11 Mnasiadou Street
1065 Nicosia, Cyprus
Effective Date: March 20th, 2022
UNITED STATES USERS
If you are a United States resident and/or are accessing, viewing, and/or using our Website in the United States, the following privacy terms will apply.
COLLECTION OF INFORMATION & DATA FROM OUR USERS
We may collect personally identifiable information that you provide to us through the Website. This is done via registration forms, surveys, applications, billing process, input questions, and other online fields, including, but not limited to, your name, email address(es), your mailing address, VAT number(s), telephone number(s), username(s), profile photos and images you upload, and/or other relevant personal information (collectively, the “Personal Information”). You may be required to provide us with Personal Information to complete your registration profile, view any of our Products and Services, and/or to access, download, and purchase our Products and Services through our Website. Some of your Personal Information submitted by you and collected by us may be stored and maintained by third-party data processors, including, but not limited to, Google.
We also collect and track certain information about you that may not
constitute Personal Information. This includes, but may not be limited to:
• Collecting and tracking your session ID;
• Your server domain names;
• Date and time of your visit(s) to our Website;
• The originating IP address(es);
• Files viewed and downloaded by you;
• Search engine(s) used by you to find our Website;
• The type of operating system you use;
• Various information and data on how you use our Website, such as the page(s) visited within our Website, and the type of Web browser(s) for Users of our Website;
• The language you use in your web browser(s);
• Operating system(s) on your computer(s);
• Your mobile device type and related technical information;
• Your geo-location data;
• The state or country from which you access our Website;
• The Web pages visited (including the date and the time of a visit) immediately before and after visiting the Website using cookies;
• The number of links you click within our Website;
• The functions you use on our Website;
• The specific Products and Services that you access on our Website;
• The data you view, save on, or download from our Website;
• Http headers;
• Facebook Pixel-specific data (such as Pixel ID Facebook Cookie);
• Optional values such as custom data events and conversion values;
• And/or the number of times you view any advertisement(s) on our Website (the “User Data”).
We also may aggregate any such User Data, which is typically collected, analyzed and maintained in aggregated and de-identified formats.
HOW WE COLLECT INFORMATION
To collect User Data, we currently use Google Analytics, Sideqik, Snapchat, and Convert Flow (collectively, “Data Processors”) to track and collect information on our Website. By accessing, viewing, and using our Website, you agree to the our Data Processors’ respective Terms of Service, which are hyperlinked above.
Using our Data Processors, we will collect Personal Information and User Data (collectively, the “Information”) about you with "cookies", or other electronic tools or other similar authenticating or tracking technologies on your computer’s and/or devices’ hard drive to collect traffic and User use information.
If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You may, at your option, disable cookies through each of your individual browsers. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of our Website, the data, information, content, materials and/or our Products and Services contained on or accessed through our Website, will not function properly. You agree that we are not liable for any portion of the Website that does not operate properly after you take these actions.
Other 3rd Party Processors and Collected Information
We also use various other third party processors in order to provide you with our Products and Services, enhance your user experience on our Website, create user accounts, enable login functionality, provide you updates and various promotions and offers, provide receipts for Products and Services ordered, and enable our Website to function smoothly. These third-party processors may at various times have access to, and store, Personal Information and User Data. Our processors currently are the following (“Processors”): Google, Meta (Facebook), ActiveCampaign, Quora, Reddit, Twitter, Zapier, Convert Flow, Sideqik, Snapchat, Typesense, Recurly, FutureHosting, BrainTree, PayPal, ZenDesk, Tapfiliate. By accessing and viewing our Website, providing your Information, and accessing our Products and Services, you agree to each of our Processor’s privacy policies.
OUR USE OF COLLECTED INFORMATION
Other than to the Processors listed above, we do not sell or distribute your
Personal Information or User Data to third parties. However, we will use the
Information collected for the reasons listed above, as well as for other
internal reasons, including, but not limited to: • (a) monitoring,
researching, and analyzing traffic flow on our Website;
• Better service provision for Users of our Website;
• Compilation and aggregation of anonymous information about usage of our Website and the Services;
• Provide announcements about Website features, products, and updates, and/or
• Provide various product and service promotions. In addition, we will use your Personal Information to maintain contact with you.
DISCLOSURE OF PERSONAL INFORMATION
We will only share your Information with our Processors, partners, subsidiaries, affiliates, and parent companies on an anonymous and aggregate basis where possible. However, we may also disclose your Information to unaffiliated third parties if we believe in good faith that such disclosure is necessary, including, to: (a) comply with the law or in response to a subpoena, court order, government request, and/or other legal process; (b) produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, and/or other legal or administrative proceedings; and/or (c) protect the interests, rights, safety, or property of our Users or others.
SECURITY OF PERSONAL INFORMATION
Any Personal Information you provide to us is kept on secure servers. We use commercially reasonable administrative, technical, personnel, and physical measures and efforts: (a) to safeguard Personal Information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the Personal Information. To help us protect your privacy, you should maintain the secrecy of any login ID(s) and password(s) you may have set up in connection with your viewing and access of our Website, and the use of our Services.
Despite our efforts to protect your Personal Information, the confidentiality of any communication or material transmitted to or from us via our Website, the Services, or via e-mail cannot be, and is not, guaranteed. Accordingly, you agree that we are not responsible for the security of information transmitted to or from you via the Internet.
In addition, to protect your Personal Information, never share your password and/or Personal Information with anyone. If you feel that your password or Personal Information has been discovered or compromised, you should change it immediately by logging onto our Website and accessing your profile to change your password.
ACCESS TO, AND ABILITY TO CORRECT, PERSONAL INFORMATION
You may modify, correct, change or update your Personal Information by contacting us at firstname.lastname@example.org. We will make commercially reasonable efforts to accommodate your request and typically process requests within thirty (30) calendar days from receipt of your request(s). However, we reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by law.
STORING & DELETING YOUR INFORMATION
We store certain Information for various periods of time. Various data can be
deleted by you in your account settings or by sending us a written request to
email@example.com. As stated above, we typically remove this information
within thirty (30) calendar days from receipt of your request. For: • Your
username, email address, and Session ID(s) – we store this until you request
we delete this information;
• Your mailing address, and VAT number(s) (where applicable) – we store this until you either manually delete such information from your account settings, or until you request we delete this information;
• The last four (4) digits of your credit card and credit card expiration date – we store until you request we delete this information; and
• Billing address, email address, and PayPal recurring token for PayPal transactions - we store this until you request we delete this information.
Please note that all financial data for carrying out various transactions is
conducted currently through JCC, and thus such credit card and related data is
collected, stored, and used according to JJC’s terms and conditions, and
data is collected, stored, and used according to Braintree’s terms and
our Website, and purchasing our Products and Services, you agree that: • We
can transfer your credit card information,
• Purchase history; and
• Related data from JCC to Braintree, as well as to other third-party credit card processors of our choosing from time to time.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California Civil Code Section 1798.83 provides you with the right to request certain information regarding disclosure of your Personal Information to third parties for direct marketing purposes, including a description of the categories of Personal Information, be disclosed. In order to obtain such information, please email your request to firstname.lastname@example.org.
USERS FROM THE EUROPEAN UNION AND THE UK
THE LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA
In processing or holding your personal data in connection with the purposes
legal reasons, depending on the circumstances, where: • We have obtained your
prior informed consent to the processing (this legal basis is only used in
relation to processing that is entirely voluntary, i.e it is not used for
processing that is necessary or obligatory in any way) of your personal
• The processing is necessary in connection with any contract that you may enter into with Us;
• The processing is required by the applicable law;
• The processing is necessary to protect the vital interests of any individual; or
• We have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting Our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
ACCURACY OF PERSONAL DATA
We take all reasonable steps to ensure that: your personal data held or processed by Us is accurate and up to date; and than any of your personal data that is inaccurate is rectified or erased without delay. We may from time to time ask to you confirm the accuracy of your personal data. You may, at any time, ask Us correct any of your personal data that is incorrect.
STORING AND PROTECTING YOUR PERSONAL DATA
We will store your personal data for as long as you hold an account with Us. After you have closed your account with Us we will store and keep you personal data for a reasonable period to maintain Our records and Our legal obligations to you. We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law. You are however responsible for ensuring that any personal data sent by you to Us is sent securely.
TRANSFER OF YOUR PERSONAL DATA
Due to the nature of Our business we may need to transfer your personal data to other jurisdictions and or countries. Where such a transfer occurs your personal data will be treated with reciprocal rights to those granted to you under the General Data Protection Regulation.
CONSENT, OPT IN and OPT OUT
RIGHT TO WITHDRAW YOUR CONSENT
Where you have given your consent to the processing of any of your personal data, you have the right to withdraw your consent at any time for any reason, provided always that your account with Us is closed.
LANGUAGE AND TRANSLATIONS