Privacy notice (US)

Last updated: 02.02.2023

This Privacy Notice explains how our company and our affiliates (collectively “we” “us” or “our”) collects, compiles and discloses, 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 the residents of the United States of America (USA). If you reside outside of the USA, such as in the visit our «Outside of the 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”?

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:

  1. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
  2. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  3. Biometric information;
  4. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement;
  5. Geolocation data;
  6. Audio, electronic, visual, thermal, olfactory, or similar information;
  7. Professional or employment-related information;
  8. Education information, defined as information that is not publicly available personally identifiable information;
  9. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal Information does not include (i) publicly available information that is lawfully made available to the general public by way of federal, state, or local government records unless its use is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained; (ii) de-identified or aggregated consumer information; and (iii) health or medical information or clinical trial data, and other personal Information covered by certain sector-specific privacy laws.

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

“Processing” is any operation or set of operations that are performed on personal data by either automated or not automated means. Collecting means buying, renting, gathering, obtaining, receiving, or accessing any personal information pertaining to a consumer by any means. Therefore, it covers any type of operation by which a business acquires personal information, be it directly from the consumer, or indirectly (e.g. through observation).

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, date of birth, gender, password, 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 does 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. The right to know about the personal information and how it is used and shared. You have the right to request that we disclose certain information to you about our collection,use, disclosure, and or sale of your Personal Information over the past 12 months;
  2. The right to delete personal information collected from you (with some exceptions). You have the right to request that we delete any of your Personal Information that we collected from you and retained in our databases, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.
  3. The right to opt-out of the sale of their personal information. You may request that businesses stop selling your personal information (“opt-out”). With some exceptions, businesses cannot sell your personal information after they receive your opt-out request unless you later provide authorization allowing them to do so again. Businesses must wait at least 12 months before asking you to opt back into the sale of your personal information.
  4. The right to non-discrimination for exercising the rights. We will not discriminate against you for exercising any of your rights.
  5. The right to notice. You have the right to be informed of what categories of personal information we are collecting, including the purpose of the collection. We will notice you every time we begin collecting new forms of personal information (new categories) and if we start collecting personal information for new purposes.

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.