safeguard the data subject`s rights and freedoms and
legitimate interests, or (3) is not based on the data subject`s explicit consent. If one of the
aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored
by us, he or she may at any time contact us, as instructed at the end of this Privacy Policy. We shall
promptly ensure that the request is complied with immediately.
i) Right to Withdraw Data Protection Consent
Each data subject shall have the right, granted by the European legislator, to withdraw his or her
consent to processing of his or her personal data at any time. If one of the aforementioned reasons
applies, the data subject may contact us at any time, as instructed at the end of this Privacy Policy,
and we will comply immediately.
Changes
We reserve the right to make any changes to this Privacy Policy at any time. Once posted, the changes will become effective immediately. Please check the Privacy Policy regularly for updates.
Governing Law
This Privacy Policy shall be governed by the Governing Law clause in the General Terms of the Company, as published on our Website from to time.
Contact us
You are welcome to ask any questions related to this Privacy Policy by emailing us at [email protected].