Last Modified: February 26th, 2019
If you are a resident of jurisdictions outside the European Union, please refer to the applicable legislation. This in no way limits you in your right to contact us for any assistance and clarification regarding your privacy and personal data protection.
ДЛЯ ГРАЖДАН РОССИЙСКОЙ ФЕДЕРАЦИИ
Для граждан Российской Федерации, не являющихся резидентами государств Европейского союза: обработка Ваших персональных данных осуществляется компанией Инспиритум Лтд и/или ее аффилированными лицами в строгом соответствии с требованиями Федерального закона от 27 июля 2006 г. № 152-ФЗ «О персональных данных» и иных нормативных правовых актов, принятых уполномоченными органами Российской Федерации.
По любым вопросам, связанным с обработкой Ваших персональных данных, Вы можете обращаться по следующим реквизитам:
Адрес электронной почты: firstname.lastname@example.org
Почтовый адрес: Arch. Makariou III 67C & 2B Orfeos, 2nd floor, Office 204, 1070 Nicosia, Cyprus
“Personal data” is defined in Article 4(1) of the GDPR as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
When providing the data to us you may be asked to specify certain privacy preferences which affect how the Company will process your personal data. By selecting the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.
The Company is registered in Cyprus under company registration number HE 367859, and the Company's registered office is at Arch. Makariou III 67C & 2B Orfeos, 2nd floor, Office 204, 1070 Nicosia, Cyprus
- Contact Us
Address: Arch. Makariou III 67C & 2B Orfeos, 2nd floor, Office 204, 1070 Nicosia, Cyprus
The Company and/or its data protection officer will make sure to provide a response or take requested action as soon as reasonably possible after studying your request.
- Age Restrictions
Unless stipulated otherwise by the Website’s interface, we do not collect personal information of persons under 18-year olds and verify the age before accessing the website. If some person less than 18 years old submits personal data and we find out that this personal data are of are data of a person less than 18 years old, we will delete the data as soon as possible.
- Which Information We Collect
- ip address;
- phone number;
- technical specifications of user’s device;
- history of viewed content on the website;
- location of the link to the website;
- billing information (if provided by you);
- username (if any);
- age (if the website’s interface provides for this)
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
The Website may use the following cookies:
- tracking devices within Websites;
- saving unique identifier of the device that used to navigate through Website;
- store session identifier;
- store user last activity time.
Cookies are uniquely assigned to each visitor, and can only be read by a web server in the domain that issued the cookie to the visitor. Cookies cannot be used to run programs or deliver viruses to your device.
Persistent cookies remain on your device for a set period of time specified in the cookie. They are activated each time that the visitor visits the Website that created that particular cookie.
Session cookies are temporary. They allow Website operator to link the actions of a visitor during a browser session. A browser session starts when a visitor opens a browser window and finishes when they close it. Once you close the browser, all session cookies are deleted.
Strictly necessary cookies are essential to navigate around the Website and to use its features. Without them, visitors would not be able to use basic services like registration. These cookies do not gather information about visitors that could be used for marketing or remembering where a visitor has been on the internet.
Performance cookies collect anonymous data for statistical purposes on how visitors use the Website, they don’t contain personal information, and are used to improve the visitor experience.
Functionality cookies allow visitors to customize how the Website looks for them: they can remember usernames, language preferences and regions.
These descriptions are provided for your general information only and in order for you to better understand the functionality of the Website and other websites and in no way imply that all of these kinds of cookies are used on the Website, however either or all of these kinds of cookies may be used.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features on the Website.
- Purposes of Processing
The Company processes personal data for the following purposes:
- Providing the Website content and billing to you which is required for contract performance.
- Processing of your requests which is required for performance of legitimate rights and obligations or to enter a contract with a data subject.
- Ad targeting and analysis which requires your consent.
- Marketing communications which can be considered our legitimate interest.
- Analysis of technical performance which can be considered our legitimate interest.
- How your personal data is used by the Company
The Company may process:
- Usage data which may include browser type and version, operating system and date and time of your visit. The source of the usage data is our analytics tracking system as updated from time to time. This usage data may be processed for the purposes of analysing the use of the Website. The legal basis for this processing is the Company’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely monitoring usage of Subscription Services for illegal activities as well as improving the Website and other products.
- Profile data – the Company may process personal data included in your personal profile. Your profile data may include, as a minimum, phone number, and country of residence. Profile data may be processed for the purposes of enabling and monitoring your use of the Website and other products as well ad targeting. The legal basis for this processing is the Company’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely monitoring usage of Subscription Services for illegal activities as well as improving the Website and other products.
- Account data – the Company may process your account data, which will include your name and email address, as well as your registered address and photo identification details. The source of the account data is the data which you enter when signing up for an account. The account data may be processed for the purposes of operating the Website, providing the Website services, ensuring the security of Website, monitoring any illicit or suspicious transactions undertaken using the Website and also communicating with you. The legal basis for this processing is the Company’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely monitoring usage of Website for illegal activities as well as improving the Website and other products.
- Service data – the Company may process personal data that you provide in the course of the use of Subscription Services and other products. The service data may include ATM data, transaction amounts and merchant information, if applicable and requested at the Website. The source of the service data is your use of the Website, including, without limitation, the transactions you undertake. The service data may be processed for the purposes of operating Website, providing the Website services, ensuring the security of Website, maintaining back-ups of the Company’s databases and communicating with you. The legal basis for this processing is the Company’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely monitoring usage of Website for illegal activities as well as improving the Website and other products.
- Transaction data – the Company may process information relating to transactions that you enter into with us and/or through the Website or other products. The transaction data may include your phone number and specific data concerning each transaction you enter into, merchant and pricing information. The transaction data may be processed for the purpose of monitoring the purchased goods and services and keeping proper records of those transactions.
The legal basis for this processing is the performance of a contract between you and the Company and/or taking steps, at your request, to enter into such a contract, as well as the Company’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely monitoring usage of the Website for illegal activities as well as improving the Website and other products.
- Enquiry data – the Company may process information contained in any enquiry or request you submit to us. The enquiry data may be processed for the purposes of offering, marketing and selling other relevant the Company products and/or services to you. The legal basis for this processing is the Company’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis.
- Correspondence data – the Company may process information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is the Company’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, proper administration of the Company’s business and communications with the Company’s users.
- Notification data – the Company may process information that you provide to us for the purpose of subscribing to the Company’s email notifications and/or newsletters. The notification data may be processed for the purposes of sending you relevant notifications and/or newsletters. The legal basis for this processing is the Company’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- Data on specifications and location of your device used for ad targeting which me receive directly or indirectly. The legal basis for such processing is your consent.
((i) to (x) being “Relevant Data”)
The Company may also process any of your personal data identified in the other provisions of this policy where absolutely necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
In addition to the specific purposes for which the Company may process your personal data, the Company may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which the Company is subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless the Company request in writing or from a Company email address that you do so.
- Providing your personal data to others
The Company may disclose any or all of Relevant Data to:
(a) any member of the Company's group of companies (this means the Company's subsidiaries, ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy; and
(b) to the Company's insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
(c) subcontractors, insofar as reasonably necessary for the purposes of those subcontractors performing their obligations to the Company to allow the Company to provide the Website services.
(d) the Company's partners, including but not limited to each relevant payment processor, advertiser or ad network.
Financial transactions relating to the Subscription Services are handled by the Company's payment services providers. The Company will share transaction data with the Company's payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
- International transfers of your personal data
The website will enable you to provide consent to data processing and opt out of such processing. Opt out may result in unavailability of the website functions to you. The consent interface will provide you with the all information required to make an informed and voluntary consent.
- Third Party Websites
The website may contain links or advertisements related to third party websites which are not controlled by the Company. The Company is not responsible for the practices of such third party websites.
- Additional Provisions on the Data Use
We use the data only for the purposes mentioned above. Such use includes maintaining your user account, interaction with your mobile operator and billing providers, and sending you messages with important updates. No other use will be conducted unless you provided your consent or unless there is a legitimate ground for such use. The data will be stored for the period of providing the website services to you and for a year after termination of such services.
- Data Protection
The Company uses reasonable administrative and technical measures to protect your information against loss, theft and unauthorized use, disclosure or modification. Such measures include processing personal data in secure environment and training our personnel for proper handling of personal data.
The Company use implement appropriate technical and organizational measures, including:
(a) the pseudonymisation and encryption of personal data;
(b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
(c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
(d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
Personal data is processed for as long as the relevant legal basis for processing exists.
- Your Rights
Besides your rights stipulated above you have the following rights:
- to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing;
- to lodge a complaint with a supervisory authority if you consider violation of your rights;
- to correct your inaccurate data;
- to erase your data;
- to restrict processing of your data;
- to demand provision of your data to you in readable form.