Table of Contents:
- What kinds of data do we collect about you?
- How we use the data we collect?
- Legal basis for processing (EEA only)
- Advertising Choices
- Retention Period
- With whom we share your data?
- International data transfers
- Third-party websites
- How we protect your personal data?
- Privacy Rights
- Contact information
2. What kinds of data do we collect about you?
We collect data you make available to us voluntarily on the Website in various situations (e.g., when you send us an email). We also collect data automatically gathered during your use of the Website (e.g. your IP address).
2.1. Data we collect about you
We collect data through a variety of sources. One of our sources is cookies a that record data about the use of our website. With regard to your use of the Website we may automatically collect the following data:
Navigation data. We collect data about how you navigate and use the Website, such as the types of content you view or engage with or the frequency and duration of your activities.
Cookies and other similar technologies. You can control cookies through your browser settings.
Browser and Device data. We collect data from or about the computers, phones, or other devices where you install or access the Website, depending on the permissions you’ve granted. In particular, we ask for access to your photos and camera of your device when you want to upload or make any photos for your profile. We may associate the data we collect from your different devices, which helps us provide consistent services across your devices. Browser and Device data may include data about your Internet browser type, operating system, hardware version, type and model, geolocation, IP address, connection data such as ISP, language and time zone. We also receive the URL of both the site you came from and the one you go to next.
2.2. Data about Children
We do not knowingly collect any data about children, minors or anyone under the age of 13. Nor do we knowingly market to children, minors or anyone under the age of 13. If you are less than 13 years old, we request that you do not submit data to us.
3. How we use the data we collect?
We and our service providers use personal data to: (i) provide the services at the Website; (ii) detect and prevent fraud; (iii) promote, analyze and improve the Website.
In particular, we use your personal data in order:
- to improve the Website by using data about your usage and interaction with the Website. We conduct surveys and research, test features in development. We analyze the data we have to evaluate the Website, and conduct audits and troubleshooting activities to improve the Website content and layouts.
- to personalize the Website for you, for instance, through use of the identifiers to make personalized advertisements for you.
- to prevent, detect, investigate, resolve disputes and/or remediate malicious activities, fraud, other cybercrimes, take legally-required actions or make sure you are a real person and want to avoid fake accounts being created.
- to contact you about our Website by email and other ways through the Website, including push notifications. We will send you messages about the availability of and updates regarding the Website, security, legal notices or other service-related information (Service messages). We also send messages about your statistics, such as summary of your use of the Website (Statistic messages). You can unsubscribe from Statistic messages at any time. Please be aware that you cannot opt out of receiving Service messages from us.
- to show you advertisements on the Website and/or send you commercial email about the Website, features, offers, promotions, contests, and events or provide other news or information about third-party services that may be of interest to you. We offer you choice to opt out advertisement and/or commercial emails.
- to provide you customer service and support.
We will also notify you if we want to use your personal data for a new or different purpose. We will use your personal data for such other purposes only if and to the extent necessary or permitted by applicable law or with your consent.
4. Legal basis for processing (EEA only).
If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal data will depend on the personal data concerned and the specific context in which we collect it. However, we will normally collect personal data from you only where: (a) we have your consent to do so, (b) where we need the personal data to perform a contract with you (e.g. to provide the services available at the Website), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).
5.2. Advertising of the Website on other websites. We serve you tailored advertising based on data relating to your use of the Website, as well as data received from third parties.
At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.
6. Advertising Choices.
You have choices regarding our use and disclosure of your personal data. We offer you choices about receiving advertising.
- Advertising from third parties on the Website is tailored to you based on your previous use of the Website. You can choose not to receive advertising from third parties by contacting us.
- You can also generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance's Self-Regulatory Principles for online behavioral advertising by visiting the opt-out pages on the NAI website and DAA website.
7. Retention Period.
Please note that we have a variety of obligations to retain the data that you provide to us, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers.
8. With whom we share your data?
Protection of your personal data is important for us. Your personal data will be shared with third parties only (i) if we have a legal obligation to do so (ii) if the data transfer is necessary for performance of the contract with you, (iii) if you have consented to the transfer of your data.
Third-party service providers and partner companies will receive your data only if and to the extent necessary for performance of our contract with you or with your consent. In such cases, the extent to which data is shared will however be kept to the absolute minimum. To the extent that our service providers come into contact with your personal data, we will make sure that they too will comply with all applicable data protection laws.
We do not share personal data with other companies, organizations and individuals unless one of the following circumstances applies:
With your consent. We will share personal data with other companies, organizations or individuals when we have your consent to do so.
Other Situations. We also may disclose your data, including personal data:
- In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us in our sole and exclusive discretion.
- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
9. International data transfers.
The Website is a global business. We may transfer personal data to countries other than the one in which you live. This country may not have the same data protection law as the country in which you initially provided the data. We deploy safeguards if we transfer Personal Data originating from the European Union (EU) and European Economic Area (EEA) to other countries not deemed adequate under applicable data protection law.
We process data outside of the EU and EEA.
In particular, to offer the services at the Website, we may need to transfer your personal data to the United States, Ukraine. The United States and Ukraine are not considered to provide an adequate level of protection under EU data protection law. It means that these countries do not have the same data protection laws as the country in which you initially provided the data.
In all cases, we use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the EU. Learn more about the Standard Contractual Clauses adopted by the EU Commission. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data. The Website accordingly adopted Standard Contractual Clauses so that the data flows necessary to provide, maintain, and develop the Website take place legally.
10. Third-party websites.
11. How we protect your personal data?
We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. When personal data is collected on the Website and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. However, data transfers are generally subject to security gaps, please make sure not to provide your login data to any third parties.
13. Privacy Rights.
You may at any time and at no cost demand information about your personal data that are processed by us, correction of any errors in your personal data, termination of processing of your personal data, erasure of your personal data or portability of your personal data. To exercise these rights, simply contact us at any time by clicking “Contact Us” page or by e-mail at: [email protected] with “Privacy Rights” on the subject line and in the body of your message.
If emailing us your request, please make clear in the email what personal data you would like to have changed. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
14. Contact Us.