Last updated: January 24, 2024

SOLVING MATH PROBLEMS

PRIVACY POLICY

This Privacy Policy is a legally binding contract between Worbert Limited (“Worbert”, “We”, “Us”) and its affiliates, and Users of the App - Solving Math Problems, together with the Terms of Service.

Your Privacy is of utmost importance to us. Our Privacy Policy is crafted to offer transparency in our privacy practices, providing you with insights into the information we collect, the reasons behind its collection, how we utilize your Personal information, and outlining your rights concerning your shared information.

We encourage you to thoroughly read our Privacy Policy. For better understanding, all capitalized terms used in the policy are defined in the "Definitions" section located at the end of this document. If you have any questions or concerns, please do not hesitate to reach out to us.

DEFINITIONS

Data Controller. A company with the right to determine the purposes and means of the processing of personal information.

Data Processor. A company which processes personal information on behalf of the controller.

Personal Information (Personal data). Any information that relates to an identified or identifiable individual/natural person.

GDPR. Abbreviation For General Data Protection Regulation.

CCPA. California Consumer Privacy Act

Account. Account means a unique account created by you with which you access our Services.

Application. Application is the software provided by us and downloaded by you on any electronic device.

Aggregate information. Information about groups or categories of users, which does not identify and cannot reasonably be used to identify an individual user. It is not considered as Personal Information.

Company. As referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement, Company refers to Worbert Limited, its affiliates and partners.

Cookies. Cookies are small text files that are downloaded to your computer, tablet or mobile phone when you use the Service (visit a website or application).

Service. Refers to the Application or the Website or both.

Website. Refers to Solving Math Problems’s webpage https://mathwaysolver.com/

You. “You” means the individual accessing or using the Service, and an individual to which this Privacy Policy applies.

1. GENERAL

Introduction. Solving Math Problems is a service designed to read and solve mathematical problems in real time using the camera of your mobile device. We are dedicated to providing you with an exceptional user experience while prioritizing and respecting your privacy. Solving Math Problems is operated by Worbert Limited, along with our affiliates and partners. Throughout this Privacy Policy, we may refer to "Solving Math Problems" as "we," "us," or "our" as applicable.

Data Controller. For the purposes of the GDPR and other relevant laws, Worbert Limited, registered at Christou Tsiarta, 20, ELMA 2 BUILDING, Flat/Office22 1077, Nicosia, Cyprus.

Scope of the Privacy Policy. This Privacy Policy, in conjunction with our Terms of and any referenced documents, applies to the Solving Math Problems mobile application (the "Application") and the associated website located at https://mathwaysolver.com/ and its subdomains (the "Website"). Collectively, the Application and the Website form the "Service." The policy outlines how any personal data collected from you or provided by you will be handled by us.

Acceptance of Privacy Practices. By using our Services, you acknowledge and agree to the privacy practices outlined in this Privacy Policy. It is important to review and understand the terms described herein. If you have any questions or concerns, feel free to reach out to us.

Exclusions from Privacy Policy. This Privacy Policy specifically pertains to the personal data processed during your use of the Service. It does not extend to third-party websites and/or services, including third-party applications, that may come into play while using the Service. These external entities operate under their own privacy policies, and any information you provide to them is governed by their respective rules and regulations.

We urge you to carefully review the privacy policies associated with any websites and/or services operated by third parties. It's important to note that we are not accountable for the privacy practices of these third parties. However, in cases where we have the ability to choose such third parties, we strive to align with those who not only adhere to similar privacy principles but also share comparable positive values.

If you seek additional information or wish to address any concerns, you can find the contact details under the "Your Rights" section.

2. DATA WE COLLECT:

In order to enhance your user experience with the Service, we may collect various types of personal data from you, including:

a) Data You Provide to Us Directly:

We collect information directly provided by you, which may include:

Images and text submitted for feedback on the Service.
Your email address if you choose to subscribe to our mailing list, request support, or provide feedback.
Email address, screen name, and age if you register for a Solving Math Problems account.
Subscription information when using our paid Services, including credit or debit card details.
Any additional information voluntarily provided during promotions or similar events.

If you contact us or our customer care team, the data you provide and records of correspondence may be retained for quality customer service.

b) Data Collected Automatically:

The Service may automatically collect certain information, which may constitute personal data, including:

Location data: Real-time geographic location of your device using various signals.
Usage data: Information on how you navigate and utilize the Service.
Device data: Details about the device you use, such as hardware model, operating system, identifiers, MAC address, IP address, and mobile network information.
Images or videos from the camera: Captured through the app for problem recognition and solving.
Analytics technologies: Cookies, beacons, unique identifiers, tags, crash logs, and scripts for analyzing trends and user movements.
Traffic optimization and distribution: Third-party services may be used for a better user experience, with data collection governed by their privacy policies.
Third-party analytics providers: External services for analyzing Service usage, with data shared with them for enhancement purposes. The list of analytics providers is available upon request.

Note: Cookies are employed in the Service for various functionalities.

For additional information or concerns, please contact us at [email protected].

3. THE PURPOSES FOR DATA PROCESSING:

The primary purposes for utilizing your information are aimed at enhancing our Services and optimizing your user experience. Here are the specific purposes for which we use the information you provide:

a) Personal Data Provided Directly. We use personal data you directly provide for the following objectives:

Setting up and maintaining your registration with the Service, if you opt to register and are of legal age.
Managing the Service.
Providing features available in the Service.
Developing, improving, and protecting the Service.
Communication with you.
Facilitating and processing in-app purchases.
Prevention and investigation of fraud and other misuses.
Protecting our rights and/or property.
Operating and improving our products and services.
Conducting market research
Electronic direct marketing, in compliance with applicable laws.
Auditing and analyzing the Service.
Ensuring the technical functionality and security of the Service.

It's important to note that images and feedback sent through the Service contribute to improving its capabilities, including math problem-solving, as well as enhancing other products and services, such as machine vision technologies from Solving Math Problems affiliates and partners.

b) Data Collected Automatically. Automatically collected data serves the following purposes:

Providing the service.
Enhancing customer service.
Personalizing user experience.
Managing the Service.
Providing features available in the Service.
Assessing the quality of the Service.
Developing, improving, and protecting the Service and other products and services, including machine vision technologies.
Auditing and analyzing the Service, including trends related to its use.
Ensuring the technical functionality and security of the Service.

4. THE PRINCIPLES OF PROCESSING

We rely on the following principles:

Consent: If we want to collect your data, we will ask you first. We will also provide a contact address where you can withdraw your consent in any time.
Legitimate interest: We will use your information where we have legitimate interest to do so. For instance, we will use the pictures taken by you in order to provide the Service and gather information about how to improve our AI.
Lawful and transparent processing. We abide by relevant legislation and give our best to present you all your rights
Privacy by design: Even while developing our Services, we have your privacy in mind at every step. We therefore include data-protection principles such as pseudonymization and data minimization.
Privacy by default: We have implemented appropriate measures for ensuring that only necessary data is processed for each specific purpose. In practice, this is shown in the amount of personal data collected, the extent of data processing and their accessibility.

5. HOW WE DISCLOSE YOUR INFORMATION:

We prioritize the privacy of our users and do not sell, lease, rent, or disclose personal data to third parties unless stated otherwise. However, there are specific scenarios where information may be shared:

Analytics Providers. We may allow other companies to provide analytics on your use of our Services. This helps us analyze user behavior, evaluate the effectiveness of changes and updates, and target relevant advertisements.

These entities may use technologies like cookies to collect information such as IP address, web browser, mobile network details, pages viewed, time spent, links clicked, and conversion data. Importantly, this does not include your name, email address, mailing address, or telephone number.

Disclosure of Personal Data Provided by You:

To Service Providers: We may share personal data with service providers, like data storage service providers, enabling us to deliver the Service.
To Business Partners: Disclosure to business partners, including advertising partners, in compliance with applicable laws.
To Public Authorities: In situations where we are legally required or need to protect our rights or the rights of third parties.
To Subsidiaries and Affiliates: Information may be shared in connection with corporate events like mergers, consolidations, restructuring, or sale of assets.
To Technology Partners: Sharing with technology partners, such as machine vision technology partners.
With Your Consent: Information may be shared with third parties when you provide explicit consent.

Disclosure of Automatically Collected Personal Data:

To Service Providers: Sharing with service providers, such as data analysis companies.
To Business Partners: Disclosure to business partners, including advertising partners, in compliance with applicable laws.
To Public Authorities: In situations where we are legally required or need to protect our rights or the rights of third parties.
To Subsidiaries and Affiliates: Information may be shared in connection with corporate events like mergers, consolidations, restructuring, or sale of assets.
To Technology Partners: Sharing with technology partners, such as machine vision technology partners.
With Your Consent: Information may be shared with third parties when you provide explicit consent.

It's essential to note that images taken by users will never be shared with any service provider, advertising agency, business partner, or third party

Additionally, non-personal information may be disclosed in an aggregate or derivative format, preventing the identification of individual users, for purposes such as statistical analysis. This is not considered personal data under data protection laws.

6. THIRD-PARTY SERVICES AND INTEGRATIONS

As part of our commitment to enhancing Services and improving user experience, we may introduce additional third-party content. It's important to note:

Voluntary Nature: The use of third-party content will never be a mandatory condition for utilizing our Services. It remains optional, and you can choose whether to engage with such additional features.
Providing Personal Information: If you decide to use third-party content, there might be a necessity to provide personal information to these third parties. An example is micro-tutoring services offered within the Application, where sharing user-generated images with the micro-tutoring service provider may be required.
Terms Adherence: We ensure that any third-party content providers adhere to our Terms of Use, Privacy Policy, and the principles outlined therein. This is to safeguard your privacy and ensure compliance with established standards.
Data Deletion: When offering added features through third-party content, we take special care to delete your Personal Information promptly after you conclude the use of such features. This emphasizes our commitment to data privacy and security.

By integrating third-party content, our goal is to enrich your experience while maintaining a strong focus on privacy and user protection.

OpenAI Integration. Our App is powered by the OpenAI platform, which means that when you interact with our App and make requests, your input and queries are processed on the OpenAI platform. This is essential for providing the advanced features and services that our App offers.

Data Sharing with OpenAI. Please be aware that when you use our App, certain information, such as your input text and queries, may be shared with OpenAI to facilitate the processing of your requests. While we prioritize the security and confidentiality of your data, it's important to understand that OpenAI will process your data according to their own privacy practices and terms of service. We encourage you to review OpenAI's privacy policy to gain a full understanding of how they handle your information.

7. OUR PRIVACY RIGHTS

You are in control of your personal information. We therefore want to give you a clear overview of your rights with respect to the personal data we hold about you, wherever you may be from:

Right to be forgotten. The right to request deletion of all available data we hold about you. Should you ever wish to start anew, contact us and we will delete all personal information which was collected during your use of Services.
Right to object. This right allows you to request from us to stop processing your data at any time, either for direct marketing purposes or otherwise. We only process your Personal information for direct marketing purposes if you have expressly allowed such processing with the positive action; in other words, if you have opted-in for such processing. In any case, we only collect user personal information if we have legitimate interest to do so.
Right to rectification. The right to have incomplete, incorrect, outdated, or unnecessary personal data corrected, or updated. The easiest way to achieve that is to log in to the Service and enter the necessary changes in the account settings of the Service. If you have additional questions regarding the correction, deletion, or updating of the personal data we hold about you, please contact us at [email protected].
Right to restrict processing/Right not to be profiled. Profiling consists of solely automated processing of personal data which evaluate some personal aspects relating to you, for instance, the country from which you are using our Services so we can show you more relevant ads. You will not be subject to such automated processing and decision making unless you have either given us your consent or if there is a legal basis/justified interest. Profiling is usually used for the purpose of incorporating relevant marketing. Our use of such processing shall not have any negative legal repercussion for you.
Right to access. You have the right to request access to Personal data we hold about you, or to request a copy of such data. If you would like to know what personal data we hold about you, please contact us at [email protected]. We seek to promptly respond to your inquiry.
Right to data portability. You have a right to request and receive the Personal data you have shared with us in a commonly used format and you can transmit that data to another controller or otherwise use it for your own purposes.
Right to data minimization. This right requires from us that the data we collect must be relevant and sufficient only to fulfill the purpose for which this information was collected.
Right to be informed. We will inform you about processing of your Personal data, purposes of processing, transfer of your data, retention policy, as well as information about us and contact details should you ever choose to contact us. In a way, we build this Privacy Policy to comply with your right to be informed.

By providing information to the Service that forms the basis of communications with you, such as contact information, you agree to receive electronic communications from us. However, you have the right to opt out of receiving electronic direct marketing communications from us: All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at [email protected].

For your protection and the protection of all our users, we may ask you to provide proof of identity before we can comply with some of your requests.

No user shall ever be discriminated against for exercising any of its privacy rights. However, please note that some information is sometimes necessary to provide the Services, or offer promotions, discounts, or other deals. You can always request information about how your request may affect your participation in such cases. For instance, we cannot provide customer support without you providing us with your contact information.

8. COOKIES POLICY

Cookies are small text files stored within a web browser which can be retrieved when you return to the website again.

Cookies do lots of different jobs, and as most other service providers, we also use cookies and similar tracking technologies which help us remember your preferences, keep you signed in, letting you navigate between pages efficiently and to generally improve your user experience. Some cookies are necessary for the functioning of our Services or they help us improve our performance by providing analytical data and some are used for marketing purposes. Our Privacy Policy uses the term “cookies” for all such technologies.

Main types of cookies:

First-party cookies (our own cookies) are created by web location that you visit, for instance, our Website. Such a web location is shown in the address bar. Data stored in our own cookies are anonymous and do not contain personal data such as personal name or email address. Therefore, it is not possible to connect data stored in cookies with a particular person.
Third-party cookies are created by other web locations. Please note that we may not control the storage or access to these cookies. You should review the privacy and cookie policies of these services to find out how these third parties use cookies. In addition, for more information on how third parties use these types of cookies, visit the following link: https://www.youronlinechoices.com/.
Session cookies are cookies which are only stored for the duration of your visit to our Website.
Persistent cookies are cookies which remain stored on your device after your visit and may be accessed by our Website every time you re-visit the Website

Cookies generally do not hold any information to identify an individual person but are instead used to identify a browser or an individual device.

a) How do we use cookies?

The table below explains the cookies we use on the Website and why. Note that only Essential cookies will be turned on as these cookies are strictly necessary. If such cookies are disabled, this can affect how the Website functions. You can disable Essential cookies in your browser.

Essential. Cookies necessary to allow navigation on our website, provide the services you will request and prevent security threats. Our own cookies: sign-in related cookie (3 minutes). Third party cookie: cookie used to prevent security threats: Cloudflare (1 month).

Functional. These cookies allow our Website to remember choices you make (such as that you accepted the Cookies on the Cookie Notification Bar and your sign-in data), thus providing enhanced, more personal features. These cookies cannot track your browsing activity on other websites. For example, these cookies are used to determine if the Cookie Notification Bar should be displayed or not. If you have already made your choice regarding the use of cookies, then we will not show you the Bar again. These are our own cookies (30 days).

Analytics. These cookies and scripts are used to measure, understand, and anonymously report on your usage of our Website. They help us understand how visitors interact with the Website by collecting and reporting information anonymously. This Website uses Google Analytics, a service of Internet analysis provided by Google LLC (“Google”). Google Analytics uses cookies for the analysis of your use of the Website. Information generated by cookie on your use of this Website is transferred to the United States of America. For more information, please see Privacy and data security policy on the following link: https://support.google.com/analytics/answer/6004245. Third-party cookie used: Google Analytics (2 years).

Marketing. These cookies are used to deliver adverts on our or third party websites more relevant to you and your interests, as well as to measure the effectiveness of advertising campaigns. We may utilize cookies and technologies from our marketing partners (Google), and/or social media platforms (Facebook). These technologies help us measure the efficacy of our marketing campaigns and to understand how visitors navigate to the Websites from our ads on other websites. They help us and our marketing partners (Google LLC and/or Facebook Inc.) determine how many times people who click on our ads end up using our services or performing a particular action, which information will be transmitted to our aforementioned marketing partners. These technologies are used to compile statistics about visitors who interact with the Websites and our other online content, to estimate the effectiveness of our ads, and to provide more pertinent information to our visitors. This also includes using previously collected information about your interests to select ads and whether you took any action related to the advertisement, including for example clicking an ad. For these purposes we use:

(i)Retargeting. This website uses retargeting technology for online advertising. This makes it possible to specifically address the Internet browsers with advertising that have already shown interest in our products and services. It is known from studies that the display of interest-based advertising is more interesting for the Internet user than advertising that has no such relevance. With retargeting, the display of the advertising media is done on the basis of a cookie-based analysis of the previous visit behavior. This Website uses the Google Analytics functions for marketing tools such as remarketing lists for search ads and remarketing for the Google display network. If you do not wish interest-based advertising from Google to be displayed, you can deactivate this function here https://adssettings.google.com/authenticated?hl=hr. For more information on how Google uses cookies and similar technologies for advertising, please visit: https://policies.google.com/technologies/ads?hl=en-US.

(ii) Facebook-Pixel. We use “Facebook Pixel” of the social network Facebook Inc. (Facebook). The Facebook pixel can track the behavior of users after clicking on a Facebook ad. With the aid of the Facebook pixel, we can understand how our marketing measures are being adopted on Facebook and, if necessary, are taking optimization measures. For more information on cookies and similar technologies placed by Facebook, please visit: https://www.facebook.com/policies/cookies/. If you want to disable cookie storage placed by Facebook, you need to change your browser settings. The data collected by our Website remain anonymous and do not provide any information about the identity of the users. Facebook stores and processes the data for its own advertising purposes in accordance with the Facebook Data Directive, which we invite you to visit at ( https://www.facebook.com/about/privacy/).

You are required to review the corresponding privacy policy of listed third parties, whose cookies and similar technologies may include advertising identifiers and device identifiers. These cookies are placed by third parties: Facebook (2 months) and Google Ads (3 months).

Personalization. They are used for customizing content, including ads.

b) How to manage cookies on your web browser

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

You can restrict, block, or delete cookies by changing your browser settings but that may mean that the website won’t work properly.

Find out how to manage cookies on popular browsers:

Google Chrome
Internet Explorer
Mozilla Firefox
Safari (Desktop)
Safari (Mobile)
Android Browser
Opera
Opera Mobile

To find information relating to other browsers, visit the browser developer’s website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

Please note that if you choose to refuse cookies you may not be able to use the full functionality of our Website and any communications you receive from us may be less relevant to you than they could have been. Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser.

c) How can I restrict, block, or delete cookies?

Strictly necessary cookies are always on when you visit us. On your first visit to us, we’ll tell you about our other types of cookies and ask you to choose which cookies we can use. You can always change your mind

In the settings of your web browser, you can access and change all cookie settings. Most web browsers automatically accept cookies, so if you want to change, delete, or block them, you must do so manually. For mobile devices, consult your phone’s manual for instructions on how to clear cookies.

9. SECURITY MEASURES

Ensuring the security of your Personal Information is a top priority. Here are the measures we take to safeguard your data:

Secure Storage: Your Personal Information is stored in a firewalled and secured database. Access to this database is strictly limited and controlled, ensuring that only authorized personnel can access the stored data.
Encryption: We utilize encryption methods to enhance the security of your Personal Information. This protective measure adds an extra layer of security, making it more challenging for unauthorized parties to access or manipulate the data.
Access Rights: Access to Personal Information is carefully managed, with strict access rights in place. This ensures that only individuals with the necessary authorization can retrieve or modify specific data.
Transparency: We maintain a secure operating environment that is not publicly accessible. This transparency aids in controlling and limiting access, mitigating the risk of unauthorized use.

However, despite these rigorous security efforts, it's important to note:

Transmission Risks: While we employ security measures during the transmission and storage of Personal Information, we cannot guarantee absolute security. There are inherent risks during data transmission, and we strive to minimize these risks to the best extent possible.

No Absolute Guarantee: Although we work diligently to maintain the integrity and security of Personal Information, we cannot provide an absolute guarantee against unauthorized access, loss, misuse, or alteration by third parties.

External Threats: Security measures may not always prevent illegal access by third parties, such as hackers. We acknowledge the existence of external threats and cannot warrant that Personal Information will be entirely protected from such risks.

In summary, while we implement robust security measures, we emphasize the importance of acknowledging the inherent risks associated with data transmission and storage. Our commitment is to continuously enhance security protocols to provide the highest level of protection for your Personal Information.

10. LOCAL NOTICES

CALIFORNIA RESIDENT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request: a) the categories of personal information that is processed; b) the categories of sources from which personal information is obtained; c) the purpose for processing of user personal data; d) the categories of third parties with whom we may share your personal information; e) the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows to identify the user.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above. Be informed that according to CCPA personal information does not include de-identified or aggregated consumer information.

DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

OPT-OUT OPTIONS. If you don’t want us to process your personal information any more, please contact us through [email protected]. Please be informed that such opt out may impact App’s further operation without functional data and you will be advised to remove the App from your device. If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described above.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected] . When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

CALIFORNIA PRIVACY RIGHTS

The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months. Please, note that we shall not be required to provide personal information to you more than twice in a 12-month period.
The right to prohibit sale of information means that you have the right to request that we stop the processing of your data for direct marketing purposes either by asking us to cease processing all data about you or asking us not to send you direct marketing communications. We generally do not sell your Personal Information for profit.
The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
The right to opt out of automated decision-making technologies means your right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
The right to restrict the use of your sensitive information means directly contacting us to stop such processing of your sensitive personal information for such purposes. We do not process any sensitive personal information to infer characteristics about you.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. Please note that under the CCPA we are under no obligation to comply with your request if we need to maintain your information if we need it to, among other things: (a) complete the transaction for which the personal information was collected, or (b) fulfill the terms of a written warranty or product recall; (c) detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; (d) debug to identify and repair errors that impair existing intended functionality; (e) comply with the California Electronic Communications Privacy Act; (f) enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business; (g) comply with a legal obligation.
Otherwise use the personal information internally in a lawful manner that is compatible with the context in which the consumer provided the information, etc.
The rights to portability means your right to receive your personal information in an electronic and structured form to you or to another party.

SALE OF DATA. We do not sell any of your personal data to third parties.

COLORADO RESIDENT NOTICE

This section applies only to Colorado residents in addition to the rest of this Privacy Policy. We process personal data in compliance with the Colorado Privacy Act that requires us to disclose the following additional information related to our privacy practices.

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will provide you with the required information in an alternative format that you can access.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected]. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

COLORADO PRIVACY RIGHTS.

The right of access means the right to know if a controller is processing the consumer’s data.
The right to portability provides the ability for you to receive the data in their right to access in a portable and machine-readable format, where technically feasible, that enables you to transmit the data to another entity without hindrance. Please note that you may only exercise the right to data portability twice per calendar year.
The right to opt-out means your right to object to the processing of your personal data for such purposes as (1) the sale of your personal data. Please note that we do not sell any of your personal data to third parties; (2) Targeted advertising, or (3) Profiling to help make decisions that produce legal or similarly notable effects concerning a consumer.
The right of correction means your right to request that we rectify inaccurate information about you.
The right of deletion means that you can ask us to delete or stop processing your personal data.
The right of appeal means that if you are not satisfied with resolving your privacy request, you can initiate an appeal procedure described below.

HOW TO EXERCISE YOUR PRIVACY RIGHTS You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts.

If you send us a request we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee.

If we refuse to take action on your request, you can follow the appeal procedure within 30 days after receiving such refusal sending your appeal to this email [email protected] adding in the subject of email “Appeal to answer on privacy request”.

We are obliged to consider your appeal within 45 after receipt of the appeal and inform you of any action taken or not taken in response to the appeal. We can extend this term by 60 additional days where reasonably necessary, taking into account the complexity and number of requests serving at this time.

If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

AUTHENTICATION. For the purpose of safeguarding your Personal Data against unauthorized access or deletion, we may need to authenticate your credentials before accepting a request pertaining to your rights. If you do not possess an account with us or if we suspect unauthorized access to your account, we may request additional personal information from you to verify your identity. If after these steps we are unable to verify your identity, we reserve the right to decline your rights request.

SALE OF DATA. We do not sell any of your personal data to third parties.

VIRGINIA PRIVACY NOTICE

The following section pertains exclusively to residents of Virginia. It outlines our practices regarding the collection, utilization, and sharing of Personal Data belonging to Virginia residents, in our capacity as a business operating under the Virginia Consumer Data Protection Act ("VCDPA"). Additionally, it outlines your rights in relation to your Personal Data. Please note that the term "Personal Data" used in this section holds the definition ascribed to it by the VCDPA, with the exception of information exempted from the VCDPA's scope.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected]. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

VIRGINIA PRIVACY RIGHTS. As a resident of Virginia, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations.

Correct inaccuracies in the consumer’s personal data that is collected by the controller.
Confirm if the controller is actually processing their personal data or request a copy of the personal data.
Delete personal data provided by or obtained about the consumer.
Obtain copies of the personal data collected by the controller.
Opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling.
The right to restrict processing of your sensitive personal information. We do not process any sensitive personal information to infer characteristics about you.
You have the right to be free from discrimination related to your exercise of any of your Virginia privacy rights.
Appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts.

If you send us a request, we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee.

If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email: [email protected] adding in the subject of email “Appeal to answer on privacy request”.

If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

SALE OF DATA. We do not sell any of your personal data to third parties.

CONNECTICUT PRIVACY NOTICE

This notice outlines the manner in which we, acting as a "Controller" under Connecticut's Data Protection Act ("CTDPA"), collect, utilize, and disclose your personal data, as well as the rights you have concerning your personal data, including sensitive personal data. In this context, "personal data'' and "sensitive data'' carry the definitions provided in the CTDPA and do not encompass information excluded from the scope of the CTDPA.

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

REQUESTS. To submit a verifiable consumer request please contact us through the email [email protected]. Before processing most requests, we will need to verify your identity and confirm that you are a resident of the State of Connecticut. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

If you are submitting a request on behalf of a Connecticut resident, including a minor child, we will also need sufficient information to verify that the individual is the person about whom we collected personal data, and that you are authorized to submit the request on their behalf.

CONNECTICUT PRIVACY RIGHTS. As a resident of Connecticut, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations.

Right to know. You have the right to verify whether we are processing your personal data or not.
Right to deletion. You have the right to request the deletion of your personal data under certain circumstances. If you make such a request, we will assess whether we are legally obligated to comply or if there are reasons that limit the scope of the deletion. If there are any reasons, we will provide you with an explanation in our response.
Right to access. The right to access and obtain a copy of personal data you previously provided to us, in a readily usable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible.
The right to opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling.
The right to ppt out of profiling. You have the right to choose not to have your personal data processed for profiling purposes that could lead to decisions with significant legal or similar effects on you. If you wish to exercise this right, you can opt out of such profiling activities.
The right to appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”.

If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email [email protected] adding in the subject of email “Appeal to answer on privacy request”. If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

11. INTERNATIONAL DATA TRANSFERS

Given our global operations, certain components of the Service may be hosted on servers situated in countries different from your own. It's crucial to recognize that data protection laws in these countries may vary from those in your home country. If you are situated within the European Union, please be aware that the personal data collected by us is transferred outside the European Union / European Economic Area.

By utilizing our Services, you expressly consent to the transfer of personal data about you beyond the borders of your own country and, where applicable, outside the European Union / European Economic Area.

To ensure the protection of your privacy during such transfers, storage, or processing of Personal Information, we commit to taking reasonable measures. These measures may encompass: A) Consent: We may obtain your explicit consent before transferring your Personal Information to a location outside your country or the European Union / European Economic Area. B) Contractual Clauses: Implementation of contractual clauses that clearly define rules and obligations regarding the transfer or processing of Personal Information. These clauses are designed to safeguard your data and privacy.

The objective is to maintain a high level of protection for your Personal Information, regardless of its physical location. We are dedicated to transparent practices and the responsible handling of your data, ensuring compliance with relevant data protection regulations.

12. CHILDREN’S PRIVACY NOTICE

We are committed to protecting the privacy of children, and as such, we do not knowingly collect personal data from children under the age of 13 years (or the applicable age in your country).

If you are under 16 years of age, we will seek your consent or the consent of your authorized parental representative before processing your personal information in any way.

For children under 16 years of age, we take specific measures:

Consent Requirement: We will either request your explicit consent or the consent of your authorized parental representative before processing any personal information.
Data Collection Limitations: We refrain from knowingly collecting personal data from children under 13 years of age (or the applicable age in your country).
No Sale of Information: We do not sell the information of children under 16 years of age, and we always seek consent.

If you become aware that we have unintentionally collected personal data from a child, please reach out to us promptly at [email protected]. We take such matters seriously and will take appropriate actions to address and rectify the situation. Your cooperation in notifying us is crucial in ensuring the protection of children's privacy.

13. DATA RETENTION

We are committed to retaining personal data only for as long as necessary for the purposes outlined in this Privacy Policy. Our general approach to data retention involves either deleting personal data after a certain period or anonymizing and aggregating the data in a way that no individual can be personally identified. The term "delete" is used in this Privacy Policy to encompass these practices.

Here are key points regarding our data retention practices:

Anonymized Data: We collect and store anonymized data from your initial use of the Services. Unless legal requirements dictate otherwise, we aim to retain data in an anonymized form.
Legal Requirements: For cases such as tax law or employment law, where specific legal requirements regarding data retention exist, we will comply with those applicable laws.
User Requests: We will promptly delete any personal data upon your request or if you withdraw your consent to processing.
Outdated or Unnecessary Data: We commit to deleting data that is no longer up-to-date or necessary for the original purpose of processing.

Methods employed for data deletion may include:

Erasure of unique identifiers allowing allocation to a specific person.
Removal of individual pieces of information that identify the data subject.
Separation of personal data from non-identifying information (e.g., order number from customer's name and address).
Aggregation of personal data in a way that prevents allocation to any individual.

Our goal is to prioritize data privacy and adhere to responsible data management practices.

14. CHANGES TO THE PRIVACY POLICY

Our commitment to transparency extends to any changes made to this Privacy Policy. Here are important points regarding updates to the Privacy Policy:

Notification of Changes: Whenever changes are made to the Privacy Policy, we will provide a "Last Updated" date at the top of the page. Users can easily identify when modifications were last implemented.
Material Changes: In the case of material changes to the ways in which we use and disclose personal data, a notice will be posted in the Service. This ensures that users are informed about significant alterations to our privacy practices.
Review Encouraged: Users are encouraged to review the Privacy Policy whenever they access the Service. This practice allows individuals to stay informed about the latest updates and our privacy practices.
Acceptance of Changes: By continuing to use the Service after any changes to the Privacy Policy, users implicitly accept and consent to the revised terms. Your ongoing use of the Service signifies acknowledgment and agreement with any modifications made to the Privacy Policy.

We are dedicated to maintaining transparency and keeping our users informed about any adjustments to our privacy practices

15. CONTACT US.

For any questions, concerns, or inquiries regarding this Privacy Policy, your privacy in connection with the use of the Service, or the protection of your personal data, please feel free to reach out to us. We are here to assist you promptly.

Worbert Limited, Christou Tsiarta, 20, ELMA 2 BUILDING, Flat/Office22 1077, Nicosia, Cyprus

Contact Email: [email protected]

Your privacy matters to us, and we are committed to addressing any queries or issues you may have regarding the handling of your personal data.