-
To save or protect an individual's vital interest. We may
process your information when necessary to save or protect an individual’s
vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information
when we believe it is necessary and we have a valid legal reason (i.e.,
legal basis) to do so under applicable law, like with your consent, to
comply with laws, to provide you with services to enter into or fulfill our
contractual obligations, to protect your rights, or to fulfill our
legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases to process your
personal information:
-
Consent. We may process your information if you have
given us permission (i.e., consent) to use your personal information for a
specific purpose. You can withdraw your consent at any time.
Click here to learn more.
-
Performance of a Contract. We may process your personal
information when we believe it is necessary to fulfill our contractual
obligations to you, including providing our Services or at your request
prior to entering into a contract with you.
-
Legitimate Interests. We may process your information when
we believe it is reasonably necessary to achieve our legitimate business
interests and those interests do not outweigh your interests and fundamental
rights and freedoms. For example, we may process your personal information
for some of the purposes described in order to:
-
Send users information about special offers and discounts on our products
and services
-
Develop and display personalized and relevant advertising content for our
users
-
Analyze how our services are used so we can improve them to engage and
retain users
-
Support our marketing activities
-
Diagnose problems and/or prevent fraudulent activities
-
Understand how our users use our products and services so we can improve
user experience
-
Legal Obligations. We may process your information where
we believe it is necessary for compliance with our legal obligations, such
as to cooperate with a law enforcement body or regulatory agency, exercise
or defend our legal rights, or disclose your information as evidence in
litigation in which we are involved.
-
Vital Interests. We may process your information where we
believe it is necessary to protect your vital interests or the vital
interests of a third party, such as situations involving potential threats
to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission
(i.e., express consent) to use your personal information for a specific
purpose, or in situations where your permission can be inferred (i.e., implied
consent). You can withdraw your consent at any time. Click here to learn more.
In some exceptional cases, we may be legally permitted under applicable law
to process your information without your consent, including, for
example:
-
If collection is clearly in the interests of an individual and consent
cannot be obtained in a timely way
-
For investigations and fraud detection and prevention
-
For business transactions provided certain conditions are met
-
If it is contained in a witness statement and the collection is necessary
to assess, process, or settle an insurance claim
-
For identifying injured, ill, or deceased persons and communicating with
next of kin
-
If we have reasonable grounds to believe an individual has been, is, or may
be victim of financial abuse
-
If it is reasonable to expect collection and use with consent would
compromise the availability or the accuracy of the information and the
collection is reasonable for purposes related to investigating a breach of
an agreement or a contravention of the laws of Canada or a province
-
If disclosure is required to comply with a subpoena, warrant, court order,
or rules of the court relating to the production of records
-
If it was produced by an individual in the course of their employment,
business, or profession and the collection is consistent with the purposes
for which the information was produced
-
If the collection is solely for journalistic, artistic, or literary
purposes
-
If the information is publicly available and is specified by the
regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this
section and/or with the following
categories of
third parties.
Vendors, Consultants, and Other Third-Party Service Providers.
We may share your data with third-party vendors, service providers,
contractors, or agents (“third parties”) who perform services
for us or on our behalf and require access to such information to do that
work. We have contracts in place with our
third parties, which are designed to help safeguard your personal information.
This means that they cannot do anything with your personal information unless
we have instructed them to do it. They will also not share your personal
information with any organization apart from us. They also commit to protect
the data they hold on our behalf and to retain it for the period we instruct.
The
categories of
third parties we may share
personal information with are as follows:
-
Affiliate Marketing Programs
-
Communication & Collaboration Tools
-
Data Storage Service Providers
-
Finance & Accounting Tools
-
Performance Monitoring Tools
-
Product Engineering & Design Tools
-
User Account Registration & Authentication Services
-
Website Hosting Service Providers
-
Order Fulfillment Service Providers
We also
may need to share your personal
information in the following situations:
-
Business Transfers. We may share or transfer your
information in connection with, or during negotiations of, any merger, sale
of company assets, financing, or acquisition of all or a portion of our
business to another company.
-
When we use Google Maps Platform APIs. We may share your
information with certain Google Maps Platform APIs (e.g., Google Maps API,
Places API). To find out more about Google’s Privacy Policy, please refer to
this link. We use certain Google Maps Platform
APIs to retrieve certain information when you make location-specific
requests. This includes:
__________;
and other similar information. A full list of what we use information for
can be found in this section and in the previous section titled “HOW DO WE PROCESS YOUR INFORMATION?”. We obtain and store on your device
('cache') your location for
__________ months. You may revoke your consent anytime by contacting us at the contact
details provided at the end of this document. The Google Maps Platform APIs that we
use store and access cookies and other information on your devices. If you
are a user currently in the European Economic Area (EU countries, Iceland,
Liechtenstein and Norway) or the United Kingdom, please take a look at our
Cookie Notice.
-
Affiliates. We may share your information with our
affiliates, in which case we will require those affiliates to honor this
privacy notice. Affiliates include our parent company and any subsidiaries,
joint venture partners, or other companies that we control or that are under
common control with us.
-
Business Partners. We may share your information with our
business partners to offer you certain products, services, or
promotions.
-
Other Users. When you share personal information
(for example, by posting comments, contributions, or other content to the
Services) or otherwise
interact with public areas of the Services, such personal information may be
viewed by all users and may be publicly made available outside the Services
in perpetuity. If you interact with other
users of our Services and register for our Services through a social network
(such as Facebook), your contacts on the social network will see your name,
profile photo, and descriptions of your activity.
Similarly, other users will be able to view descriptions of your activity,
communicate with you within our Services, and view your profile.
-
Offer Wall. Our application(s) may display a
third-party hosted “offer wall.” Such an offer wall allows third-party
advertisers to offer virtual currency, gifts, or other items to users in
return for the acceptance and completion of an advertisement offer. Such an
offer wall may appear in our application(s) and be displayed to you based on
certain data, such as your geographic area or demographic information. When
you click on an offer wall, you will be brought to an external website
belonging to other persons and will leave our application(s). A unique
identifier, such as your user ID, will be shared with the offer wall
provider in order to prevent fraud and properly credit your account with the
relevant reward.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you
share with third parties that we may link to or who advertise on our
Services, but are not affiliated with, our Services.
The Services, including our offer wall, may link to third-party
websites, online services, or mobile applications and/or contain
advertisements from third parties that are not affiliated with us and which
may link to other websites, services, or applications. Accordingly, we do not
make any guarantee regarding any such third parties, and we will not be liable
for any loss or damage caused by the use of such third-party websites,
services, or applications. The inclusion of a link towards a third-party
website, service, or application does not imply an endorsement by us. We
cannot guarantee the safety and privacy of data you provide to any third
parties. Any data collected by third parties is not covered by this privacy
notice. We are not responsible for the content or privacy and security
practices and policies of any third parties, including other websites,
services, or applications that may be linked to or from the Services. You
should review the policies of such third parties and contact them directly to
respond to your questions.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and
store your information.
We may use cookies and similar tracking technologies (like web beacons and
pixels) to access or store information. Specific information about how we
use such technologies and how you can refuse certain cookies is set out in
our Cookie Notice.
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our services using a social media
account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your
third-party social media account details (like your Facebook or Twitter
logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile
information we receive may vary depending on the social media provider
concerned, but will often include your name, email address, friends list,
and profile picture, as well as other information you choose to make public
on such a social media platform.
We will use the information we receive only for the purposes that are
described in this privacy notice or that are otherwise made clear to you on
the relevant Services. Please note that we do not control, and are not
responsible for, other uses of your personal information by your third-party
social media provider. We recommend that you review their privacy notice to
understand how they collect, use and share your personal information, and
how you can set your privacy preferences on their sites and apps.
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other
than your own.
Our servers are located in
Georgia, Sweden, Germany, and
Poland. If you are accessing our Services from
outside
Georgia,
Sweden,
Germany,
and
Poland, please be aware
that your information
may be transferred to,
stored, and processed
by us in our
facilities and by
those third parties
with whom we may share
your personal
information (see
"WHEN AND WITH WHOM DO
WE SHARE YOUR PERSONAL
INFORMATION?" above), in
Georgia,
Sweden,
Germany,
Poland, and
other
countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom
(UK), then these countries may not necessarily have data protection laws or
other similar laws as comprehensive as those in your country. However, we
will take all necessary measures to protect your personal information in
accordance with this privacy notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information,
including by using the European Commission's Standard Contractual Clauses
for transfers of personal information between our group companies and
between us and our third-party providers. These clauses require all
recipients to protect all personal information that they process originating
from the EEA or UK in accordance with European data protection laws and
regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party
service providers and partners and further details can be provided upon
request.
9. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary
for the purposes set out in this privacy notice, unless a longer retention
period is required or permitted by law (such as tax, accounting, or other
legal requirements). No purpose in this notice will require us keeping your
personal information for longer than
forty eight (48) months past the termination of
the user's account.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if
this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is
possible.
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational
security measures designed to protect the security of any personal
information we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Although we
will do our best to protect your personal information, transmission of
personal information to and from our Services is at your own risk. You
should only access the Services within a secure environment.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European
Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and
Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to request
access and obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of your personal
information; and (iv) if applicable, to data portability. In certain
circumstances, you may also have the right to object to the processing of
your personal information. You can make such a request by contacting us by
using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
We will consider and act upon any request in accordance with applicable
data protection laws.
Withdrawing your consent: If we are relying on your
consent to process your personal information,
which may be express and/or implied consent depending on the applicable
law, you have the right to
withdraw your consent at any time. You can withdraw your consent at any time
by contacting us by using the contact details provided in the section
"HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the
processing before its withdrawal, nor when
applicable law allows, will it
affect the processing of your personal information conducted in reliance on
lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any
time by clicking on the unsubscribe link in
the emails that we send, or by
contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may
still communicate with you — for example, to send you service-related messages
that are necessary for the administration and use of your account, to respond
to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your
account or terminate your account, you can:
-
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may retain
some information in our files to prevent fraud, troubleshoot problems, assist
with any investigations, enforce our legal terms and/or comply with applicable
legal requirements.
Cookies and similar technologies: Most Web browsers
are set to accept cookies by default. If you prefer, you can usually choose
to set your browser to remove cookies and to reject cookies. If you choose
to remove cookies or reject cookies, this could affect certain features or
services of our Services. To opt out of interest-based advertising by
advertisers on our Services visit
http://www.aboutads.info/choices/.
If you have questions or comments about your privacy rights, you may email us
at [email protected].
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ("DNT") feature or setting you can activate to signal
your privacy preference not to have data about your online browsing
activities monitored and collected. At this stage no uniform technology
standard for recognizing and implementing DNT signals has been finalized. As
such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked
online. If a standard for online tracking is adopted that we must follow in
the future, we will inform you about that practice in a revised version of
this privacy notice.
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights
regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light"
law, permits our users who are California residents to request and obtain
from us, once a year and free of charge, information about categories of
personal information (if any) we disclosed to third parties for direct
marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar
year. If you are a California resident and would like to make such a
request, please submit your request in writing to us using the contact
information provided below.
If you are under 18 years of age, reside in California, and have a
registered account with Services, you have the right to request removal of
unwanted data that you publicly post on the Services. To request removal of
such data, please contact us using the contact information provided below
and include the email address associated with your account and a statement
that you reside in California. We will make sure the data is not publicly
displayed on the Services, but please be aware that the data may not be
completely or comprehensively removed from all our systems (e.g., backups,
etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a
temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is
outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain
rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the
past twelve (12) months:
|
Category
|
Examples
|
Collected
|
|
A. Identifiers
|
Contact details, such as real name, alias, postal address,
telephone or mobile contact number, unique personal identifier,
online identifier, Internet Protocol address, email address, and
account name
|
YES
|
|
B. Personal information categories listed in the California
Customer Records statute
|
Name, contact information, education, employment, employment
history, and financial information
|
YES
|
|
C. Protected classification characteristics under California or
federal law
|
Gender and date of birth
|
YES
|
|
D. Commercial information
|
Transaction information, purchase history, financial details, and
payment information
|
YES
|
|
E. Biometric information
|
Fingerprints and voiceprints
|
YES
|
|
F. Internet or other similar network activity
|
Browsing history, search history, online behavior, interest data,
and interactions with our and other websites, applications, systems,
and advertisements
|
YES
|
|
G. Geolocation data
|
Device location
|
YES
|
|
H. Audio, electronic, visual, thermal, olfactory, or similar
information
|
Images and audio, video or call recordings created in connection
with our business activities
|
YES
|
|
I. Professional or employment-related information
|
Business contact details in order to provide you our services at a
business level or job title, work history, and professional
qualifications if you apply for a job with us
|
YES
|
|
J. Education Information
|
Student records and directory information
|
YES
|
|
K. Inferences drawn from other personal information
|
Inferences drawn from any of the collected personal information
listed above to create a profile or summary about, for example, an
individual’s preferences and characteristics
|
YES
|
We may also collect other personal information outside of these categories
instances where you interact with us in person, online, or by phone or mail
in the context of:
-
Receiving help through our customer support channels;
-
Participation in customer surveys or contests; and
-
Facilitation in the delivery of our Services and to respond to your
inquiries.
How do we use and share your personal information?
Individual Entrepreneur DANIEL KAMIL GUSTAW
collects and shares your personal information through:
-
Targeting cookies/Marketing cookies
-
Click redirects:
__________.
-
Social media plugins: __________. We use social media features, such as a "Like" button, and
widgets, such as a "Share" button in our Services. Such features may
process your Internet Protocol (IP) address and track which page you
are visiting on our website. We may place a cookie to enable the
feature to work correctly. If you are logged in on a certain social
media platform and you interact with a widget or button belonging to
that social media platform, this information may be recorded to your
profile of such social media platform. To avoid this, you should log
out from that social media platform before accessing or using the
Services. Social media features and widgets may be hosted by a third
party or hosted directly on our Services. Your interactions with
these features are governed by the privacy notices of the companies
that provide them. By clicking on one of these buttons, you agree to
the use of this plugin and consequently the transfer of personal
information to the corresponding social media service. We have no
control over the essence and extent of these transmitted data or
their additional processing.
More information about our data collection and sharing practices can be found
in this privacy notice.
You may contact us
by email at [email protected],
or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we
may deny a request if the authorized agent does not submit proof that they
have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers
pursuant to a written contract between us and each service provider. Each
service provider is a for-profit entity that processes the information on
our behalf.
We may use your personal information for our own business purposes, such as
for undertaking internal research for technological development and
demonstration. This is not considered to be "selling" of your personal
information.
Individual Entrepreneur DANIEL KAMIL GUSTAW has
not sold any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months. Individual Entrepreneur DANIEL KAMIL GUSTAW has disclosed the following categories of personal information to
third parties for a business or commercial purpose in the preceding twelve
(12) months:
-
Category B. Personal information, as defined in the California
Customer Records law, such as your name, contact information,
education, employment, employment history, and financial
information.
-
Category K. Inferences drawn from any of the personal
information listed above to create a profile or summary about,
for example, an individual's preferences and
characteristics.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If
you ask us to delete your personal information, we will respect
your request and delete your personal information, subject to
certain exceptions provided by law, such as (but not limited to)
the exercise by another consumer of his or her right to free
speech, our compliance requirements resulting from a legal
obligation, or any processing that may be required to protect
against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
-
whether we collect and use your personal information;
-
the categories of personal information that we collect;
-
the purposes for which the collected personal information is
used;
-
whether we sell your personal information to third
parties;
-
the categories of personal information that we sold or
disclosed for a business purpose;
-
the categories of third parties to whom the personal
information was sold or disclosed for a business purpose;
and
-
the business or commercial purpose for collecting or selling
personal information.
In accordance with applicable law, we are not obligated to
provide or delete consumer information that is de-identified in
response to a consumer request or to re-identify individual data
to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s
Privacy Rights
We will not discriminate against you if you exercise your
privacy rights.
Verification process
Upon receiving your request, we will need to verify your
identity to determine you are the same person about whom we have
the information in our system. These verification efforts
require us to ask you to provide information so that we can
match it with information you have previously provided us. For
instance, depending on the type of request you submit, we may
ask you to provide certain information so that we can match the
information you provide with the information we already have on
file, or we may contact you through a communication method
(e.g., phone or email) that you have previously provided to us.
We may also use other verification methods as the circumstances
dictate.
We will only use personal information provided in your request
to verify your identity or authority to make the request. To the
extent possible, we will avoid requesting additional information
from you for the purposes of verification. However, if we cannot
verify your identity from the information already maintained by
us, we may request that you provide additional information for
the purposes of verifying your identity and for security or
fraud-prevention purposes. We will delete such additionally
provided information as soon as we finish verifying you.
Other privacy rights
-
You may object to the processing of your personal
information.
-
You may request correction of your personal data if it is
incorrect or no longer relevant, or ask to restrict the
processing of the information.
-
You can designate an authorized agent to make a request under
the CCPA on your behalf. We may deny a request from an
authorized agent that does not submit proof that they have
been validly authorized to act on your behalf in accordance
with the CCPA.
-
You may request to opt out from future selling of your
personal information to third parties. Upon receiving an
opt-out request, we will act upon the request as soon as
feasibly possible, but no later than fifteen (15) days from
the date of the request submission.
To exercise these rights, you can contact us by email at
[email protected],
or by referring to the contact details at the bottom of this
document. If you have a complaint about how we handle your data, we
would like to hear from you.
14. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this
notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The
updated version will be indicated by an updated "Revised" date
and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy notice,
we may notify you either by prominently posting a notice of such
changes or by directly sending you a notification. We encourage
you to review this privacy notice frequently to be informed of
how we are protecting your information.
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may
email us at
[email protected] or by post to:
Individual Entrepreneur DANIEL KAMIL GUSTAW
Zakaria Paliashvili street, N 41,
Tbilisi,
Vake district
0179
Georgia
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the
right to request access to the personal information we collect
from you, change that information, or delete it in some
circumstances. To request to review, update, or delete your
personal information, please
submit a request form by
clicking here.