Privacy Policy

Effective from 22.05.2024

This Privacy Policy has been developed taking into account Our awareness of the importance and significance of Your Personal information. The main purpose of this Policy is to help You understand how We Process and protect Your Personal information when You use the Site.

This Privacy Policy is developed and operates taking into account the California Consumer Privacy Act of 2018, California Online Privacy Protection Act of 2003, General Data Protection Regulation (GDPR), the General Data Protection Regulation of Great Britain (UK GDPR), Privacy Act 1988 of Australia (“Privacy Act”), as amended from time to time, including the Australian Privacy Principles (“APPs”), as well as other regulations and practices on the protection of Personal information.

By using this Site, You confirm that:

(I) You have read, understood, and agree to this Policy;

(II) You have reached the age from which the legislation of the country of Your stay allows You to give Consent to the Processing of Your Personal information. In any case, in order to use the Site, You must be at least 16 years old (at least 13 years old in certain regions) or one of Your legal representatives or guardians must have read and agree to the terms of this Privacy Policy on behalf of You. If You do not agree or cannot confirm the above, You must immediately stop using the Site. In this case, You must (a) contact Us and request the deletion of Your Personal information; (b) leave the Site and not use it.

1. Terms used in this Policy:

1.1. “Privacy Policy” – this document, which is available at the following link: https://searchanalytics.ai/privacy-policy/ (hereinafter — “Policy”).

1.2. “Company” — Local Profy LLC, a company incorporated under the laws of the United States of America (Delaware) with a company file number 5724993 and a registered address at 3422 Old Capitol Trail, STE 700, Wilmington, DE, USA (hereinafter — “Company”, “We”, “Us”, “Our”).

1.3. “Personal information” — any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

1.4. “Processing of Personal information” – any operation or set of operations which is performed on Personal information or on sets of Personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (hereinafter — “Processing”, “Processing of Personal information”).

1.5. “Subject of Personal information” – a person who visits and/or uses the Site within the scope of its available functionality and in accordance with the documentation contained on the Site (hereinafter — “User”, “You”, “Your”, “Subject of Personal information”).

1.5. “Site” — the website of the Company, https://searchanalytics.ai, all its content and links that lead to this website.

1.6. “Services” — functionalities and tools offered by the Site, tailored for optimizing and managing SEO activities, including content analysis, backlink research, rank tracking, keyword research, competitor analysis, technical SEO audits, and innovative SEO assessments, etc.

1.7. “Consent” — any freely given, specific, informed, and unequivocal indication of the Subject of Personal information wishes by which he or she, through clear affirmative actions, signifies agreement to the Processing of his or her Personal information.

1.8. “Cookies” — files that are downloaded to the User's computer or any other device when the User visits the Site. These types of files allow Us to store and research information about the preferences of the User on the Site.

1.9. “General Data Protection Regulation” — European Parliament and Council Regulation № 2016/679 as of 27.04.2016 On the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter — “GDPR”).

1.10. “CCPA” – California, USA Consumer Privacy Act of 2018.

1.11. “CalOPPA” – The Internet Privacy Protection Act of 2003 of the State of California, USA.

2. Personal information We Process when You use the Site

2.1. Personal information You provide to Us personally:

1) By completing the registration procedure and filling out the registration form on the Site, You may provide the following Personal information:

First and last name;
Email address;
Password.

Phone number.

2) In case of contacting Us through the means of communication available on the Site or via email, You additionally provide Us with Personal information that may be necessary to resolve Your request / problem.

3) In order to subscribe to the Company's newsletter, You may be required to provide Your email address and Consent to receiving the specified newsletter.

2.2. Personal information We Process automatically:

The list of Personal information that We automatically receive from You when using Our Site includes:

Cookies;
IP or MAC address of Your device;
Information about Your device's operating system and browser type, Your device type, unique device identifier (UDID);
Geolocation data to the extent that Your device settings allow Us to collect such information;
Personal information on age, gender, Your interests;
Interface language.

3. Children's Privacy

Ensuring the privacy and safety of children online is a top priority for Us. We are committed to complying with the privacy laws, particularly concerning the protection of children's Personal information.

We knowingly do not Process the Personal information of children under the age of 13 (if applicable) and children under 16, and We also do not offer them to use the Site.

If We become aware that a person who has not reached the age from which it is permitted to Process their Personal information has provided Us with their Personal information without the Consent of a legal representative, guardian, or other person authorized to provide such Consent, We will take all necessary measures to delete such Personal information. If You believe We might have any Personal information from or about a child under 16 (or 13 if applicable), please contact Us at [email protected].

We promptly delete the Personal information of minors upon request, in compliance with the rights granted to children and their parents or guardians under the privacy laws. We maintain efficient processes to facilitate such requests and ensure the secure deletion of Personal information.

We uphold transparency in Our data practices regarding children's privacy and provide clear information to parents, guardians, and minors about how their Personal information is collected, used, and shared. Additionally, We maintain accountability for compliance with relevant regulations and regularly review and update Our policies as necessary.

4. Purposes of Personal information Processing

We Process the Personal information provided by You only for the specific and limited purposes specified below:

Keep things up & running (i.e., operate, deliver, and maintain Our Services). We use the information We collect in order to operate, deliver, and maintain Our Services. The Personal information You provide can give You access to different functionalities of the Services. We also use some of Your Personal information to help keep Our Site up to date, for example, to make sure that Our Services work with the latest operating systems and devices.

Management and improvement of the Site. All the time, We try to improve the functions that support the operation of the Site. This allows Users to use the Site smoothly, quickly and efficiently.

Performance of a contract. The development, compliance, conclusion, and execution of the services contract for the Services You have purchased on the Site or of any other contract with Us through the Services. The Processing of Personal information is necessary to ensure the performance of the contract between the User and the Company, thereby enabling the provision of the agreed-upon Services.

Enhance the safety and security of Our Services. We may use Your Personal information to enhance the safety and security of Our Services, and prevent fraud or other unauthorized or illegal activity. We monitor failures of the Site and create software solutions to eliminate them, detect violations of this Policy, and monitor the use, abuse and potential abuse of the Site.

Aggregate data analysis. To aggregate and anonymize Personal information for statistical, research, or analytical purposes, and to generate insights or reports that do not identify individual Users.

Sending a newsletter. Under the condition that the User has subscribed and provided Consent to receive newsletters, Personal information may be used for sending informational and marketing messages deemed by the Company to align with the preferences of the Users.

User support. Personal information Processing is utilized for providing customer support services, including responding to inquiries, resolving issues, and facilitating communication between Users and the support team.

Compliance and security. Personal information Processing is essential for ensuring compliance with legal obligations, such as tax regulations and consumer protection laws, as well as for implementing security measures to protect against unauthorized access, fraud, and other security threats.

Enforce Our Terms & Policies. We use Personal information We collect to enforce Our Terms & Conditions, Policy and the law. This includes enforcing, investigating, and reporting conduct that violates Our Terms & Conditions, Policy, or the law, responding to requests from law enforcement, and complying with legal requirements. In some cases, We may also use or share Your Personal information to cooperate with law enforcement requests, escalate safety issues to law enforcement, industry partners, or others, or comply with Our legal obligations.

5. Legal basis for Processing Your Personal information

To Process Your Personal information, We rely on the following lawful bases:

Consent. We may Process Your Personal information based on Your explicit Consent.
Business Purpose. Processing Your Personal information may be necessary to fulfill a business purpose outlined in Our initial notice or reason for collection. This includes activities directly related to the provision of products or Services You have requested.
Compliance with legal obligations. We may Process Your Personal information to comply with legal obligations to which We are subject. This may include obligations related to tax, accounting, regulatory reporting, and other legal requirements.
Exercise or defense of legal claims. Processing Your Personal information may be necessary for the establishment, exercise, or defense of legal claims. This includes situations where We need to protect Our legal rights or defend against legal claims brought against Us.

We ensure that Our Processing of Your Personal information is consistent with these legal grounds and with the requirements of the privacy laws. If You have any questions or concerns about the legal basis for Our Processing activities, please contact Us using the information provided in this Privacy Policy.

6. Storage of Personal information

6.1. How long do We keep Your Personal information?

We will store Your Personal information for the period necessary to fulfill the purposes set forth in the Policy, but not more than 1 (one) year from the date of deactivation of Your account. When determining the duration of such periods, We first decide whether We need to collect Personal information at all, and, if such a need really exists, We keep it only for the period necessary to realize the purposes of collection, or until the moment You make a corresponding request to delete Your Personal information.

The specific retention period for Your Personal information may vary depending on factors such as the type of Personal information, the purposes for which it was collected, and legal requirements.

We regularly review the Personal information We hold and implement measures to ensure that it is accurate, up-to-date, and necessary for the purposes for which it was collected.

6.2. Where do We store Your Personal information?

We adhere to generally accepted industry standards to protect Your Personal information both during transmission and after receipt. Personal information is also stored on servers operated by Hetzner Online GmbH, located in Germany.

Processing of Personal information is carried out using computers and/or automated means in accordance with procedures and methods that correspond to the purposes of collecting Personal information.

We take the protection of Your Personal information very seriously. We take all commercially reasonable measures to prevent unauthorized access to Your Personal information and those data obtained in the process of using the Site. Not only that, but We strive to protect Your Personal information by various means in order to preserve its confidentiality and integrity, prevent unauthorized use or disclosure of Your Personal information, and protect Your Personal information from loss, misuse, disclosure, alteration, and/or destruction.

6.3. Security of Your Personal information

The security of Your Personal information is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable means to protect Your Personal information, We cannot guarantee its absolute security.

We apply a variety of security measures appropriate to the possible risks.

Organizational measures	Staff training
	Internal policies
	Non-disclosure agreements (NDA)
Technical measures	Two-factor authentication
	Backups
	Encryption technologies. We use HTTPS/TLS encryption to protect the Personal information of Our Users.
	We use AES-256-CBC to hash the password.

7. Do We transfer Your Personal information to third parties?

In some cases, Personal information may be available to certain categories of Company’s responsible persons (officials), whose activities are related to ensuring the proper functioning of the Site, or to third-party organizations (such as independent providers of technical services, postal organizations, hosting service providers, companies — providers of information technologies, communication services), contractors and partners of the Company, whom We entrust to perform the functions of the Processor if necessary. You can additionally ask Us for a list of the above-mentioned persons.

IT service providers. We may engage other companies (including foreign ones) that provide administrative and IT services, including hosting services, the use of cloud services, and databases, which will Process the User's Personal information on Our behalf in order to provide technical support and proper functioning of the Site. Such companies may access the User's Personal information only if it is necessary to carry out the above purposes and in accordance with the provisions of the agreements with these companies on the non-disclosure of confidential information, and such companies are not entitled to use it for any other purpose.

We use the services of Elasticsearch, Inc. and its subsidiaries and affiliates and Hetzner Online GmbH to store Personal information. The policy of Hetzner Online GmbH can be found here: https://www.hetzner.com/legal/privacy-policy/.

We use Google Analytics and Google Tags to analyze Your Personal information. Please note that the Personal information collected by Google are transferred to the United States of America. To find out how Google Processes Your Personal information, visit the link: https://policies.google.com/privacy.

We use the Hortaj (Hotjar Ltd.) tool to track the users' behavior on Our Site. The policy of Hotjar Ltd. can be found here: https://www.hotjar.com/legal/policies/privacy/.

Marketing and informational materials are sent to the User in accordance with Section 10 of this Policy using the SendPulse service (SendPulse Inc.). To find out how SendPulse Processes Your Personal information, visit the link: https://sendpulse.com/legal/pp?_gl=1*x7ku3a*_ga*MzQwMjUzODg5LjE3MTU2MDY3NDk.*_ga_46NQ594GKJ*MTcxNTYwNjc0OC4xLjEuMTcxNTYwNjc2MS4wLjAuMTE0NjE3NTI0OA..*_fplc*dlpSR3JrZDlsSVlweEtFSWVOc3lzMkx5WUVWR3RxNmklMkZpQTVMcXRYTkR5OTNrdk1uaFJEenJaajJlRzNIUzJkUjJ3T1VJQ2J1QmJLRmY3NUpNVmpXcnV4cHZrcHcwVnlMWjJUSkRyajFwVUI3cUJKOE9mT3NpeXhSTldUbWclM0QlM0Q.

Authorities (of the USA, European Union, United Kingdom of Great Britain and Northern Ireland, Australia, or other countries). We reserve the right to disclose and/or report any Personal information of the User, if this is required by any law or normative legal act, or a confirmed legal requirement of state authority and/or local authorities, for the purpose of compliance with the requirements of the laws of the applicable legislation, protection of the integrity of the Site, to fulfill the requests of Users, state authorities and/or local authorities, or for the purpose of facilitating any investigation by law enforcement agencies or an investigation aimed at guaranteeing public (national) security. In some cases, We may also provide the User's Personal information to the state authorities and/or local authorities (both national and supranational) in the event of an official request from such an authority as part of a criminal investigation.

8. How can You exercise Your right to privacy?

You, as a Subject of Personal information, have the right to interact with its Personal information directly or through a request to Us. This section describes these rights and how You can exercise them.

Your rights vary depending on the laws that apply to You, but may include:

Right	Description	Area
Right to access	You can request an explanation of the Processing of Your Personal information.	California; Colorado; Connecticut; Indiana; Iowa;	Montana; Tennessee; Texas; Utah; Virginia.
Right to correct	You can change the Personal information if it is inaccurate or incomplete.	California; Colorado; Connecticut; Indiana;	Montana; Tennessee; Texas; Virginia.
Right to delete	You can send Us a request to delete Your Personal information from Our systems.	California; Colorado; Connecticut; Indiana; Iowa;	Montana; Tennessee; Texas; Utah; Virginia.
Right to portability	You can request all the Personal information You provided to Us and request to transfer Personal information to another controller.	California; Colorado; Connecticut; Indiana; Iowa;	Montana; Tennessee; Texas; Utah; Virginia.
Right to opt out of sales	The right to opt out of the sale of Personal information to third parties.	California; Colorado; Connecticut; Indiana; Iowa;	Montana; Tennessee; Texas; Utah; Virginia.
Right to opt out of certain purposes	The right to opt-out of Processing for profiling / targeted advertising purposes.	Colorado; Connecticut; Indiana; Montana;	Tennessee; Texas; Utah; Virginia.
Right to opt out of Processing of sensitive Personal information	The right to opt-out of Processing of sensitive Personal information.	California.
Right to opt in for sensitive Personal information Processing	The right to opt in before Processing of sensitive Personal information.	Colorado; Connecticut; Indiana; Montana;	Tennessee; Texas; Virginia.
Right against automated decision-making	A prohibition against a business making decisions about a consumer based solely on an automated process without human input.	California; Colorado; Connecticut; Indiana; Iowa;	Montana; Tennessee; Texas; Virginia.
Private right of action	The right to seek civil damages from a Company for violations of a statute.	California.
Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If Your state is not on the list, please contact Us [email protected].

To exercise Your rights, please contact Us using the following e-mail address: [email protected]. Please note that before providing the information according to Your request, We may ask You to provide additional Personal information to confirm Your identity.

Please note! Depending on the state and legislative requirements, We have from 30 to 60 days to exercise Your request, with the right to postpone it for 30 days more.

If Your complaint is not satisfied, You can file a complaint with the Federal Trade Commission.

Access to specific Personal information and the right to transfer Personal information

With certain exceptions, if You are a resident of the state of California, USA, You have the right to request a copy of the Personal information We have collected about You in the 12 (twelve) months prior to Your request. After receiving Your request and establishing Your identity, We will inform You of:

– categories of Personal information that We have collected about You;

– Our business or commercial purpose for collecting such Personal information;

– categories of third parties with whom We share this Personal information.

Non-discrimination

We will not discriminate against You for exercising Your rights related to the Processing of Your Personal information, as well as Your right to refuse to receive Our Services in the future, or for refusing to receive further marketing, informational / advertising materials from Us.

Do not sell my Personal information

California residents have the right under the California Consumer Privacy Act to opt out of the “sale” of their Personal information by a company governed by CCPA. We do not and will not “sell” Your Personal information, but We recognize that the CCPA defines “Personal information” in such a way that providing access to identifiers associated with You may be considered a “sale”. In the event that these Site visitor identifiers and inferences may be identified as a sale under the CCPA, please use the “Do not sell my Personal information” setting on the Site's home page. After receiving Your request through the “Do not sell my Personal information” setting, the Company makes a corresponding entry in its database of Personal information / Site Users, which indicates that the Company is aware of the impossibility of further selling Your Personal information. Also, if You would like to record Your preference that We will not “sell” Your Personal information in the future, please contact Us via [email protected].

We generally do not collect information that is considered sensitive Personal information (as defined under the CCPA). In the limited circumstances that We do, such as the collection of Your username and password, We do not collect this information for the purpose of inferring characteristics about You.

9. Cookies

9.1. What are Cookies?

Cookies are small pieces of data (text files) or parts of program code that contain a unique User ID and information about how You use the Site. Cookies are transmitted through a server and stored on Your device when You visit and/or use the Site. The Cookies are installed by a request issued by a web server to a browser (e.g.: Internet Explorer, Chrome, Firefox) and are completely “passive” (does not contain software programs, viruses, or spyware and cannot access the information on the User's hard drive).

A Cookie consists of 2 parts: the name and the content or value of the Cookie. Moreover, the duration of existence of a Cookie is determined; technically, only the web server that sent the Cookie can access it again when a User returns to the website associated with that web server. Cookies themselves do not require Personal information to be used and, in most cases, do not personally identify Internet Users.

Cookies may be stored until You close Your web browser (“session Cookies”) or during a repeat visit (“persistent Cookies”). “Persistent Cookies” remain on the User's device for a certain period of time specified in the Cookies. They are activated every time the User visits the Site.

Cookies may also be used to collect anonymous statistics about the experience of visiting the Site. The data collected is not personally identifiable and is limited to the minimum information necessary to optimize the performance of the Site.

In order to obtain additional general information about Cookies, You can check out information about HTTP Cookies, which is available at the following link: https://en.wikipedia.org/wiki/HTTP_cookie.

9.2. Consent to the use of Cookies

Cookies are not strictly necessary for visiting and/or using the Site (except for the “strictly necessary” type of Cookies) and will be used by Us only after obtaining Your Consent to their use. Once You agree to Our use of Cookies in a separate notice about the use of Cookies, We will consider Your Consent to be obtained.

When You have given Us Your Consent to use Cookies when visiting and/or using the Site, the Processing of the Data collected by Cookies is carried out in accordance with Art. 6(1)(a) GDPR, in accordance with which the Processing shall be lawful only if and to the extent that at least one of the following applies: the data subject has given Consent to the processing of his or her Personal Data for one or more specific purposes. You can familiarize yourself with the text of the GPDR by following the link: https://eur-lex.europa.eu/eli/reg/2016/679/oj.

You may certainly change Your Cookie settings on Your device at any time. For more information, please read the section 9.4 “How You can manage Your Cookies settings”.

9.3. The types of Cookies We collect:

Strictly necessary Cookies. These are essential for the Site's functionality and the use of its features, especially those related to security. Without these Cookies, it is impossible to ensure the proper functioning of the Site. They allow Users to freely use the Site and access various available features.
Statistics Cookies. These Cookies gather information about visits and traffic sources, helping Us assess and enhance the Site's performance. All information collected by these Cookies is aggregated and therefore anonymous.

Marketing Cookies. We may also use Cookies in Our marketing emails (which will be sent only after We have received Your Consent to such sending) to analyze User interaction with Our marketing campaigns. This helps Us fine-tune and make them more convenient.
Preference Cookies. They enable the Site to remember information that changes the way the Site behaves or looks, like Your preferred language or the region You are in.

Name	Provider	Purpose	Expiry Period
searchanalyticsai_session	Company		During the session period
XSRF-TOKEN	Company	Protection against cross-site request forgery	2 minutes
_ga	Google LLC	Used to distinguish users	2 years
_gid	Google LLC	Used to distinguish users	24 hours
_gat If Google Analytics is deployed using Google Tag Manager, this cookie will be named _dc_gtm_<property- id>.	Google LLC	Used to throttle request rate	1 minute
AMP_TOKEN	Google LLC	Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service	from 30 seconds to 1 year
_gac_<property-id>	Google LLC	Contains campaign related information for the user	90 days

We assure You that all information collected through Cookies is used solely for the purposes stated in this Policy, and Cookies in no way are harmful to You or Your device, as they do not make any changes to its configuration.

9.4. How You can manage Cookies settings?

You can change how Cookies are used, including completely blocking or deleting them, through Your web browser settings. Please be aware that disabling or blocking some Cookies may hinder or significantly affect the proper functioning of the Site, potentially slowing it down.

You can configure, block or delete Cookies that are installed on Your computer or mobile device in the settings of Your browser.

When adjusting Your Cookie settings, You can:

delete all Cookies;
block all Cookies;
allow all Cookies;
block third party Cookies (including those set by other online services than the one You are on);
clear all Cookies when You close the web browser;
open “private browsing” / “incognito browsing”, which allows You to browse pages without recording the history of visits or storing local data such as Cookies (at the same time, You should be aware of the limitations of such a function in terms of privacy).

Learn how to manage Cookies in popular web browsers:

Microsoft Edge: Follow the instructions for configuring Cookies in Microsoft Support.
Internet Explorer: Find instructions for configuring Cookies in Microsoft Support.
Google Chrome: Discover how to adjust Cookie settings in Google Support.
Firefox: Get instructions on configuring Cookies in Mozilla Support.
Safari for Mac: Learn about Cookie settings in Apple Support.
Opera: Find instructions on configuring Cookies in Opera Support.
Safari for iOS and iPadOS (iPhone / iPad): Check Cookie settings in Apple Support.
Google Chrome for Android: Learn how to configure Cookie settings in Google Support.

To find information about other web browsers, review the privacy settings in Your browser's settings or visit the website of the developer of the web browser You are using.

If You want to learn more about Cookies or how to control, disable, or delete them, You can visit http://www.aboutcookies.org for additional information.

PLEASE NOTE THAT CHANGES TO THE USE OF COOKIES MAY RESULT IN THE LOSS OF FUNCTIONAL CAPABILITIES OF THE SITE IN PART OR IN FULL.

10. Sending marketing and informational materials to the User

Periodically, with the prior consent of the User, the Company may send informational and promotional messages regarding the Services, news, special tariff plans, and other relevant updates. These messages may include, but are not limited to:

Service Updates: information regarding updates, improvements, or changes to the Services offered by the Company.
Special Offers and Promotions: notifications about special offers, discounts, promotions, or deals available to Users.
Other messages that the Company believes may be of interest and importance to the User.

Consent to receive such messages is given by the User by ticking the appropriate checkbox when filling out the relevant form in which the User has provided his / her e-mail address for receiving marketing messages, which confirms the User's desire to receive such messages and materials.

In the event that the User did not opt in a corresponding mark in the checkbox, We will not send information messages listed above, but will only communicate with the User regarding his / her specific request.

If the User agreed to receive such informational and promotional messages, they will be sent by Us for any reason that We consider to be in the User's interests.

At the same time, the User has the right to withdraw the Consent for the further receipt of the above-mentioned materials by submitting an appropriate objection to their receipt by using the “Unsubscribe” function available at the bottom of the received e-mail message, or by contacting Us via [email protected].

11. Links to other sites

We may post active links to sites that are not maintained by the Company. If You visit such sites, You should review their privacy policies and operating principles. We are not responsible for the Personal information Processing policies and practices of other companies, and any information You provide to such companies is subject to their Company policies.

12. Dispute Resolution

Before filing a claim in court in disputes arising from the relationship between the User and Us, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute). The recipient of the claim shall, within 30 (thirty) calendar days from the date of receipt of the claim, notify the applicant of the claim in writing about the results of the consideration of the claim.

All claims shall be considered by the Company in writing and sent to the Company's e-mail address, namely: [email protected]

In case of failure to reach a compromise, the dispute will be referred to the competent court of the United States of America (Delaware). The Policy is governed by and construed in accordance with the law of the United States of America (Delaware).

13. Changes to the Policy

We have the right to make changes to this Policy at any time and for any reason by posting a new version of the Policy at the above link. We strongly recommend that You check the Policy and the date of the last change from time to time to stay informed of the latest changes.

If You do not agree with any changes made to the Policy, You must stop using the Site, and You can also request the deletion of Your Personal information.

If there are material changes to the Policy or the Site that affect Your data privacy rights, We will notify You by displaying information on the Site and, if necessary, ask for Your Consent.

14. Contact information

If You have any comments, doubts, or questions regarding this Policy, please contact Us at [email protected].

We will try to answer You as soon as possible, but no longer than within 30 (thirty) calendar days.

15. Additional information for the resident of the European Union (EU) and European Economic Area (EEA)

This section applies only to residents of the European Union (EU) and European Economic Area (EEA). The Company Processes Personal Data in accordance with the General Data Protection Regulation (GDPR), the General Data Protection Regulation of Great Britain (UK GDPR).

15.1. Terms used in this section

“Personal Data” — any information relating to a natural person who is identified or can be identified using this information (hereinafter — “Personal Data”).

“Controller” – the Company, which determines the purposes and means of Personal Data Processing, establishes the composition of this Personal Data and the procedures for its Processing.

“Processor” – the Company or other persons that are authorized by the Controller or by law to Process Personal Data on behalf of the Controller.

15.2. Children's Privacy

We knowingly do not Process the Personal Data of children under the age of 13 (applies to Users who are residents of countries with a reduced minimum age for Personal information Processing) and children under 16, and We also do not offer them to use the Site.

If We become aware that a person who has not reached the age from which it is permitted to Process their Personal Data has provided Us with their Personal Data without the Consent of a legal representative, guardian, or other person authorized to provide such Consent, We will take all necessary measures to delete such Data. If You believe We might have any information from or about a child under 16 (or 13 if applicable), please contact Us at [email protected].

15.3. Legal basis for Processing Your Personal Data

To Process Your Personal Data, We rely on the following lawful bases:

performance of the contract — for the Processing of Personal Data necessary for the negotiating on, conclusion, and performance of a contract (mainly, the Terms and Conditions) with You;
legitimate interest — for the Processing necessary for the development of Our Services, taking into consideration Your interests, rights, and expectations;
legal obligation — for the Processing as required by applicable laws (for example, to comply with tax or KYC/AML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorized public body;
consent — for additional specific purposes.

15.4. Where do We store Your Personal Data?

Your Personal Data that We Process may be transferred and stored outside the European Economic Area (EEA):

if there is no adequate decision by the European Commission regarding the country We transfer Personal Data to, We use adopted standard contractual clauses based on legislation assessments for Personal Data protection during transfer and storage;
if there is an adequate decision by the European Commission regarding the country We transfer Personal Data to, We can transfer Personal Data to that third country without any further safeguard being necessary.

15.5. Transfer Your Personal information to third parties

As described in section 7 of the Policy, We may share Your Personal information with third parties such as Google LLC. Google LLC is certified under the EU-U.S. Privacy Shield Framework, a network that protects the fundamental rights of everyone in the European Union whose Personal information is transferred to the United States for commercial purposes. It allows the free transfer of data to companies that are certified in the United States under the Privacy Shield. For more information about the Privacy Shield, please visit the U.S. Department of Commerce's Privacy Shield website: https://www.privacyshield.gov/welcome/.

15.6. Privacy rights

Right to access: You can request an explanation of the Processing of Your Personal Data, as well as details regarding the Processing activities such as the manner in which the Personal Data are processed, the purpose for which the Processing is done, the recipients or the categories of Personal Data recipients, etc.;
Right to rectification: You have the right to obtain the correction, without justified delay, by the Company of inaccurate / unjustified Personal Data, as well as the completion of incomplete Personal Data;
Right to erasure (“right to be forgotten”): You can send Us a request to delete Your Personal Data from Our systems and/or databases. We will remove them unless otherwise provided by law;
Right to restrict the Processing: You may partially or completely prohibit Us from Processing Your Personal Data;
Right to data portability: You can request to receive all the Personal Data You provided to Us in a structured way, commonly used and in an easy-to-read format, as well as the right for this data to be transmitted by the Company to another controller, to the extent that the conditions provided for by law are met;
Right to object: You may object to the Processing of Your Personal Data;
Right not to be subject to an automated individual decision: the right not to be the subject of a decision taken solely on the basis of automated processing activities, including the creation of profiles, which produce legal effects concerning the Subject of Personal Data or similarly affect him in a significant measure;
Right to withdraw Consent: You can withdraw Your Consent at any time;
Right to file a complaint: If Your request was not satisfied, You could file a complaint to the regulatory body of the National Supervisory Authority for the Processing of Personal Data or competent courts, to the extent You deem necessary.

If You are a UK resident, You may lodge a complaint at the other Authority in the UK – Information Commissioner’s Office.

You can contact them at 0303 123 1113 or go online at www.ico.org.uk/concerns.

16. Additional information for residents of Canada

This section applies only to residents of Canada. The Company Processes Personal Data in accordance with the Personal Information Protection and Electronic Documents Act, Personal Information Protection Act of British Columbia, Personal Information Protection Act of Alberta, and Act respecting the protection of personal information in the private sector of Quebec have the right to interact with its data directly or through a request to Us regarding privacy issues.

Right	Description
Right to access	You can request an explanation of the Processing of Your Personal Data.
Right to rectification	You can change the Data if it is inaccurate or incomplete via request or profile settings on the Site.
Right to delete	You can send Us a request to delete Your Personal Data from Our systems or delete Your account via Site settings. We will remove all Data unless some of them We have to store in compliance with the law requirements.
Right to Data portability	You can request all the Personal Data You provided to Us and request to transfer Data to another controller.
Right to object opt-out	You may object to the Processing of Your Personal Data.
Right to withdraw Consent	You can withdraw Your Consent at any time.
Right not to be subject to automated decision-making	You can object to being subject to automated-based Processing to know if there are consequences of them due to such Processing.
Right to lodge a complaint	If Your request is not satisfied, You can file a complaint to the regulatory body.

To exercise Your rights, contact Us at the following e-mail address: [email protected]. We have 30 (thirty) days to exercise Your request from the moment it is received on Our contact email.

We have the right to extend the 30-day period for providing an answer to the request for another 30 (thirty) days in the event that:

failure to respond within the initial 30 (thirty) days may be considered unreasonable interference with our business;
We need additional time for consultation;

We need additional time to convert the Personal Data into a format that is easy to read.

You have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) if We do not respond to Your request within the first 30 (thirty) days.

In the event of a leak of Your Personal Data, We will promptly notify You of such a case and the degree of threat to Your Personal Data. In accordance with PIPEDA, We will immediately notify the Office of the Privacy Commissioner of Canada (OPC) and keep a record of the leak that has occurred.

16.2. Transfer Your Personal information to third parties

We may disclose Personal Data to third-party service providers and related corporations located outside of Canada for the purposes described in the Policy. The Policy requires that the Company share Your Personal Data abroad in a manner that requires the highest standards of confidentiality and security when transferring Personal Data abroad. Please note that when Personal Data is transferred abroad, it may be accessed by courts, law enforcement agencies, and national security agencies. Before disclosing Personal Data, We will assess possible risks that may adversely affect the protection of Personal Data. We ensure the appropriate level of integrity and protection of Personal Data when transferred to third parties, which is required by the provisions of PIPEDA, by entering into agreements with such companies, which provide for the limitation of the use of Personal Data by the third party solely for the purposes provided for in the agreement.

17. Additional information for residents of Australia

This section applies only to residents of Australia. The Company Processes Personal Data in accordance with the Privacy Act 1988 of Australia (“Privacy Act”), as amended from time to time, including the Australian Privacy Principles (“APPs”).

17.1. Terms used in this section

“Personal Data” — any information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not (hereinafter — “Personal Data”, “Data”).

“Processing of Personal Data” – any operation or set of operations related to the collection, holding, use or disclosure of Personal Data by the Company (hereinafter — “Processing”, “Processing of Personal Data”).

17.2. Children's Privacy

We are committed to protecting the privacy of children, and We do not knowingly collect Personal Data from children under the age of 15 (unless a different minimum age is required by applicable law), and We also do not offer them to use the Site.

If You are under 15 years of age (or other minimum age that is required by applicable law), then do not use the Site at any time. If We become aware that a person who has not reached the age from which it is permitted to Process his / her Personal Data has provided Us with their Personal Data without the Consent of a legal representative, guardian, or other person authorized to provide such Consent, We will take all necessary measures to delete such Data. If You believe We might have any information from or about a child under 15 years of age (or other minimum age that is required by applicable law), please contact Us at [email protected] for the purpose of deleting this Data. We bear no responsibility in case if You’re not old enough to use the Site. You must be of legal age to be in line with Our Privacy Policy, as well as with Our Terms & Conditions.

Individuals under the age of 15 are presumed not to have the capacity to Consent. However, individuals under the age of 18 may have the capacity to Consent when they possess sufficient understanding and maturity to comprehend what is being proposed. In some cases, it may be appropriate for a parent or guardian to Consent on behalf of a young person, particularly if the child is young or lacks the maturity or understanding to provide Consent themselves.

17.3. Legal basis for Processing Your Personal Data

To Process Your Personal Data, We rely on the following lawful bases:

Consent: where You have provided explicit Consent for the Processing of Your Personal Data for specific purposes.
Contractual necessity: the Processing of Your Personal Data may be necessary for the performance of a contract to which You are a party, or to take pre-contractual steps at Your request. This includes processing necessary to fulfill requests for products or services You have initiated.
Legal obligation: We may Process Your Personal Data to comply with requirements or authorizations by or under Australian law or a court / tribunal order, or if requested by a law enforcement agency, supervisory authority, or another state-authorized public body.
Legitimate interests: the Processing of Your Personal Data may be based on Our legitimate interests, provided that such interests are not overridden by Your rights and freedoms. This includes processing for purposes such as fraud prevention, network and information security, and business administration.

It's crucial to note that We only Process Your Personal Data on lawful bases as provided by Australian legislation and will ensure that the Processing is fair, transparent, and proportionate to the purposes for which the Data is Processed. We will also respect Your rights and freedoms in accordance with applicable privacy laws.

In accordance with the Australian legislation, APP entities must not collect Personal Data unless the Data is reasonably necessary for, or directly related to, one or more of the entity's functions or activities. Therefore, We will only collect Your Personal Data when it is necessary for carrying out our functions or activities, ensuring compliance with the law and respecting Your privacy rights.

17.4. Privacy rights

You, as a Subject of Personal Data, have the right to interact with its Data directly or through a request to Us. This section describes these rights and how You can exercise them:

Right to access: You can request an explanation of the Processing of Your Personal Data, as well as details regarding the processing activities such as the manner in which the Personal Data are processed, the purpose for which the processing is done, the recipients or the categories of Personal Data recipients, etc.;
Right to rectification: You have the right to obtain the correction, without justified delay, by the Company of inaccurate / unjustified Personal Data, as well as the completion of incomplete Personal Data;
Right to delete: You can send Us a request to delete Your Personal Data from Our systems and/or databases. We will remove them unless otherwise provided by law;
Right to restrict the Processing: You may partially or completely prohibit Us from Processing Your Personal Data;
Right to object: You may object to the Processing of Your Personal Data;
Right to withdraw Consent: You can withdraw Your Consent at any time;
Right to file a complaint: If Your request was not satisfied, You could file a complaint to the regulatory body of the Office of the Australian Information Commissioner (OAIC) or competent courts, to the extent You deem necessary.

In the event that We receive Your request, We will endeavor to respond as soon as possible, but no later than thirty (30) days from the date of receipt of the request.