Privacy notice (non-US)

Last updated: 02.02.2023

This Privacy Notice explains how our company and our affiliates (collectively “we” “us” or “our”) will collect, compile and disclose information about those who use our Services. We put great efforts in making sure that we secure your personally identifiable information and use it properly. This Privacy Notice explains generally how we receive Personal Information about you, and what we do with that Personal Information once we have it.

Please read this Privacy Notice (“Privacy Notice”, “Notice”) in full before using Services.

If you do not agree to this Notice, please do not provide us with your data.

We reserve the right to review this Notice at any given time of which you will be promptly updated. If we decide to change our Notice, we will post those changes on this page, and/or update the Privacy Notice. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page.

Important supplement information

This Notice regulates the processing of personal data of residents of worldwide except the USA. If you reside in the United States of America (USA), such as in the visit our «for residents of USA» page to learn about the controllers of your personal information, legal basis including the legitimate interests, for collecting and processing your personal information, safeguards relied upon for transferring personal information, your rights and contact details of the controller(s) and Data Protection Officer.

What do we mean by “Personal Information”?

For us, “Personal Information” or “Personal date” means any information relating to an identified or identifiable natural person; “Sensitive Personal Information” is a subset of Personal Information and is data about the racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, physical or mental health or condition, his sexual life, the commission or alleged commission by him of any offence, any proceedings for any offence committed or alleged to have been committed by him, the disposal of such proceedings or the sentence of any court in such proceedings, trade union membership.

What do we mean by “processing of your Personal Information”?

“Processing” covers “any operation” performed on personal data “such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

What type of Personal Information is collected?

We may collect data, including Personal Information, about you as you use our websites, services and interact with us. This information may include full name, phone, e-mail, IP-address, date of birth, gender, country of residence, language, avatar (photo or another image), other information such as interests and preferences, data profile regarding your online behaviour on our website.

If we link other data with your Personal Information, we will treat that linked data as Personal Information. We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us.

Why we collect, hold, use and disclose personal information?

We collect, hold, use and disclose personal information for purposes including the following:

  1. to provide products and services to you;
  2. to enable us to perform our obligations to you under Terms of Use, and to ensure that you perform your obligations under Terms of Use;
  3. for communicating with you, including sending you information about our products and services;
  4. for planning, research, promotion and marketing of our goods and services, including conducting competitions or promotions;
  5. to create aggregate data about clients through demographic profiling and statistical analysis of our database to optimise our products and services and /or allow for more efficient operation of our business;
  6. to establish your bona fides;
  7. for the investigation of suspected unlawful, fraudulent or other improper activity connected with the use of our products and services; and
  8. to comply with our legal and statutory obligations, including our obligations relating to identity verification and reporting under the Anti-Money Laundering and Counter Terrorism legislation and other applicable laws.

To whom Personal Information is disclosed?

We share personal information with other entities in a strictly controlled manner. We prohibit third parties who purchase the Personal Information we hold from reselling it unless you have an opportunity to opt-out of the sale of your information.

We may disclose your personal information to third parties as follows:

  1. to our contractors and external service providers associated with the operation of our business and provision of our services including, without limitation, associated data centres, web hosting providers, identification verification service providers, advertising agencies, mailing houses, printers, call centres, market research analysts, IT consultants, professional advisors and consultants;
  2. to law enforcement agencies to assist in the prevention of criminal activities;
  3. to government and regulatory authorities and other organisations as required or authorised by law or otherwise;
  4. controlling bodies where such controlling bodies request information to protect and maintain the integrity of services provided; and
  5. to a successor entity in the event of a business transition, such as a merger, corporate reorganisation or to a purchaser of part of or all of our assets.
  6. other third parties for whom we have obtained your permission to disclose your Personal Information.

Should the information be transferred to a third party, we will use reasonable measures to ensure that the information disclosed is protected by the third party under contractual arrangements.

How do we receive Personal Information about you?

We learn Personal Information about you when:

  1. you give it to us directly;
  2. we collect it automatically through our products and services (e.g., your use our services);
  3. when we try to understand more about you based on Personal Information you’ve given to us (e.g., when we use your IP address to customize language for some of our services).

What do we do with your Personal Information once we have it?

When you give us Personal Information, we will use it in the ways for which you’ve given us permission, or ways in which our clients who provided us the Personal Information instruct. Generally, we use your Personal Information to help us provide and improve our products and services for you. We may also use the Personal Information you provide to contact you regarding additional or our new services and features.

We may use the Personal Information to prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws and prevent or detect use or abuse of our services.

How long we retain your personal data?

We will store your date within the period of validity of your account. Your information will be deleted, anonymized or pseudonymized once it is no longer needed to comply with our business requirements, legal obligations, resolve disputes, protect our assets, or enforce our agreements.

How do we protect your information?

All personal data shall be processed in a manner that ensures appropriate security, integrity and confidentiality thereof, including, for example, protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organizational measures, such as encryption protocols and software, pseudonymization/anonymization, where applicable, access controls, authentication mechanisms and physical, operational and information security.

What rights do you have?

In particular, you have the right to:

  1. Withdraw your consent to the processing of your personal data at any time;
  2. Object to the processing of your personal data. If we process your information in our legitimate interests, e.g., for direct marketing emails or for our marketing research purposes, you can object against it. We will consider your request and, if there are no legal grounds to refuse it (e.g., public interest), stop the processing for such purposes;
  3. Be informed of what information of yours we hold, how we obtained it and how long we intend to keep it;
  4. Verify and have your personal data rectified in the event that they are inaccurate, incomplete or out-of-date;
  5. Restrict the processing of your personal data. When you contest the accuracy of your personal data, believe we process them unlawfully or want to object against the processing, you have the right to temporarily stop the processing of your personal data to check if the processing was consistent. In this case, we will not process the personal data for any purpose other than storing them or for the legal compliance purposes until the circumstances of restriction cease to exist;
  6. Ask us to delete/destroy/erase/otherwise remove the personal data about you (the right to be forgotten). Please note, that the deletion of your personal data may affect your experience on our Services or lead to close of relationships between you and us if the personal data were strictly necessary for the provision of services; and
  7. Have your personal data transferred to another organization (the right to data portability). The right applies if we are processing personal data based on your consent or under, or in talks about entering into a contract and the processing is automated.
  8. the right to lodge a complaint with a supervisory authority.

Your rights above - mentioned can be exercised free of charge by writing to us or telephoning us. In certain cases, we may ask you to verify your identity before we can act on your request.

How to contact Us?

If you have any questions about this Privacy Notice, please contact us here.

Controller: Golovna Group LTD

Data Protection Officer: [email protected]