Privacy policy 
We respect your privacy and are committed to protecting it through our compliance with this privacy policy(“Policy”). This Policy describes the types of information we may collect from you or that you may provide(“Personal Information”) on the 
website (“Website”), “” mobile application (“MobileApplication”), and any of their related products and services (collectively, “Services”), and our practices forcollecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choicesavailable to you regarding our use of your Personal Information and how you can access and update it. 

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and this Website operator andMobile Application developer (“Operator”, “we”, “us” or “our”). If you are entering into this agreement on behalf of abusiness or other legal entity, you represent that you have the authority to bind such entity to this agreement, inwhich case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you donot agree with the terms of this agreement, you must not accept this agreement and may not access and use theServices. By accessing and using the Services, you acknowledge that you have read, understood, and agree to bebound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own orcontrol, or to individuals that we do not employ or manage. 

Automatic collection of information 
When you open the Website or use the Mobile Application, our servers automatically record information that yourbrowser or device sends. This data may include information such as your device’s IP address and location,browser and device name and version, operating system type and version, language preferences, the webpage youwere visiting before you came to the Services, pages of the Services that you visit, the time spent on those pages,the information you search for on the Services, access times and dates, and other statistics. 
Information collected automatically is used only to identify potential cases of abuse and establish statisticalinformation regarding the usage and traffi c of the Services. This statistical information is not otherwiseaggregated in such a way that would identify any particular User of the system. 

Collection of personal information 
You can access and use the Services without telling us who you are or revealing any information by whichsomeone could identify you as a specifi c, identifi able individual. If, however, you wish to use some of the featuresoffered on the Services, you may be asked to provide certain Personal Information (for example, your name and e-mail address). 

We receive and store any information you knowingly provide to us when you create an account, make a purchase,or fi ll any forms on the Services. When required, this information may include the following: 
- Account details (such as user name, unique user ID, password, etc) 
- Contact information (such as email address, phone number, etc) 
- Basic personal information (such as name, country of residence, etc) 
- Payment information (such as credit card details, bank details, etc) 
You can choose not to provide us with your Personal Information, but then you may not be able to take advantageof some of the features on the Services. Users who are uncertain about what information is mandatory arewelcome to contact us. 

Privacy of children 
We do not knowingly collect any Personal Information from children under the age of 13. If you are under the ageof 13, please do not submit any Personal Information through the Services. If you have reason to believe that achild under the age of 13 has provided Personal Information to us through the Services, please contact us torequest that we delete that child’s Personal Information from our Services. 
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policyby instructing their children never to provide Personal Information through the Services without their permission.We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions toensure that their children are instructed to never give out Personal Information when online without theirpermission. 

Use and processing of collected information 
We act as a data controller and a data processor in terms of the GDPR when handling Personal Information, unlesswe have entered into a data processing agreement with you in which case you would be the data controller and wewould be the data processor. 
Our role may also differ depending on the specifi c situation involving Personal Information. We act in the capacityof a data controller when we ask you to submit your Personal Information that is necessary to ensure your accessand use of the Services. In such instances, we are a data controller because we determine the purposes andmeans of the processing of Personal Information and we comply with data controllers’ obligations set forth in theGDPR. 
We act in the capacity of a data processor in situations when you submit Personal Information through theServices. We do not own, control, or make decisions about the submitted Personal Information, and such PersonalInformation is processed only in accordance with your instructions. In such instances, the User providing PersonalInformation acts as a data controller in terms of the GDPR. 
In order to make the Services available to you, or to meet a legal obligation, we may need to collect and use certainPersonal Information. If you do not provide the information that we request, we may not be able to provide youwith the requested products or services. Any of the information we collect from you may be used for the followingpurposes: 
Deliver products or services 
Run and operate the Services 
Processing your Personal Information depends on how you interact with the Services, where you are located in theworld and if one of the following applies: (i) you have given your consent for one or more specifi c purposes; this,however, does not apply, whenever the processing of Personal Information is subject to European data protectionlaw; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which youare subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of offi cialauthority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or bya third party. We may also combine or aggregate some of your Personal Information in order to better serve youand to improve and update our Services. 
We rely on the following legal bases as defi ned in the GDPR upon which we collect and process your PersonalInformation: 
User’s consent 
Note that under some legislations we may be allowed to process information until you object to such processingby opting out, without having to rely on consent or any other of the legal bases above. In any case, we will be happyto clarify the specifi c legal basis that applies to the processing, and in particular whether the provision of PersonalInformation is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

Payment processing 
In case of Services requiring payment, you may need to provide your credit card details or other payment accountinformation, which will be used solely for processing payments. We use third-party payment processors (“PaymentProcessors”) to assist us in processing your payment information securely. 
Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council,which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private dataexchange happens over a SSL secured communication channel and is encrypted and protected with digitalsignatures, and the Services are also in compliance with strict vulnerability standards in order to create as secureof an environment as possible for Users. We will share payment data with the Payment Processors only to theextent necessary for the purposes of processing your payments, refunding such payments, and dealing withcomplaints and queries related to such payments and refunds. 
Please note that the Payment Processors may collect some Personal Information from you, which allows them toprocess your payments (e.g., your email address, address, credit card details, and bank account number) andhandle all the steps in the payment process through their systems, including data collection and data processing.Where necessary for processing future or recurring payments and subject to your prior consent, your fi nancialinformation will be stored in encrypted form on secure servers of our Payment Processors. The Payment 
Processors’ use of your Personal Information is governed by their respective privacy policies which may or maynot contain privacy protections as protective as this Policy. We suggest that you review their respective privacypolicies. 

Managing information 
You are able to delete certain Personal Information we have about you. The Personal Information you can deletemay change as the Services change. When you delete Personal Information, however, we may maintain a copy ofthe unrevised Personal Information in our records for the duration necessary to comply with our obligations to ouraffi liates and partners, and for the purposes described below. If you would like to delete your Personal Informationor permanently delete your account, you can do so on the settings page of your account on the Services. 

Disclosure of information 
Depending on the requested Services or as necessary to complete any transaction or provide any Service you haverequested, we may share your information with our affi liates, contracted companies, and service providers(collectively, “Service Providers”) we rely upon to assist in the operation of the Services available to you and whoseprivacy policies are consistent with ours or who agree to abide by our policies with respect to PersonalInformation. We will not share any personally identifi able information with third parties and will not share anyinformation with unaffi liated third parties. 
Service Providers are not authorized to use or disclose your information except as necessary to perform serviceson our behalf or comply with legal requirements. Service Providers are given the information they need only inorder to perform their designated functions, and we do not authorize them to use or disclose any of the providedinformation for their own marketing or other purposes. 
We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such asto comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessaryto protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a governmentrequest. 
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of allor a portion of its assets, your user account, and your Personal Information will likely be among the assetstransferred. 

Retention of information
We will retain and use your Personal Information for the period necessary as long as your user account remainsactive, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permittedby law. 
We may use any aggregated data derived from or incorporating your Personal Information after you update ordelete it, but not in a manner that would identify you personally. Once the retention period expires, Personal 
Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectifi cation, and theright to data portability cannot be enforced after the expiration of the retention period. 

Transfer of information 
Depending on your location, data transfers may involve transferring and storing your information in a country otherthan your own. However, this will not include countries outside the European Union and European Economic Area.If any such transfer takes place, you can fi nd out more by checking the relevant sections of this Policy or inquirewith us using the information provided in the contact section. 

Data protection rights under the GDPR 
If you are a resident of the European Economic Area (“EEA”), you have certain data protection rights and we aim totake reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If youwish to be informed what Personal Information we hold about you and if you want it to be removed from oursystems, please contact us. In certain circumstances, you have the following data protection rights: 
(i) You have the right to withdraw consent where you have previously given your consent to the processing of yourPersonal Information. To the extent that the legal basis for our processing of your Personal Information is consent,you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processingbefore the withdrawal. 
(ii) You have the right to learn if your Personal Information is being processed by us, obtain disclosure regardingcertain aspects of the processing, and obtain a copy of your Personal Information undergoing processing. 
(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You alsohave the right to request us to complete the Personal Information you believe is incomplete. 
(iv) You have the right to object to the processing of your information if the processing is carried out on a legalbasis other than consent. Where Personal Information is processed for the public interest, in the exercise of anoffi cial authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to suchprocessing by providing a ground related to your particular situation to justify the objection. 
(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information. Thesecircumstances include: the accuracy of your Personal Information is contested by you and we must verify itsaccuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request therestriction of its use instead; we no longer need your Personal Information for the purposes of processing, but yourequire it to establish, exercise or defend your legal claims; you have objected to processing pending theverifi cation of whether our legitimate grounds override your legitimate grounds. Where processing has beenrestricted, such Personal Information will be marked accordingly and, with the exception of storage, will beprocessed only with your consent or for the establishment, to exercise or defense of legal claims, for theprotection of the rights of another natural, or legal person or for reasons of important public interest. 
(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us.These circumstances include: the Personal Information is no longer necessary in relation to the purposes forwhich it was collected or otherwise processed; you withdraw consent to consent-based processing; you object tothe processing under certain rules of applicable data protection law; the processing is for direct marketingpurposes; and the personal data have been unlawfully processed. However, there are exclusions of the right toerasure such as where processing is necessary: for exercising the right of freedom of expression and information;for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims. 
(vii) You have the right to receive your Personal Information that you have provided to us in a structured, commonlyused, and machine-readable format and, if technically feasible, to have it transmitted to another controller withoutany hindrance from us, provided that such transmission does not adversely affect the rights and freedoms ofothers. 
(viii) You have the right to complain to a data protection authority about our collection and use of your PersonalInformation. If you are not satisfi ed with the outcome of your complaint directly with us, you have the right to lodgea complaint with your local data protection authority. For more information, please contact your local dataprotection authority in the EEA. This provision is applicable provided that your Personal Information is processedby automated means and that the processing is based on your consent, on a contract which you are part of, or onpre-contractual obligations thereof. 

How to exercise your rights 
Any requests to exercise your rights can be directed to us through the contact details provided in this document.Please note that we may ask you to verify your identity before responding to such requests. Your request mustprovide suffi cient information that allows us to verify that you are the person you are claiming to be or that you arethe authorized representative of such person. If we receive your request from an authorized representative, wemay request evidence that you have provided such an authorized representative with power of attorney or that theauthorized representative otherwise has valid written authority to submit requests on your behalf. 
You must include suffi cient details to allow us to properly understand the request and respond to it. We cannotrespond to your request or provide you with Personal Information unless we fi rst verify your identity or authority tomake such a request and confi rm that the Personal Information relates to you. 

Our Services use “cookies” to help personalize your online experience. A cookie is a text fi le that is placed on yourhard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer.Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie toyou. You may learn more about cookies and how they work in 
this guide 

We may use cookies to collect, store, and track information for security and personalization, and for statisticalpurposes. For further information on the cookies we collect and their purpose, see our 
cookie policy 
. Please note 
that you have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default,but you can modify your browser settings to decline cookies if you prefer. 

Data analytics 
Our Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered isused to compile statistical reports on User activity such as how often Users visit our Services, what pages theyvisit and for how long, etc. We use the information obtained from these analytics tools to monitor the performanceand improve our Services. We do not use third-party analytics tools to track or to collect any personally identifi ableinformation of our Users and we will not associate any information gathered from the statistical reports with anyindividual User. 

Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to haveyour online activity tracked. Tracking is not the same as using or collecting information in connection with awebsite. For these purposes, tracking refers to collecting personally identifi able information from consumers whouse or visit a website or online service as they move across different websites over time. How browserscommunicate the Do Not Track signal is not yet uniform. As a result, the Services are not yet set up to interpret orrespond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughoutthis Policy, we limit our use and collection of your Personal Information. 

Push notifications 
We offer push notifi cations to which you may voluntarily subscribe at any time. To make sure push notifi cationsreach the correct devices, we use a third-party push notifi cations provider who relies on a device token unique toyour device which is issued by the operating system of your device. While it is possible to access a list of devicetokens, they will not reveal your identity, your unique device ID, or your contact information to us or our third-partypush notifi cations provider. We will maintain the information sent via e-mail in accordance with applicable lawsand regulations. If, at any time, you wish to stop receiving push notifi cations, simply adjust your device settingsaccordingly. 

Links to other resources 
The Services contain links to other resources that are not owned or controlled by us. Please be aware that we arenot responsible for the privacy practices of such other resources or third parties. We encourage you to be awarewhen you leave the Services and to read the privacy statements of each and every resource that may collectPersonal Information. 

Information security 
We secure information you provide on computer servers in a controlled, secure environment, protected fromunauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physicalsafeguards in an effort to protect against unauthorized access, use, modifi cation, and disclosure of PersonalInformation in our control and custody. However, no data transmission over the Internet or wireless network can beguaranteed. 
Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security andprivacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and allinformation and data exchanged between you and the Services cannot be guaranteed; and (iii) any suchinformation and data may be viewed or tampered with in transit by a third party, despite best efforts. 
As the security of Personal Information depends in part on the security of the device you use to communicate withus and the security you use to protect your credentials, please take appropriate measures to protect thisinformation. 

Data breach 
In the event we become aware that the security of the Services has been compromised or Users’ PersonalInformation has been disclosed to unrelated third parties as a result of external activity, including, but not limitedto, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but notlimited to, investigation and reporting, as well as notifi cation to and cooperation with law enforcement authorities.In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that thereis a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When wedo, we will send you an email. 

Changes and amendments 
We reserve the right to modify this Policy or its terms related to the Services at any time at our discretion. Whenwe do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other waysat our discretion, such as through the contact information you have provided. 
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unlessotherwise specifi ed. Your continued use of the Services after the effective date of the revised Policy (or such otheract specifi ed at that time) will constitute your consent to those changes. However, we will not, without yourconsent, use your Personal Information in a manner materially different than what was stated at the time yourPersonal Information was collected. 

Acceptance of this policy 
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and usingthe Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide bythe terms of this Policy, you are not authorized to access or use the Services. 

Contacting us 
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or ifyou wish to exercise your rights, we encourage you to contact us using the details below: 
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish toexercise your rights as quickly as possible and in any event, within the timescales provided by applicable dataprotection laws. 
This document was last updated on December 22, 2021