PRIVACY POLICY

Last updated: 29 October 2020

Introduction

We ("we", "us", "our") take the protection of the data of users ("users" or "you") of our website and/or mobile application (the "Website" and/or the "Mobile App") very seriously and are committed to protecting the information that users provide to us in connection with the use of our website and/or mobile application (collectively, our "Digital Assets").

Furthermore, we are committed to protecting and using your data in accordance with applicable law.

This Privacy Policy explains our practices regarding the collection, use, and disclosure of your information through your use of our Digital Assets (the "Services") when you access the Services via your devices.

Please read this Privacy Policy carefully and ensure that you fully understand our practices regarding your information before using our Services. If you have read and fully understood this Privacy Policy and do not agree with our practices, you must discontinue the use of our Digital Assets and Services. By using our Services, you acknowledge the terms of this Privacy Policy. Your continued use of the Services constitutes your acceptance of this Privacy Policy and any amendments thereto.

This Privacy Policy explains:

How we collect data
What data we collect
Why we collect this data
With whom we share the data
Where the data is stored
How long the data is retained
How we protect the data
How we deal with minors
Updates or changes to this Privacy Policy

What data do we collect?

Below is an overview of the data we may collect:

Non-personal data

Non-identified and non-identifiable information that you provide during the registration process or that is collected through the use of our Services ("Non-Personal Data"). Non-Personal Data does not identify the individual from whom it was collected. The Non-Personal Data we collect mainly consists of technical information and aggregated usage information.

Personal data

Personally identifiable information, meaning information by which you can be identified or could reasonably be identified ("Personal Data"). Personal Data that we collect through our Services may include information requested from time to time, such as names, email addresses, postal addresses, telephone numbers, IP addresses, and more.

Where we combine Personal Data with Non-Personal Data, we will treat the combined information as Personal Data for as long as it remains combined.

How do we collect data?

Below is an overview of the data we may collect:

We collect data when you use our Services. When you visit our Digital Assets and use our Services, we may collect, record, and store usage data, session information, and related information.
We collect data that you voluntarily provide to us, for example when you contact us directly via a communication channel (such as sending us an email containing comments or feedback).
We may collect data from third-party sources, as described below.
We collect data that you provide when you sign in to our Services through a third-party provider such as Facebook or Google.

Why do we collect this data?

We may use your data for the following purposes:

To provide and operate our Services;
To develop, customise, and improve our Services;
To respond to your feedback, enquiries, and requests, and to provide assistance;
To analyse request and usage patterns;
For internal statistical and research purposes;
To improve our data security and fraud prevention capabilities;
To investigate violations and enforce our terms and policies, as well as to comply with applicable laws, regulations, and governmental requests;
To send you updates, notices, promotional materials, and other information relating to our Services. With respect to promotional emails, you may choose whether you wish to continue receiving them. If not, simply click the unsubscribe link included in those emails.

With whom do we share this data?

We may share your data with our service providers in order to operate our Services (for example, third-party hosting providers, technical support providers, and similar service providers).

We may also disclose your data under the following circumstances:

(i) to investigate, detect, prevent, or take action against illegal activities or other wrongdoing;
(ii) to establish or exercise our rights of defence;
(iii) to protect our rights, property, or personal safety, as well as the safety of our users or the public;
(iv) in the event of a change of control involving us or one of our affiliated companies (through a merger, acquisition, or sale of substantially all assets, among others);
(v) to collect, hold, and/or manage your data through authorised third-party providers (such as cloud service providers), where appropriate for business purposes;
(vi) to work together with third parties to improve your user experience.

To avoid any misunderstanding, we wish to point out that we may transfer, disclose, or otherwise use Non-Personal Data at our own discretion.

Blog or Forum

Please note that our Services may enable social interactions (for example, publicly posting content, information, comments, or chatting with other users).

We remind you that any content or data you submit in these areas may be read, collected, and used by others. We advise against posting or sharing information that you do not wish to make public.

If you upload content to our Digital Assets or otherwise make it available while using a Service, you do so at your own risk. We cannot control the actions of other users or members of the public who may have access to your data or content.

You acknowledge and agree that copies of your data may remain accessible even after deletion through cached and archived pages or where third parties have copied or stored your content.

Cookies and Similar Technologies

When you visit or access our Services, we authorise third parties to use web beacons, cookies, pixel tags, scripts, and other technologies and analytics services ("Tracking Technologies").

These Tracking Technologies may enable third parties to automatically collect your information in order to improve the navigation experience on our Digital Assets, optimise their performance, provide a customised user experience, and for security and fraud prevention purposes.

For more information, please read our Cookie Policy.

Advertising Service

Without your consent, we will not share your email address or other Personal Data with advertising companies or advertising networks.

Advertising Service, Campaign Manager, or Facebook Ads

We may deliver advertisements through our Services and our Digital Assets (including websites and applications that use our Services), which may be tailored to you, for example based on your recent browsing activity across websites, devices, or browsers.

To provide these advertisements, we may use cookies, JavaScript, web beacons (including clear GIFs), HTML5 Local Storage, and other technologies.

We may also engage third parties, such as advertising networks (that display advertisements based on your visits to websites), to deliver targeted advertising.

Third-party advertising providers, advertisers, sponsors, and website traffic measurement services may also use cookies, JavaScript, web beacons (including clear GIFs), Flash cookies, and other technologies to measure the effectiveness of their advertisements and customise advertising content for you.

These third-party cookies and technologies are governed by the respective third party's own Privacy Policy and not by this Privacy Policy.

Where do we store the data?

Non-Personal Data

Please note that our companies, as well as our trusted partners and service providers, are located around the world.

For the purposes described in this Privacy Policy, we store and process all Non-Personal Data we collect in various jurisdictions worldwide.

Personal Data

Personal Data may be maintained, processed, and stored in the United States, Ireland, South Korea, Taiwan, Israel, and, where necessary for the proper provision of our Services and/or as required by law (as explained further below), in other jurisdictions.

How long is the data retained?

Please note that we retain the collected data for as long as necessary to provide our Services, comply with our legal and contractual obligations to you, resolve disputes, and enforce our agreements.

We may correct, supplement, or delete inaccurate or incomplete data at any time at our sole discretion.

How do we protect the data?

The hosting service for our Digital Assets provides us with the online platform through which we are able to offer our Services.

Your data may be stored through our hosting provider's data storage systems, databases, and general applications.

Your data is stored on secure servers behind a firewall, and secure HTTPS access is provided for most areas of the Services.

Payments / eCommerce

All payment methods offered by us and our hosting provider for our Digital Assets comply with the PCI-DSS (Payment Card Industry Data Security Standard) of the PCI Security Standards Council.

PCI-DSS is a collaborative standard established by brands such as Visa, MasterCard, American Express, and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information (including physical, electronic, and procedural safeguards) by our online store and service providers.

Notwithstanding the measures and efforts taken by us and our hosting provider, we cannot and do not guarantee the absolute protection or security of any information that you upload, publish, or otherwise transmit to us or to others.

For this reason, we encourage you to use strong passwords and, where possible, not to transmit any confidential information to us or to others if you believe that its disclosure could cause you significant or lasting harm.

As email and instant messaging are not considered secure forms of communication, we also ask that you do not share confidential information through either of these communication channels.

How do we deal with minors?

The Services are not intended for users who have not yet reached the legal age of majority. We do not knowingly collect data from children. If you are under the legal age of majority, you should not download or use the Services or provide us with any information.

We reserve the right to request proof of age at any time in order to verify whether minors are using our Services. If we become aware that a minor is using our Services, we may prohibit and block that user from accessing the Services and delete any data stored about that user.

If you have reason to believe that a minor has shared data with us, please contact us as described below.

We use your Personal Data only for the purposes set out in this Privacy Policy and only where we believe that:

the use of your Personal Data is necessary to perform or enter into a contract with you (for example, to provide the Services or customer and technical support);
the use of your Personal Data is necessary to comply with applicable legal or regulatory obligations;
the use of your Personal Data is necessary to support our legitimate business interests, provided this is carried out in a manner that is proportionate and respects your privacy rights at all times.

Your rights as an EU resident

If you are a resident of the European Union, you have the right to:

request confirmation as to whether or not Personal Data concerning you is being processed, and request access to your stored Personal Data together with certain supplementary information;
request to receive the Personal Data you have provided to us in a structured, commonly used, and machine-readable format;
request the correction of your Personal Data held by us;
request the deletion of your Personal Data;
object to our processing of your Personal Data;
request the restriction of processing of your Personal Data;
lodge a complaint with a supervisory authority.

Please note, however, that these rights are not absolute and may be subject to our own legitimate interests and regulatory obligations.

If you have any general questions about the Personal Data we collect and how it is used, please contact us as described below.

International data transfers

In providing the Services, we may transfer data across borders to affiliated companies or other third parties and from your country or jurisdiction to other countries or jurisdictions worldwide.

By using the Services, you consent to the transfer of your data outside the European Economic Area (EEA).

If you are located within the EEA, your Personal Data will only be transferred to locations outside the EEA where we are satisfied that an adequate or comparable level of protection for Personal Data exists.

We will take appropriate steps to ensure that suitable contractual arrangements are in place with our third-party providers to safeguard your Personal Data and minimise the risk of unlawful use, alteration, deletion, loss, or theft, while ensuring compliance with applicable laws at all times.

Rights under the California Consumer Privacy Act (CCPA)

If you use the Services as a resident of California, you may be entitled under the California Consumer Privacy Act (CCPA) to request access to or deletion of your information.

To exercise your right of access or deletion, please contact us as described below.

Website does not sell user data

We do not sell users' Personal Data for the purposes of the CCPA.

Blog and/or forum

Users of the Services who are California residents and under the age of 18 may request the removal of content they have publicly posted by contacting us via email using the address provided in the "Contact" section below.

Such requests must be clearly marked "California Removal Request."

All requests must include a description of the content you wish to have removed, along with sufficient information to enable us to locate the relevant material.

Requests that are not properly labelled or do not contain sufficient information may not be processed.

Please note that your request does not guarantee the complete or comprehensive removal of the material, as content may have been copied, reposted, or otherwise redistributed by other users or third parties.

Updates or Changes to this Privacy Policy

We may revise this Privacy Policy from time to time at our sole discretion.

The version published on this Website is always the current version (see the "Last updated" date).

We encourage you to review this Privacy Policy regularly for any changes.

Where significant changes are made, we will publish a notice on our Website.

Your continued use of the Services following notification of changes constitutes your acknowledgement and acceptance of those changes and your agreement to be bound by the updated Privacy Policy.

Contact

If you have any general questions about the Services or about the information we collect and how it is used, please contact us at:

Name: AF-INTERMEDIARY LIMITED

Address: Stymfalidon Str. 46, BayViewGarden 11, 4046 Limassol-Germasogeia, Cyprus

Email: farr (dot) alexx (at) gmail (dot) com

DISCLAIMER

The information contained herein does not constitute legal advice and should not be relied upon as such.

Specific legal requirements concerning policies and legal terminology may vary from country to country and from one legal jurisdiction to another.

As stated in our Terms of Use, you are responsible for ensuring that your Services comply with the laws applicable to you and that you adhere to those laws.

To ensure full compliance with your legal obligations, we strongly recommend that you seek professional legal advice to better understand the specific requirements applicable to your circumstances.