1. Introduction1.1 We understand the importance of protection of your privacy and personal data and commit a lot of effort to develop and maintain high standards of internal security measures and technologies to provide you with secure processing and storage of the data we collect from you; and protect your data against unauthorized or unlawful processing and against accidental loss, destruction or damage.
1.2 This Privacy Policy is an integral part of our Terms and Conditions (the Terms). As a general rule, all definitions are used within the meaning established by the Terms, unless otherwise specified herein.
2. Consent2.1 By using the Site, the App, and/or accepting our Terms and Service Agreement (the Agreement), you consent to the collection, processing and receipt of your personal data, as described in this Privacy Policy.
3. Personal data we collect and objective3.1 We do not collect any data that may identify you without your permission. We follow the principle of data minimization, meaning that we only collect and use data that is required to accomplish the task relevant for provision of the Services.
3.2 The Company does not require you to register in order to use the Services. However, when you access the Site or the App, we may collect and further process the following categories of data:
3.2.1 Your email address and ID of the account at the EO Broker platform. These are the only parameters that we send directly to our server;
3.2.2 data, which we may collect through automated means. Through your use of the Site, we may also monitor and collect tracking information related to usages such as access date and time, device identification, operating system, browser type and IP address. This information may be obtained directly by the Company or through third-party services;
3.2.3 data provided by you when referring your queries to the Company.
3.3 We neither solicit, nor collect personal data from anyone under the age of 18 or under the legal age of your country if it is higher. If you are below 18 or you are not of legal age in your country, do not provide us with any personal data.
3.4 The term we keep the personal data you provide depends on the type of information, the purpose of its use, nature of sensitiveness, etc. To the general rule, we will retain your personal data for the length of time reasonably needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will also retain and use your information for as long as necessary to resolve disputes and/or enforce our rights and agreements.
3.5 We collect and process the aforementioned data to fulfill our obligations and realize legitimate interest before you, namely to:
3.5.1 provide access to the Site;
3.5.2 inform on any changes and updates to the services we provide;
3.5.3 comply with applicable legislation;
3.5.4 maintain actions in relation to legal claims;
3.5.5 provide additional or supportive services, as well as perform surveys, statistical analysis;
3.5.6 to ensure marketing activities (send you news, updates, promotions, product information, event announcements, and other).
3.5.7 improves the performance and functionality of our services as described in the Terms (the Services).
3.6 The above list may be extended depending on the development of the Services.
4. Incidents notification 4.1 If the Company becomes aware of any breach of our security leading to the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of, or access to (excluding unsuccessful attempts or activities) your personal data on systems managed or otherwise controlled by us we will notify you promptly and without undue delay and in compliance to the procedure prescribed under applicable legislation and GDPR.
4.2 The notification will be made to your email address. It is your sole responsibility to provide us with the email address and ensure that this email address is valid and current.
4.3 None of the data incidents notification from the Company may not be and will not be construed as an acknowledgment of any fault or liability with respect to data incidents by us.
5. Your security commitments5.1 You agree that without prejudice to our security measures and data incidents that it is your responsibility to make appropriate use of our Services to ensure a level of security appropriate to the risk in respect of your personal data and securing your system and devices which you use to access the Site.
5.2 We are not obliged to protect your personal data that you choose to store or transfer outside the Company and our Subprocessors’ systems.
6. Cookie & similar technologies6.1 Cookie is a small text file placed on your computer when you visit the Site.
6.2 Cookies are widely used in order to make the Site work more efficiently, as well as to provide information about the functionality and your behavior on the Site.
6.3 Cookie helps you better interact with the Site and helps the Site better interact with you.
6.4 Cookies do not contain your personal data.
6.5 We use cookies and tags (collectively the Cookie) to:
6.5.1 understand how you use Site and to provide you with safe, effective and user-friendly Site;
6.5.2 remember your settings, such as preferred language, type of the device, news already shown to you, your preference about Cookie allowance;
6.5.3 keep opened sessions and conversation during your last visit to the Site;
6.5.4 identify the popularity of different section of the Site and improve respectively;
6.5.5 prevent and exclude unauthorized use of the Site;
6.5.6 keep track of actions and operations;
6.5.7 prepare reports, this allows us to measure and analyze the performance of our Services.
6.6 We normally do not associate you with your cookie, however, in exceptional cases, we may use this option to prevent or avoid unauthorized use of the Site and violation of applicable agreements. In this case, we will treat this information as personal and process as described in the Privacy Policy.
6.7 If you do not want to share your Cookie you may restrict it or block it out.
6.8 If you prefer not to allow cookies, please use your browser settings, most browsers give you an ability to manage your cookies or provide you with “incognito mode” or similar options.
6.9 For more information on how to disable cookies at all or how to amend your cookie settings check
http://www.allaboutcookies.org/.
6.10 We also may use similar technology and collect unique identifiers from our visitors of the Site, the information we collect by this means includes:
6.10.1 unique identification numbers, e.g. Internet protocol (IP) address and device ID;
6.10.2 as applicable to your type of device, browser type and version, and browser plug-in types and versions, application release and version, device model, manufacturer (brand), operating system, operating system version, OS library version, time of last seen, enable WiFi, radio (EDGE, HSDPA, LTE, WCDMA, none), device screen (width, high, dpi), NFC, telecom operator, Bluetooth enable, Bluetooth version;
6.10.3 time zone setting, city, region, country and language;
6.10.4 operating system and platform;
6.10.5 and information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
6.11 We use this information for the same purposes as Cookie.
6.12 We use Cookie for the following purposes, namely:
6.12.1 authentication;
6.12.2 security;
6.12.3 storing preferences and supporting additional features and functionalities;
6.12.4 performance, analytics and personalization;
6.12.5 marketing.
6.13 The time a Cookie will stay on your computer or mobile device depends on the type of Cookie whether it is "persistent" or "session" Cookie:
6.13.1 session cookies will only stay on your device until you stop browsing;
6.13.2 persistent cookies stay on your computer or mobile device until they expire or are deleted.
6.14 Some features of the App may require you to access third-party resources via the WebView or a similar built-in instrument for opening websites within the interface of the App. While you may be prompted to login to your account at the EO Broker platform and connect it to the App in order to use some features of the App, we do not collect your login credentials and are unable to use your account. The only relevant data that we may collect through automated means is the statistics on the App’s performance and automated actions performed by the Apps via your account at the EO Broker platform.