PRIVACY POLICY
Effective Date: December, 2023
This privacy policy (the “Policy”) is an integral part of the [email protected] Terms of Use (the “Agreement”). All the terms used herein are used with the same meanings as the Agreement provides unless otherwise are directly set out hereby.
We are committed to protecting and respecting your privacy, so we take your privacy seriously and will use your personal data (the “data”) to make the Website available and process your requests sent to us only after obtaining your consent for the collection and processing of your data as follows. The Policy explains what data, when, where, and why we collect the data of yours, on what legal basis we process and how do we use it, the conditions under which we may disclose the data to others, your rights in respect of your personal information, as well as how we keep it secure.
Since we use tracking technologies on the Website (cookies), please check our Cookies Policy Section, where we also describe the purpose and means we do it with.
Whether you have any questions, please contact us at: [email protected]
1. CHANGES AND UPDATES TO POLICY
1.1. We may revise the Policy according to new developments or advances in legislation and the broader data protection landscape from time to time, so please check this page to ensure that you're OK with any changes.
1.2. If we make any material changes, we will notify you by email (to the address provided by you). A notification regarding other changes may be rendered to you by publishing at [email protected].
2. YOUR DATA CONTROLLER AND DATA PROCESSORS; THIRD PARTIES
2.1. The first you should know is information about your data controller and processors. The data controller is an entity that determines the purposes and means of the processing of the data. The data processor is an entity that processes the data on behalf of the controller.
2.2. In this current case, your data controller is Bonimor Limited.
2.3. When processing your data, we may use the following data processors:
- G-Suite service which may be represented by Google LLC (California, USA), Google Ireland Limited (the Republic of Ireland), Google Asia Pacific Pte. Ltd. (Singapore), or any other entity that directly or indirectly controls, is controlled by, or is under common control with Google LLC, which is a storage place provider, in order to store the data. Google provides more information on how it processes data in its Privacy Policy;
- Google Analytics services which may be represented by Google LLC (California, USA), Google Ireland Limited (the Republic of Ireland), Google Asia Pacific Pte. Ltd. (Singapore), or any other entity that directly or indirectly controls, is controlled by, or is under common control with Google LLC, which is an analytical services provider, in order to analyze the data. Google provides more information on how it processes data in its Privacy Policy;
- Facebook Ads Pixel services represented by Facebook, Inc. with a registered office at 1601 Willow Road, Menlo Park, CA, 94025, USA, which is an analytical services provider, in order to analyze the data. Facebook provides more information on how it processes data in its Privacy Policy;
- LinkedIn Ads Pixel services represented by LinkedIn Corporation with a registered office at 1000 W Maude, Sunnyvale, CA 94085, US, which is an analytical services provider, in order to analyze the data. LinkedIn provides more information on how it processes data in its Privacy Policy;
2.4. Where there will be a necessity, we may also engage third-party services and may share the data with them. That will help us operate, provide, improve, integrate, customize, support, and market our service and the Website. We share the data, in particular, for purposes indicated in section 5 hereof. The types of third parties we share information with include, in particular: cloud storage providers; data analytics providers; measurement partners; marketing partners; payment processing providers; communication services providers, etc. By providing us with the services, those providers will also be your data processors.
2.5. We may also use and disclose the data to enforce the Agreement, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
2.6. If we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission, or (ii) the European Commission adequacy decisions about certain countries (details available here).
2.7. Website contains links to other websites. This privacy policy only applies to this Website and doesn't cover other sites that we link to. If you go to another website, read the privacy policy on that website to find out what it does with your information.
3. NOTE ABOUT CHILDREN
3.1. You are prohibited to use the website where you are under 18 or age of legal majority in your country. We do not knowingly process personal data from persons under 18 years of age.
3.2. If a minor submits personal information to us and we learn that the personal information is the information of a child under the legal age range, we will attempt to delete the information as soon as possible. If you believe that we may have any personal information of a child under the legal age range, please contact us at [email protected].
4. DATA THAT WE PROCESSES
4.1. The data is any information relating to you. That alone or in cumulative with other information pieces allows the person who collected and processed such information to identify you as a person. Processing of the data means any action with your data, including, but not limited to, collecting, storing, transferring, etc.
4.2. We solely or with help of data processors may collect the following data about you: a) the data we receive when you contact us: name, email, mobile phone number; b) the data we receive when you use the Website, including, without limitation: duration of a session; the history of the interaction of the Website; surveys responses, data you provided our support team with, including, the language of your requests; other information you may voluntarily provide us with whether by adding in your profile or sending us direct messages; c) the data we collect automatically: data about how you found us; IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, country, region, city; your activity on the Website; d) cookies and other tracking identifiers as our Cookies Policy Section set forth;
5. PURPOSES AND LEGAL BASSES OF DATA PROCESSING
5.1. We process your information with the following purposes: a) to make the Website available for your access as well as provide you with the most relevant services with the Website; b) to communicate with you regarding your use of the Website, your requests, update you on services, information, and products; c) to notify you of any crucial information or changes within the Website which may affect you; d) to analyze active users' number, support users from different regions and provide proper work of various versions of the Website as well as to develop and optimize the Website; e) to keep the Website safe and secure, enforce the Agreement and prevent and combat fraud; f) to generate statistical studies of market; g) to comply with our legal obligations.
5.2. We may also send you news and information about us and the Website that you either request from us, or we believe may interest you. In most cases, we will contact you via email.
5.3. We process your data under the following legal bases:
- performing of the contract (the Agreement) with you: a) to make the Website available for your access as well as provide you with the most relevant services with the Website; b) to communicate with you regarding your use of the Website, your requests, update you on services, information, and products; c) to notify you of any crucial information or changes within the Website which may affect you;
- our legitimate interest: a) to send to you marketing communications; b) to analyze active users' number, support users from different regions and provide proper work of various versions of the Website as well as to develop and optimize the Website; c) to keep the Website safe and secure, enforce the Agreement and prevent and combat fraud; and d) to comply with our legal obligations.
5.4. Please note, when the data is collected for marketing purposes you will be additionally asked for such processing. Furthermore, you will at any time have the possibility to withdraw your consent free of charge by clicking on a separate “Unsubscribe button” in the email sent.
6. DURATION AND LOCATION OF PROCESSING
6.1. Your data will be processed within the term of your use of the Website and up to termination of such use (or the Agreement) which means the deletion or blocking or suspending of your account on the Website; we shall terminate the processing of your personal information unless the special retention period for the storage of such data is set by the relevant legislation then.
6.2. You are entitled to restrict us to process your data by sending to us a data erasure request or a notice of prohibition to process your data. Please be warned that such action prohibits us from processing your data and/or makes us delete your data so you may lose your access to the Website. It also may prohibit us from replying to your inquiries.
6.3. Our servers are based in the USA.
7. COOKIES POLICY AND TRACKING TECHNOLOGIES
7.1. We use cookies and some of others tracking technologies to improve your user experience and obtain data about how the website is being used. This data enables us to develop and optimize the Website.
7.2. The cookies on our website are either set by us or by third-party partners and fall into the following categories:
First Party Cookies
| Cookie Name | Description | Duration |
|---|---|---|
| mtid | Used to store information about the advertising source you reached the site from. | Session |
| gclid | Used to store information about the advertising source you reached the site from. | Session |
| refurl | Used to store information about the website that referred you to our website. | Session |
| lpg | Used to store information about the page you first landed on when visiting our site. | Session |
Third Party Services
| Service | Description |
|---|---|
| Google Analytics | Collects statistical information about how you use the site so that we can improve the site. |
| Google AdWords | Tracks performance of advertising campaigns. |
| Facebook Ads | Tracks performance of advertising campaigns. |
| Bing | Tracks performance of advertising campaigns. |
| Optin Monster | Provides offers to specific customers. |
Third Party Cookies
| Cookie Name | Description | Duration |
|---|---|---|
| _ga | Google Analytics cookie used to identify unique users. | 2 years |
| _gat | Google Analytics cookie that limits the number of requests made to their servers. | 10 minutes |
| _spin | Facebook advertiser cookies are used for reporting on social campaign | 1 year |
| _sb | Facebook cookie used to detect browser | 10 minutes |
| _xs | Facebook cookie used alongside c_user to authenticate user's identity | 1 year |
| _datr | Facebook cookie used to identify the web browser being used to connect to Facebook independent of the logged in user. | 2 years |
7.3. You can withdraw your consent and delete cookies whenever you want, you can do that by choosing the appropriate settings of your browser:
- For the users of Internet Explorer
- For the users of Firefox
- For the users of Chrome
- For the users of Safari web and iOS.
- For the users of Android.
7.4. The processing of the data that we collect with these technologies, where it is personal data, falls within the Privacy Policy. For example, our employees and subcontractors may be able to access this data. Moreover, your data may be processed on our behalf by the third-party service providers mentioned above. For more information on our practices, see the Privacy Policy.
8. YOUR DATA SUBJECT'S RIGHTS
8.1. Being a data subject, you have the following rights: a) a right to request us to access to your data: you can ask us what personal information of yours is being processed as well as for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties that have access to information. To exercise the right please contact us at [email protected]; b) a right to request us to rectify your personal information: you can ask for all the inaccurate personal information concerning you being corrected. You can also complete the personal information if you feel there is a need to do so. To exercise the right please contact us at [email protected] or use a specific area of your account on the Website; c) a right to request us to erase personal information: you can request us to erase such data if its processing is no longer necessary in relation to the purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases we will erase it unless otherwise will be required by legislation. To exercise the right please contact us at [email protected]; d) a right to request us to restrict the processing of your data: for example, if you contest the accuracy of your data being processed or in case we will not be interested to process your personal information any longer, but you will want us to do this on different reasons, for example, to bring some claim for somebody and instead of the erasure of information its processing will be just restricted. To exercise the right please contact us at [email protected]; e) a right to withdraw your consent for the collection and processing of your data by us at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To exercise the right please contact us at [email protected]; f) a right to lodge a complaint with supervisory authority; and g) a right to data portability. To exercise the right please contact us at [email protected].
8.2. We will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if we are overwhelmed by the number of requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
9. PROTECTION OF DATA
We take technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. For example, we use verified contractors that might have access to the data as specified in section 4 hereof with which the relevant data processing agreements are signed.
10. CONTACT US
If you have any questions regarding this Policy, please contact us at [email protected].
This Privacy Policy was last updated on April 1, 2022