Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

We use certain terms such as Personal Data, Usage Data, Cookies, etc. throughout our Privacy Policy. To understand it better please consult with interpretation and definitions explained in this section.

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

“Account” means a unique account created for You to access our Service or parts of our Service.

“Business”, for the purpose of the California Consumer Privacy Act (“CCPA”), refers to the Company as the legal entity that collects Consumers’ personal information, or on the behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of Consumers’ personal information, that does business in the State of California.

“Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Fourdev LLC Wyoming, 1309 Coffeen Ave STE 16541, Sheridan, WY, 82801, USA. For the purpose of the General Data Protection Regulation (“GDPR”), the Company is the Data Controller.

“Consumer”, for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (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.

“Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

“Data Controller”, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

“Device” means any device that can access the Service such as a computer, a cell phone or a digital tablet.

“Do Not Track” (“DNT”) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

“Personal Data” is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data (Personal information) means any information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

“Sale”, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.

“Service” refers to the Website and any services the Website and/or the Company provide.

“Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

“Usage Data” refers to any data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

“Website” (referred to as either the “Platform” in this Agreement) refers to https://app.4dev.com.

“You” means the individual accessing or using the Service as a contractor or as Our client’s representative, as applicable.

Collecting and Using Your Data

We may collect the different categories of data, for example, data you provide us upon registration or while using the Service, data we obtain automatically from common internet technologies, such as cookies, or sometimes we may receive additional information about you from other sources. If you refuse to provide certain data, there is a possibility that you will not be able to use our services in full. For more information about how we collect and use your Personal Data please read this section.

Data You Provide To Us

Contact and Personal Information: You may provide us with Your name, last name, taxpayer identification number (TIN) and registration number, country, address, phone number, email, messengers accounts, password and registration date at the Platform, correspondence with individuals when You are using the Service, pictures and images, audio containing Your voice and the voices of other people, videos, audio recordings.

Financial Information: Credit card number, VAT number, bank account details and details of the electronic wallets or other payment account information may be stored by Us or by Our payment processors depending on the circumstances.

Information about Your business: for the purpose of providing the Service, You may provide us information about Your business (such as company, role, relations between role/hierarchy, job title, business contact, business needs, etc.).

Data We Automatically Collect From Your Device

Cookies or Browser Cookies. A cookie is a small file stored in your web browser or placed on Your Device while you are browsing the Website or using the Services. Our Website sends Cookies to Your browser and Your device stores them. You can customize Cookies, delete Cookies in the web browser settings, instruct Your browser to refuse all Cookies or indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless You have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies. For more information about the cookies management, including refusal from them, please refer to the settings of the browsers: Chrome, Edge, https://4dev.com/cookies-policy.

Web Beacons. Certain sections of Our Service and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

To know more about use of tracking technologies, please, visit Our Cookies Policy. You can always find there information and update your cookies settings to accept or reject them.

Device Information. This is technical information about the device You use to access the Service such as Your device’s IP address and operating system. Additionally, in the case of mobile devices, Your device type, user settings, MAC address, language settings, mobile network information, mobile carrier, unique advertising identifier (such as the Apple IDFA or Android Advertising ID) and any other unique identifiers that may be assigned to the mobile device, such as an Android ID or UDID in older Apple phone models, or a non-cookie unique identifier.

IP Address. This is IP address associated with the Device You are using when accessing the Service.

Location Data. This is non-precise information related to Your geography derived from Your Device’s IP address. This does not reveal Your precise geographic coordinates (i.e., Your GPS latitude and longitude) – only country, state, city and zip/postal code level location data.

Browser Data. This is technical information about the browser You are using. An example of browser information is the technical information that identifies Your browser as, for example, Chrome, Firefox, Safari, etc. (browser type and version, operating system).

Activity on the Website. This is data about Your browsing activity on Our Website and Your interactions with our other tools or dashboards. For example, which pages You visited and when, what items were clicked on a page, how much time was spent on a page.

Data We Collect from Third Party Sources

We may receive information about You from our third-party partners, such as business or marketing partners or from publicly available sources which help us to update, expand, and analyze our records; prevent or detect fraud; process payments; or analyze how you use the Website and Services. We may combine this information with the other information We collect about You to provide more useful information to You regarding our Service. The data from third party sources may include without limitation the data from analytics providers (e.g., Google).

If You choose to use the Google Contacts feature within Our Website or Services, We will have the ability to view Your contacts via the Google People API. This data will be used to make the auto-completion of your contacts possible when sending invitation emails. We will not use this data for any other purpose.

Special Categories of Personal Data

We do not collect any special categories of Personal Data about You, except for the copies of your ID documents (if You are a contractor), which we may request from You from time to time. The special category of data includes details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Your health and genetic and biometric data. We also do not collect any information about criminal convictions (including religious or ideological convictions) and offences.

If You fail to provide Personal Data

Where We need to collect Personal Data by law, or under the terms of a contract We have with You and if You fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with You (for example, to provide You with Service). In this case, We may have to cancel a Service You have with us but We will notify You if this is the case at the time.

Anonymous Data

We may anonymize the Personal Data, or use the anonymous information we receive. The anonymous data shall not be considered to be the Personal Data, as it does not identify you as an individual. We may use the anonymous data to administer the Website and the Services, for analytics, advertising and promotional purposes. We may share the anonymous data with other entities (e.g., service providers, business partners) for such purposes. The anonymous data includes without limitation aggregated data which allows us to conduct analytics and research.

Use of Your Data

We use Your Data within necessary period of time to provide You with services You request, and to help Us improve Our Services to meet Your needs. We use Your Data only for the purposes consistent with the reason You provided it. We may share your Data with the companies that perform services for Us, and We require those companies to protect Your data in the same manner as We do. We also may disclose your data if We legally obliged to do so.

We use different locations to provide You with Our Services which means that Your Data may be transferred and stored outside your residual location. We seek adequate level of protection of Your data in these cases.

To use the Personal Data, we must rely on one or more legal bases and purposes. Please read more about use of your data in this section.

The Company may use Your Data for the following purposes:

We may use Your Contact Information, Financial Information, Information about Your business, Data We Automatically Collect from Your Device, copies of Your ID documents (only for contractors), which are considered to be special category of the Personal Data, to provide and maintain Our Service, including to monitor, manage and improve the usage of Our Service.

We may use Your Contact Information, Information about Your business, and Financial Information to manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

We may use Your Contact Information, Financial Information, Information about Your business, copies of Your ID documents (only for contractors) to execute and to perform a contract: performing the contract with between You (or the client You represent) and Us through the Service.

We may use Your Contact Information, Financial Information, Information about Your business, copies of Your ID documents (only for contractors) to process Your payments and otherwise service your tasks within the Service.

We may use Your Contact Information, Information about Your business, copies of Your ID documents (only for contractors) to verify Your identity, to prevent fraud, deception and other illegal activities and to confirm eligibility to use Our Service.

We may use Your Contact Information to contact You: to contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

We may use Your Contact Information and Information about Your business for direct marketing: to provide You with news, special offers and general information about our Service unless You have opted not to receive such information.

We may use Your Contact Information, Financial Information, Data We Automatically Collect from Your Device to manage Your requests: to attend and manage Your requests to Us.

We may use any and all data You provide Us or We collect about You:
for business transfers. We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred;
to fulfil legal requirements: to comply with law – for example, when the court or a public authority requests Personal Data.

We may use Data We Automatically Collect from Your Device and Data We Collect from Third Party Sources for analytics. We use anonymized information for further analysis, such as to identify trends about Our contractors and clients’ representatives as a whole including to support decisions about improvements to our products, services or operations, to measure the success or effectiveness of Our offers, promotions, benefits contents, products and services.

We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, for payment processing, to contact You;
For business transfers: We may share or transfer Your personal 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;
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include any related company that We control or that are under common control with Us;
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions;
If You are a freelancer, we may share Your personal information with Our clients;
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Monitoring, Recording and Retention of Your Personal Data

We reserve the right to monitor your sessions and communication via Service for quality control and training purposes. With some exceptions, We record the audio and video of each session and retain these recordings for up to 18 months for quality control and training purposes, and to improve Our Platform. If You ask Us not to record a session or a specific communication, We will either stop recording that session or let You know if We are unable to comply with the request. We will generally store other information associated with You until it is no longer necessary to provide the Service to You or until You ask us to delete it. We may retain certain information to comply with Our legal obligations or enforce Our rights.

Retention of Your Personal Data

The retention period depends on the category of data subject and the purpose of processing.

If You are a contractor, We retain the Personal Data processed:

for the following purposes until You delete Your account or until Our contract with You terminates or expires:
- to provide and maintain Our Service;
- to manage Your Account;
- to conclude a contract with You and to perform it;
- to contact You and to manage Your requests;
- to transfer Our business;
for analytics – until the purposes of the analysis are fulfilled or until You withdraw Your consent – whichever is earlier;
for direct marketing – until You unsubscribe.

If You are a representative of Our client We retain the Personal Data processed:

for the following purposes until Our contract with the client you represent expires or terminates or until You withdraw Your consent, whichever is earlier:
- to provide and maintain Our Service;
- to manage the Account of Our client You represent;
- to conclude and perform Our contract with the client;
- to contact Our client and to manage its requests;
- to transfer Our business;
for analytics – until the purposes of the analysis are fulfilled or until You withdraw Your consent or until We are informed that You resigned or were fired from the company, whichever is earlier;
for direct marketing – until You unsubscribe or until We are informed that You resigned or were fired from the company You represent, whichever is earlier;

In some circumstances, You can ask Us to erase Your Personal Data, for example if the data is no longer needed to fulfil the processing purpose. However, the Company is not obliged to do so if it has to keep the Personal Data to comply with a legal obligation. So, irrespectively of whether You are a contractor or our client’s representative, We retain Your Personal Data processed to address our legal needs until the period prescribed by the legislation expires.

After the retention period ends, we will:

delete your Personal Data; or
anonymize them, so that they can no longer be associated with You.

We may use such anonymized data for research or statistical purposes or to improve our Service. We may use them indefinitely without further notice to you.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and at our data centres in places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. This Privacy Policy applies regardless of the location in which We store or process your Personal Data.

The countries to which We or the third parties We engage transfer the Personal Data may not have the same data protection laws as Your jurisdiction. In these cases, We take reasonable security measures which the applicable laws prescribe to ensure that the Personal Data are properly protected when they are transferred outside Your jurisdiction.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

If You don’t agree to such transfers You will no longer be able to use the Website and (or) the Service.

If You are a resident in the EEA We may transfer your data outside the EEA to fulfill our contract with You (to provide You with information You request), as We provide an international service. When We make such transfers we: (1) comply with our legal and regulatory obligations; (2) estimate if the country to which we intend to transfer the Personal Data provides for sufficient level of data protection; and (3) implement the appropriate safeguards such as executing standard data protection contractual clauses. We will take all the steps to ensure that your data are treated securely and in accordance with the Policy.

Disclosure of Your Personal Data

Business obligations

We may disclose Your Personal Data to engage a third party to provide you with the Service.

We may share your data with Our business partners, service providers, contractors or agents performing the services for us or on our behalf and require access to such information to perform their obligations. The examples of such third parties’ services are payment processing, email delivery, hosting. We may allow selected third parties to use tracking technology on Our platform, which will enable them to collect the data about how you interact with Our platform over time. We may also share the information about you with Our affiliates. Affiliates include our parent companies and any subsidiaries, joint venture partners or other members of Our group of companies. Our affiliates, partners and contractors will be required to meet Our standards on processing data and security.

Consent

“>We may disclose Your Personal Data for other purposes described in this section if you granted us consent to do so.

Business Transactions

“>If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

“>Under certain circumstances, We may disclose the Personal Data where We are legally required to do so to comply with the applicable law, governmental requests, a judicial proceeding, court order, or legal process. For example, We may disclose the information in response to a court order, a subpoena, a public authorities’ request to meet national security or law enforcement requirements. We may also disclose your information when we conduct or cooperate in investigations of fraud or other illegal activity, to prevent and detect fraud or crime.

Other legal requirements

“>The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

We apply special measures to ensure that your data is secured – read below more on this.

We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
For example:
Your personal information is subject to restricted access;
electronic data is protected by technological means, such as firewalls, access controls and encryption, multifactor authentication;
We sensitize our personnel to the importance of safeguarding personal information from loss, theft or unauthorized access, use or disclosure.

However, please also remember that We cannot ensure or warrant security of the Personal Data which you transmit when you using the Website and / or the Services. Although We will do our best to protect the Personal Data, their transmission to and from Our Website as well as while using the Services is at your own risk. Please, access the Website and the Services only in a secure environment: for example, use firewalls, choose the provider which encrypts the traffic, etc. After We receive the Personal Data, We use strict procedures and security features to try to prevent unauthorized access.

To the maximum extent allowed by applicable law We will not be liable for any damages related to unauthorized access to the Personal Data.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies. Read more in this section.

Analytics

We may use third-party Service providers to monitor and analyse the use of our Service. We work with analytics providers, such as Google Analytics, which use cookies and similar technologies to collect and analyse information directly from User’s browsers to enable us to better understand Your use of our Site in order to diagnose and improve the Service and to fix issues and report on activities and trends. Google Analytics may also collect information regarding the use of other Service and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners and https://developers.google.com/analytics/resources/concepts/gaConceptsTrackingOverview, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout . We do not use Google Analytics for European-based Users.

Quality control

We reserve the right to monitor Your sessions and communication for quality control and training purposes. With some exceptions, We record the audio and video of each session and communication and retain these recordings for up to 18 months. We do this for quality control and training purposes, and to improve our Platform and make it more useful to You.

Search Engine Marketing

We use Google AdWords service to advertise on the Google search result page. Google uses cookies to serve ads based on your past visits on our website. For more information on Google AdWords services and how to opt-out, please refer to Google specific privacy policy and settings for Google ads.

Online advertising

Our website uses cookies for the purpose of personalized advertising. This enables Us to show Our advertisements to visitors who are interested in Our products on partner websites and apps. Retargeting technologies rely on cookies or similar technologies to display advertisements based on your past browsing behaviour.

You can opt-out of interest-based advertising by visiting the following websites:

https://www.networkadvertising.org/choices

https://www.youronlinechoices.com

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

“Opt-out of Interest-Based Ads” or “Opt-out of Ads Personalization” on Android devices

“Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

To read more about the technologies used by our partners, please refer to their privacy policy listed in the above-mentioned platforms or listed below:
Facebook.com.

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by contacting Us via [email protected] or by clicking the unsubscribe link in any our marketing email.
If You opt-out We may still need to send You Services-related communications, which are necessary to administrate and use Your Account.

Payments

We may use third-party services for payment processing (e.g., payment processors).
This information may be stored by Us or by Our payment processors depending on the circumstances.

Business Support

We may request the services from auditors, accounting and legal advisers, which may access Your Personal Data on a need-to-know basis. We take the necessary measures to safeguard the Your data, e.g. execute standard contractual clauses if necessary.

Identification Services

If You are a contractor, we may use a third-party provider, Sumsub, to identify You. You can find the policy of processing Your Personal Data by Sumsub here.

European residents: legal basis and Your rights

If you reside in Europe you enjoy specific rights under the European data protection regulation such as rights to obtain information about data about you we process, correct this data, ask for its deletion and to file a complaint. Consult this section to know more.

For the purpose of this Privacy Policy Europe shall include European Economic Area and Switzerland and the United Kingdom.

Legal Basis

“>We process Your Personal Data to provide and maintain Our Service:
to execute and to perform a contract between You and Us;
based on Your consent – if we process the copies of Your ID documents or if You are a representative of Our client.

We process Your Personal Data to manage Your Account:
to execute and to perform a contract between You and Us;
based on Your consent – if You are a representative of Our client.

We process Your Personal Data to prevent fraud, deception and other illegal activities and to confirm eligibility to use Our Service based on:
Your consent – if we process the copies of Your ID documents or if You are a representative of Our client;
our legitimate interest which is to ensure that our Service is secure and safe to use and is not used for fraud and all the users are eligible to use it.

We process Your Personal Data to contact You based on:
Your consent – if You are a representative of Our client;
our legitimate interest which is to keep you informed about the features of Our Service.

We process Your Personal Data for direct marketing based on:
Your consent;
our legitimate interest which is to provide You with news, special offers and general information about our Service.

We process Your Personal Data to manage Your requests:
to execute and to perform a contract between You and Us;
based on Your consent – if You are a representative of Our client.

We process Your Personal Data for business transfers based on Your consent. Fulfilling legal requirements is itself an independent legal basis for processing Your Personal Data.

We process Your Personal Data for analytics based on:
Your consent;
our legitimate interest which is to analyze how You use Our Service and to improve it.

Your Rights under the GDPR

“>The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the following rights:
To access the Personal Data. The right to access, update or delete the information We have about You. Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions Yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
To rectify inaccurate Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
To object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
To request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
To make us your Personal Data portable as well as ro request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You. If You wish to have a copy of your Personal Data, We will aim to provide You with them within 14 days
To withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. Such withdrawal will only affect processing of your Personal Data after it is given. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
To restrict processing of Your Personal Data. You may ask Us to restrict or stop collection, use, processing and/or disclosure of your Personal Data.
To withdraw consent to electronic marketing which means that you may opt out receiving our marketing emails (if any).
To be informed about the safeguards which we arrange to transfer your Personal Data transfer to a third country or an international organization which means that you may ask us about these safeguards.
To file complaints which means that you may complain to a data protection authority about our collection and use of your Personal Data.

Exercising of Your GDPR Data Protection Rights

“>You may exercise Your rights by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

Please, keep in mind that there may be exceptions to Your rights under the Cyprus and (or) EU data protection law, with which We must comply, or under the legislation, with which a data processor We engage must comply. Thus, We may reject the request about execution of Your rights where permitted or required by these laws.

If We reject Your request We will describe the grounds for it in Our response.

Our time limit to respond is one month after we receive Your request. If it takes longer to process Your request, we will notify You. In any case, we cannot extend the response timeframe for more than two months after the first month for response passes.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information please contact Your local data protection authority.

Automated decision-making

We do not apply automated decision-making (making user profiles based on the Personal Data, etc.)

CCPA Privacy Policy

This Privacy Policy section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California. Being a Californian resident, you enjoy certain rights, such as right to obtain information and ask us not to share your information or delete it. Read more here.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.

Examples: first and last name, place of employment, job title, email, phone number, messengers accounts, IP address.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: first and last name, signature, job title and the powers to enter into the agreement with Us, email, phone number, messengers accounts.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: IP address, browser data, device information, current non-precise location based on IP address of the device, information about the activity at Our website.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: employer, place of employment, job title.

Collected: Yes.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Category L: sensitive personal information.

Examples: email and text messages between Our clients and contractors.

Collected: Yes.

Under CCPA, personal information does not include:
Publicly available information from government records;
Deidentified or aggregated consumer information;
Information excluded from the CCPA’s scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:
Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
Indirectly from You. For example, from observing Your activity on our Service.
Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
From Service Providers. For example, third-party vendors to monitor and analyse the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
To perform Our services, including maintaining or servicing Your accounts, providing customer service, processing transactions, verifying information about You, processing payments.
To help to ensure security and integrity of Our service.
To debug to identify and repair errors that impair existing intended functionality of Our service.
To undertake activities to verify and maintain the quality and safety of Our service and to prevent fraud.
To provide advertising and marketing services (newsletters, etc.).

Please note that the examples provided above are not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Data” section.

We do not use or disclose sensitive personal information for the purposes other than expressly set out in the CCPA and the California Consumer Privacy Act Regulations: to provide you with Our Service, to prevent, detect, and investigate security incidents, etc.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D: Commercial information

Category F: Internet or other similar network activity

Category G: Geolocation data.

Category I: Professional or employment-related information.

Category L: sensitive personal information.

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of Your personal information to the following categories of third parties:

To our affiliates and third-party vendors to whom You or Your representatives or agents authorize Us to disclose their personal information – any and all categories of the personal information we collect.

To Our business partners – Internet or other electronic network activity.

We may sell or may have sold Your personal information for advertising and/or marketing purposes.

Share of Personal Information

We may share and may have shared in the last twelve (12) months the following categories of Your personal information to the following categories of third parties:

To Our business partners – Internet or other electronic network activity.

We may share or may have shared Your personal information for advertising and/or marketing purposes.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected (including the sensitive personal information as defined below) and the purposes for which the Personal Data is being used; if Your Personal Data is sold or shared; the retention period for each category of the Personal Data (if possible) or the criteria for determining of such period.
The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

The categories of personal information We collected about You
The categories of sources for the personal information We collected about You
Our business or commercial purpose for collecting or selling that personal information
The categories of third parties with whom We share that personal information
The specific pieces of personal information We collected about You

If we sold, shared or disclosed Your personal information for a business purpose, We will disclose to You the categories of personal information categories sold, shared or disclosed.

The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell or share Your personal information. To submit an opt-out request please contact Us.
The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:

Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
Comply with a legal obligation.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:

Denying goods or services to You
Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
Providing a different level or quality of goods or services to You
Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
Retaliating against You for exercising Your rights

The right to correct inaccurate personal information. You may request that we correct inaccurate personal information about you

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:
By sending us an email: [email protected]

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:
Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:
Verify Your identity or authority to make the request
And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

When you make a request to know, which personal information We process, request to delete Your personal information, or request to correct it, we must identify You or Your representative.

Depending on the circumstances, We may identify You based on the previous authentication, e.g. via logging in to the account, e-mail or text message containing confirmation links.

At the same time, We may ask You or Your representative for further proof of identity or authority to act, e.g. We may ask for the copies of Your identification documents: driving license or passport. If We have not processed these documents before, We will delete them as soon as practical after processing Your request.

Do Not Sell My Personal Information

You have the right to opt-out of the sale or sharing Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling or sharing Your personal information. To exercise Your right to opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If You wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law,

You may do so by:
using Our “Do Not Sell My Personal Information” notice banner;
contacting us at [email protected].

We do not process an opt-out preference signal.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.
Your mobile device may also give you the ability to opt out of the use of information about the apps You use to serve You ads that are targeted to Your interests:
“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices;
“Limit Ad Tracking” on iOS devices.

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If You’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit, please refer to privacy policies of these websites to understand how the Personal Data are processed there. Visiting these other websites or applications is at your own risk.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.