Information on personal data processing

Personal Data Processing

Personal Data Processing

Personal data subjects, in particular, may turn to the Data Protection Officer. Personal data subject refers to the natural person to whom the personal data pertains. These are typically EU residents whose rights are protected under the Regulation. Personal data may exist only in relation to a living natural person, because the GDPR precludes its applicability to the data of deceased persons.

Cases which are dealt with by the data protection officer

The Data Protection Officer performs a range of activities as the point of contact for data subjects, to whom data subjects can turn in the case of a breach in the processing of their personal data and in the case of exercising their rights pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2017, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

This particularly concerns the following rights:

  • Right to access personal data
  • Right to erasure (“right to be forgotten”)
  • Right to restriction of processing of personal data
  • Right to notification of rectification or deletion of personal data or processing restriction
  • Right to portability
  • Right to object
  • Right not to be the subject of any decisions based exclusively on automated processing, including profiling
  • Right to notification about personal data security breaches
  • Right to withdraw consent to personal data processing

How to contact the Data Protection Officer:

- By phone number

+355 69 20 93 605‬

- By e-mail

- In writing, by post to the address

Attention to Data Protection Officer: Safenetkey Ltd
Ramazan Shijaku St.,
Building No.10, 1st Floor
1001 Tirana,  Albania

Information about the processing of the personal data which you provide to us in connection to resolving your request: Personal data processing is essential to fulfil the legal obligations concerning the exercise of your right pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC. We use your PD in order to verify your identity and to handle your request properly. Your data and carriers thereof will be stored in the Data Protection Officer’s information system for the time it takes to resolve your request, and subsequently for a term of 5 years from the resolution of your request, in case of court or administrative proceedings, in order to secure the relevant evidence. The data will be disclosed to the affected company to which your request pertains, and to Safenetkey Ltd, registered in Ramazan Shijaku St., Building No.10, 1st Floor, 1001 Tirana, Albania, Company ID No. M12101006E, of which the Data Protection Officer is an employee. We would like to inform you of your right to request from Safenetkey Ltd access to your personal data, their rectification or erasure, or the restriction of processing, the right to object to processing, and the right to data portability. We would also like to inform you of your right to file a complaint to the supervisory authority. Additional information about personal data processing and the manner of resolving requests regarding the exercising of data subjects’ rights and procedures in the case of a breach of personal data security is provided on the Data Protection Officer’s website at www.safenetkey.com.

Information on the Processing of Personal Data of Customers, Business Partners, Job Applicants, and Other External Persons of Safenetkey Ltd.

Dear customers, business partners, visitors, users of information systems or applications, we would like to inform you that the protection of personal data is very important to us and forms an integral part of fulfilling all our commitments. Therefore, we pay due attention to it and follow the applicable legal regulations in ensuring the protection of personal data.

This document is effective from the date of publication on 16 December 2024.

Details of the Controller and the Data Protection Officer

Safenetkey Ltd reg. No.: M12101006E, having its registered office at Ramazan Shijaku St., Building No.10, 1st Floor, 1001 Tirana, Albania, registered in the National Business Center, as the personal data controller (hereinafter referred to as “our company”), hereby informs you of the principles and procedures for processing your personal data and of your rights relating to the protection of personal data, in accordance with Act No. 110/2019 Sb., on the processing of personal data, as amended (hereinafter referred to as “PDPA”) and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation; hereinafter referred to as “GDPR”).
The principles and procedures for processing and protecting personal data, their security, and the exercise of your rights as data subjects, including the appointment of a Data Protection Officer, are set uniformly for all companies that are part of SafeNetKey Ltd.

The information provided herein is of a general legally normative nature, and therefore does not form part of any contract and may be updated in our communications with details relating to the specific case of personal data processing.

Personal Data We Process and the Manner of Processing

Our company and its contractual processors in particular process the following categories of your personal data in accordance with the relevant legal title and purpose of processing:

  • a) Identification, authentication and address data: name, surname, academic degree, date of birth, data from identity documents, permanent or temporary residence address, delivery or other contact address, nationality, place and country of birth, registered office, registration number, in rare cases birth number, handwritten signature, and electronic signature;
  • b) Contact details: telephone number, e-mail address, databox ID;
  • c) Electronic data: IP address, cookies, authentication and e-signature certificates, location data of the device used by the user, identifiers in social networks and communication platforms;
  • d) Other personal data related to the contractual relationship: bank account number, customer account number, SIPO connection number, card access ID number (if assigned to you), user personal account access ID and password (if created);
  • e) In specific cases, personal data of special categories;
  • f) Personal data in audio files—audio recordings;
  • g) Personal data in image files—camera recordings, photographs, videos.

Your personal data may be processed by us manually or by automated procedures; however, we do not use automated decision-making, including profiling, which could affect your rights when processing your data automatically.

Sources of Collecting Personal Data

Our company primarily collects your personal data directly from you, in particular in the context of negotiations for the conclusion of a contract and in the course of its performance, or from third parties who mediate such negotiations. In these cases, we inform you when the provision of personal data is necessary for the performance of a specific service or business cooperation, and when on the contrary it is optional but serves to facilitate mutual communication and make cooperation between you and our company more effective.

We also generate other personal data about you, which are mainly related to usage patterns and user interactions (in the case of services such as age verification, content moderation, etc.).

Furthermore, we may collect your personal data from public registers or from administrative authorities (for example, from the trade register, the land register, the insolvency register, or the central execution register, etc.). Alternatively, in specific cases, we may also collect your personal data from non-public records on the basis of the relevant legislation.

In order to improve service quality, objectivity, verifiability, security, and protection of rights, our company monitors and records communications with you (for example, phone calls with customers). In these cases, we always inform you in advance and you are entitled to refuse this procedure. The only exceptions are special communication lines dedicated exclusively to crisis and emergency situations, which are always recorded.

In order to ensure the protection of property, personal health, and the safety of the services provided, our company has CCTV systems located on buildings owned or managed by our company or one of the SNK companies, part of SafeNetKey Ltd. We always inform you about the use of CCTV systems by means of information signs placed on the relevant buildings. The CCTV footage may be provided to the administrative and law enforcement authorities if necessary.

Purposes and Legal Titles of the Processing of Personal Data

The legal title for our processing of the data subject's personal data within the meaning of the GDPR may be the following:

  • A. Consent to the processing of personal data for one or more specified purposes (Article 6(1)(a) of the GDPR); We only seek your consent in specific cases where the processing of personal data in question is not carried out on the basis of another legal title. In these cases, you are always informed about the specific purpose for which your consent will be collected and recorded, for how long, etc., and your consent to the processing of your personal data is optional and may be withdrawn at any time, either by following the procedure defined for the specific case of personal data processing or generally by contacting the SNK GDPR Data Protection Officer.
  • B. The processing is necessary to perform a contract to which the data subject is a party or to carry out pre-contractual measures taken at the request of the data subject (Article 6(1)(b) of the GDPR); In the context of this processing of personal data, you or your representative are a party to the contract being prepared or concluded, i.e., you are in possession of the content of the contract and, at the same time, of the information related to the processing of personal data. Alternatively, if the contract is concluded electronically via a specific website or web application, for example, information on the processing of personal data for this specific purpose is always provided directly on the website or application.
  • C. The processing is necessary for compliance with a legal obligation to which the controller is subject (Article 6(1)(c) of the GDPR); Our company is subject to many legal obligations under European law. For the sake of clarity and for your better information, we list the main legal provisions that determine the areas of personal data processing based on the fulfillment of a legal obligation in the overview of specific purposes attached below.
  • D. The processing is necessary for the protection of the vital interests of the data subject or of another natural person (Article 6(1)(d) of the GDPR); We do not normally process your personal data on the basis of this legal title. Thus, the processing in question might only occur in quite exceptional circumstances, of which you would be informed by us, including the provision of further information regarding any such processing of your personal data.
  • E. The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (Article 6(1)(e) of the GDPR); We do not normally process your personal data on the basis of this legal title. Thus, the processing in question might only occur in quite exceptional circumstances, of which you would be informed by us including the provision of further information regarding any such processing of your personal data.
  • F. The processing is necessary for the purposes of the legitimate interests of the controller or third party concerned, except where those interests are overridden by the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data, in particular where the data subject is a child (Article 6(1)(f) of the GDPR). Our company's legitimate interests include in particular ensuring the health and safety of persons and property, maintaining necessary internal records (e.g., lists of qualifications of employees of contractors working on our premises, overviews of donation applications, etc.), verifying the eligibility of key employees, preparing contracts with suppliers, customers, and employees, marketing surveys, etc. We perform a so-called balancing test in all cases of personal data processing that is based on the legal title of the personal data controller's legitimate interest. We will only proceed with the processing of personal data when we have established by a test that our interests outweigh the interests, rights, and freedoms of the data subjects concerned. In the actual processing of personal data, we always ensure that the interests, rights, and freedoms of the data subjects are affected as little as possible.

An overview of the specific purposes, legal titles, and periods for which personal data are retained are provided in the table attached. The legal titles marked A–F are defined above.

Purpose of Personal Data Processing
Legal Title
Legal Provisions
Compliance verification of contractors and job applicantsC, FAct No 69/2006 Sb., on the implementation of international sanctions
Act No 253/2008 Sb., on selected measures against legitimization of proceeds of crime and financing of terrorism
ElectromobilityB, CAct No. 235/2004 Sb., on value added tax
Records of business partners for the conclusion of purchase and sales contracts for materials, services, investments, and software acquisitionsB, F 
Records of persons provided with accommodation in connection with the armed conflict in UkraineB, CCouncil Decision (EU) 2022/382 of March 4, 2022
on the allocation of spare accommodation capacities in the regions
Records of legal disputes in SafeNetKey LtdF 
Records of customers purchasing heat from X Group's generating facilities and performance of obligations related to the supply of heat energyB 
Corporate volunteeringB 
Physical protectionCAct No. 240/2000 Sb., Crisis Act
Act No. 412/2005 Sb., on the protection of classified information and on security clearance
CCTV systemsC, FAct No. 181/2014 Sb., on cyber security
Act No. 412/2005 Sb., on the protection of classified information and on security clearance
Marketing research and competitions (Public Relations)B, F 
Recruitment and scholarship program for studentsA, B, F 
Recording of integrated security operations center phone line callsF 
Recording of phone calls and audio communications at nuclear power plant sites to meet the safety requirements of the nuclear installationCAct No. 263/2016 Sb., Atomic Act
Decree No. 21/2017 Sb., on ensuring the nuclear safety of nuclear installations
Purchase for generationB 
Commodity trading and compliance with obligations arising from related legislationB, CDirective 2009/72/EC concerning common rules for the internal market in electricity
Regulation 2017/580/EU—regulatory technical standards
Search and analysis/evaluation of data in connected systemsC, FDecree No. 82/2018 Sb., on cyber security
Act No. 181/2014 Sb., on cyber security
Protection and processing of personal dataC, FRegulation 2016/679/EU—General Data Protection Regulation
Act No. 110/2019 Sb., on the processing of personal data
Protection of classified information and security eligibilityCAct No. 412/2005 Sb., on the protection of classified information and security clearance
Verification of psychological/personal competence/qualificationsC, FDecree No. 247/2001 Sb., on the organization and activities of fire protection units
Act No. 263/2016 Sb., Atomic Energy Act
Whistleblowing and investigating possible breachesCAct No. 171/2023 Sb., on the protection of whistleblowers
Fulfilling the agenda of the Data Protection OfficerB, CRegulation 2016/679/EU—General Data Protection Regulation
Act No. 110/2019 Sb., on the processing of personal data
Postal and filing serviceF 
Obligations of the issuer, in particular maintaining a list of persons with access to inside informationCRegulation 596/2014/EU on market abuse
Act No. 256/2004 Sb., on capital market undertakings
Operation of information centersA 
Radiation protectionCDecree No. 422/2016 Sb., on radiation protection and radionuclide source security
Act No. 263/2016 Sb., Atomic Energy Act
Implementation of information and cyber securityB, C, FAct No. 181/2014 Sb., on cyber security
Decree No. 82/2018 Sb., on cyber security
Qualification management of contractors' employees in the Nuclear Energy DivisionB, C, FAct No. 263/2016 Sb., Atomic Energy Act
Decree No. 358/2016 Sb., on requirements for quality assurance and technical safety and assessment and verification of conformity of selected installations
Contractual documentation for financingB 
Closing deals on financial markets—recorded conversationB, F 
Keeping records of work accidentsCGovernment Regulation No. 201/2010 Sb., on the method of recording, reporting, and sending accident records
Act No. 262/2006 Sb., Labor Code
Keeping a construction diaryCDecree No. 499/2006 Sb., on building documentation
Act No. 183/2006 Sb., Building Act
Handling and recording applications in accordance with the Freedom of Information ActC, FAct No. 106/1999 Sb., on freedom of information
Extract of shareholders from the statutory register of the Central Securities Depository for the purpose of dividend payment and convening a Shareholders' MeetingCAct No. 256/2004 Coll., on capital market undertakings
Ensuring access to information and business resourcesB 
Processing of cookies on websitesA, C, FAct No. 127/2005 Sb., on electronic communications
Processing of accounting documentsCAct No. 563/1991 Sb., on accounting
Act No. 280/2009 Sb., Tax Code
Processors and Recipients of Personal Data

In order to ensure the efficiency and competence of the processes, our company may disclose your personal data to its employees or contractual partners as processors of personal data (based on a personal data processing agreement or other legal act) or to contractual partners as joint controllers of personal data (based on a contract on mutual rights and obligations of joint controllers or other legal act) or to another controller of personal data as recipients of personal data in justified cases.

For our contractual processors of personal data, we require a similar organizational and technical standard of personal data protection as we have set uniformly for the entire ESM Concern, including compliance with the contractual terms and conditions relating to the processing of personal data (e.g., the obligation to use the subject personal data exclusively for the purposes for which it was transferred to them, the prohibition of sharing the transferred personal data with other processors of personal data without our prior consent, etc.). We verify the fulfillment of our requirements for the processing of the personal data transferred with the contractual processors concerned before the conclusion of the personal data processing agreement (or other legal act), during its term, and after its termination (in particular as regards the deletion of the personal data transferred, etc.).

Personal Data Processors

Categories of Processors
Activity
Security agenciesEnsuring the protection of life, health, and property (through external security agencies).
Corporate volunteeringImplementation of corporate volunteering aimed at helping individuals and specific projects.
IT services and software suppliersDevelopment and maintenance of relevant IT systems, websites, systems for the electronic execution of Shareholders' Meetings, management and operation of electromobility, etc.
Marketing and communicationEnsuring communication with the public, including the implementation of promotional events, communication materials and marketing research.
Personnel agenciesProviding recruitment and selection of suitable job candidates.
Postal and courier servicesPostal services, including remittance delivery, as well as parcel and courier services.

Personal Data Recipients

Your personal data may also be transferred to third parties who are entitled to receive such personal data. These include, for example, tax, administrative, or regulatory authorities.

In particular, our company transfers personal data to the following recipients:

  • - Office for Personal Data Protection
Transfers of Personal Data to Third Countries

Our company processes your personal data, either directly or through its contractual processors, primarily within the European Union (EU). In these cases, the processing of personal data is governed by the General Data Protection Regulation (GDPR), which ensures consistent protection and security of personal data across the EU and the European Economic Area (EEA).

However, in exceptional cases, personal data may be transferred to third countries or international organizations. Before transferring your data, we assess whether the chosen controller or processor provides adequate guarantees, including the enforceability of your rights as a data subject. This evaluation also considers the effective legal protection of personal data in the recipient country. Personal data will only be transferred to third countries or international organizations if the following conditions are met:

  • - The third country or international organization has received a decision from the European Commission confirming that it ensures an adequate level of personal data protection;
  • - The selected processor or sub-processor can provide appropriate organizational and technical guarantees, and in the processor's country, data subjects' rights are enforceable with effective legal protection in place.
SUITABLE GUARANTEES INCLUDE:
  • - Legally binding and enforceable instruments between public authorities or public entities;
  • - Binding corporate rules;
  • - Standard data protection clauses adopted by the European Commission;
  • - Standard data protection clauses adopted by the relevant supervisory authority and approved by the European Commission;
  • - Approved code of conduct with binding and enforceable obligations for the processor in the third country to apply appropriate guarantees, including regarding the rights of data subjects;
  • - Approved certification mechanism with binding and enforceable obligations for the processor in the third country to apply appropriate guarantees, including regarding the rights of data subjects.
Cookies and Other Processing in the Digital Environment

We use cookies on our company's website. In order to display the website correctly, we need to collect so-called technical cookies. For all other types of cookies, we need your consent and it is entirely at your discretion as to whether or to what extent to grant your consent. You may set the extent of your consent to the collection of cookies by means of the so-called “cookie bot”, which is displayed on the respective website.

Detailed information on cookies is also available here.

Depending on whether and to what extent you grant your consent, we may then use cookies to personalize content and advertisements, provide social media features, and analyze traffic on our company's website. We may then share information about how you use our website with our social media, advertising, and analytics partners. Partners may combine this information with other information that you have provided to them or that they have obtained in connection with your use of their services. Detailed information on cookies is available in the Website Information section.

Your Data Protection Rights

Our company strives to process your personal data in a transparent and fair manner and to ensure that it is properly protected, always in accordance with the relevant legislation. To assure you of our responsible approach to the processing of your data, we are ready to respond quickly and professionally to your legitimate requests.

  • – If the processing of personal data is based on your consent, you shall be entitled to withdraw your consent for future processing at any time.
  • – You shall be entitled to request access to your personal data and more detailed information about its processing from us as data controller.
  • – You shall be entitled to request from us the rectification of inaccurate or incomplete personal data.
  • – You shall be entitled to request us to provide your personal data in a commonly used and machine-readable format that enables it to be transmitted to another controller, where we have obtained it on the basis of your consent or in connection with the conclusion and performance of a contract and it is processed by automated means.
  • – You shall be entitled to object to the processing of some or all of your personal data.
  • – You shall be entitled to request us to erase your personal data if we no longer have any legal basis for further processing.
  • – You shall be entitled to file a complaint with the Office for Personal Data Protection.

Please be informed that the exercise of the rights of data subjects under Articles 12 through 22 of the GDPR may be restricted in accordance with Article 23(1) of the GDPR. Detailed information regarding your rights, including ways to exercise your rights in the case of data protection, is available here.

Glossary of Terms and Abbreviations

Cookies

A short text file that is sent to the browser by the website you visit. It allows the website to record information about your visit, such as your preferred language and other settings. This ensures that your next visit to the site is easier and more productive. Cookies are important. Without them, browsing the web would be much more difficult.

Supervisory Authority

The authority established in Albania as the Office for Personal Data Protection (hereinafter referred to as the “OPDP") by the Personal Data Processing Act. It is entrusted with the competences of the central administrative authority for the protection of personal data to the extent provided for by this act and other competences provided for by special legislation.

GDPR

Regulation (EU) 2016/679 of the European Parliament and the Council dated April 27, 2016 on the protection of individuals with regard to the processing of personal data and free movement of such data and repealing Directive 95/46 /EC (General Data Protection Regulation).

Personal data (hereinafter referred to as “PD”)

Any information about an identified or identifiable natural person; an identifiable natural person is a natural person who is directly or indirectly identifiable, in particular by reference to an identifier such as a name, identification number, location data, network identifier, or to one or more specific elements of the physical, physiological, genetic, psychological, economic, cultural, or social identity of that natural person.

Data Protection Officer

A partner for negotiations with the OPDP and data subjects. In particular, the DPO is responsible for protecting the interests of data subjects.

Recipient

A natural person or legal entity, public authority, agency, or other entity to which personal data are disclosed, whether or not it is a third party. The recipient has the legal, contractual, or other authority to process the personal data. This includes other controllers or processors such as tax, administrative, or regulatory authorities. However, public authorities which may obtain personal data in the context of a specific investigation in accordance with the law of a member state are not considered recipients; the processing of such personal data by those public authorities must comply with the applicable data protection rules for the purposes of the processing.

Data subject (hereinafter referred to as the “DS”)

A natural person to whom the personal data relates. A data subject shall be deemed to be identified or identifiable if their identity is directly or indirectly identifiable on the basis of one or more pieces of personal data.

Adequacy test

Assessment of the data subject's request by the data controller if the data subject's request is manifestly unfounded or unreasonable, in particular because it is repetitive. Requests may be considered manifestly unfounded if, for example, they are completely devoid of justification on prima facie grounds (in cases where justification is necessary) and it is not possible to assess what the data subject is concerned about, even by interpretation (e.g., an objection to processing pursuant to Article 21(1) of the GDPR, if the DS fails to provide information in the request about their situation that enables the controller to assess whether a legitimate interest outweighs the interests of the data subject). In particular, requests may be considered manifestly unfounded if they are unreasonably repetitive or large in number. This is not to be generalized and should always be considered in the context of the case. The manifest unfoundedness or disproportionate nature of the request shall be documented and justified by the controller in a communication informing the data subject and the Data Protection Officer of the request's rejection. This justification shall be documented by the Controller and stored for possible inspection by the Supervisory Authority.

PDPA

Act No. 110/2019 Sb., on Personal Data Processing and on Amendments to Certain Acts, as amended.

Personal data processing

Any operation or set of operations with personal data or sets of personal data which is carried out with or without the aid of automated procedures, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other disclosure, alignment or combination, restriction, erasure or destruction.

Personal data processor

A natural person or legal entity, public authority, agency, or other entity that processes personal data for the controller.

Special data categories (sensitive data)

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person and data concerning the health or sex life or sexual orientation of a natural person.

Contact Us

Requests or Grievances Regarding Personal Data Processing

If you have a request or grievance regarding the processing of your personal data or a question about the person responsible for the processing of personal data in our company, please contact us. Alternatively, you can contact us by writing to Safenetkey Ltd, Ramazan Shijaku St., Building No.10, 1st Floor, 1001 Tirana, Albania, using the subject line “personal data processing”. We will respond to your requests, questions, or grievances as soon as possible, but no later than one month after receipt. If we are unable to deal with your request in a timely manner due to the complexity of your request or the high number of requests from other persons, we will inform you of the necessary time extension.

Website Information and Cookies Settings

Website information and cookies settings

Dear users of our company's website, we would like to expressly ask you:

 - GDPR,

- The Personal Data Processing Act (PDPA),

- The Electronic Communications Act (ECA),

to provide you with more information about cookies, the processing of personal data, your related rights, the Data Protection Officer and the rules of use of this website.

Information about cookies

Safenetkey Ltd., registered with the National Business Center (QKB) under ID M12101006E and located at Ramazan Shijaku St., Building No.10, 1st Floor, 1001 Tirana, Albania, is a separate controller of personal data processed during the use of cookies.

Cookies

Cookies are small text files, unique identifiers that are sent to and stored on your device when you visit a website. The main purpose of cookies is to ensure the correct display and functioning of the website in question.

- Technical cookies

Technical or necessary cookies are essential to ensure the proper and secure functioning of our website. The use of these cookies cannot be set individually and is not conditional on your consent in accordance with the provisions of the ePrivacy Directive. Any data obtained in this way is further processed on the basis of our legitimate interest within the meaning of Article 6(1)(f) of the GDPR.

- Non-technical cookies

Non-technical cookies, i.e. marketing, statistical and preference cookies, are used to optimise and adapt the website to your preferences, and in this case it is therefore entirely up to you whether and, if necessary, for which cookies, or for what processing of your personal data, you give your consent in accordance with the provisions of the GDPR and the ePrivacy Directive.

Consent to the use of non-technical cookies and the processing of personal data and its withdrawal

You can give your consent to the use of non-technical cookies (marketing, statistical and preference cookies) and other processing of personal data when you visit our website via the cookie bar that appears at the bottom of the website. Consent can be given for all categories, by clicking on "Allow All", or only for some processing, by clicking on "Allow Selection". However, if you would prefer not to grant consent, you can select the "Decline optional" button.

Of course, you can also change or withdraw your consent at any time via the "Cookie settings" link at the foot of the page on our website. At the same time, please note that if you significantly restrict the use of our non-technical cookies or the processing of personal data, either by granting consent only for certain categories, by not granting consent for any category or by setting it in your web browser, our website will not be adapted to your preferences and will only be available to you in its basic form.

Beyond the above described granting or not granting consent to the processing of cookies, you can also define the scope of their use through your web browser. For more information on this option of setting cookies, please refer to the Help of your internet browser. Below are the most commonly used browsers:

 - Chrome cookies

- Microsoft Edge cookies

- Mozilla Firefox cookies

- Apple Safari cookies

- Opera cookies

Terms & Conditions

Terms and Conditions

Last updated: December 16, 2024

Please read these terms and conditions carefully before using Our Service.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of these Terms and Conditions:

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Country refers to: Albania
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Safenetkey Ltd, Ramazan Shijaku St., Building No.10, 1st Floor, 1001 Tirana, Albania.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Service refers to the Website.
  • Terms and Conditions (also referred as “Terms”) mean these Terms and Conditions that form the entire agreement between You and the Company regarding the use of the Service.
  • Third-party Social Media Service means any services or content (including data, information, products or services) provided by a third-party that may be displayed, included or made available by the Service.
  • Website refers to SafeNetKey, accessible from https://www.safenetkey.com
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Acknowledgment

These are the Terms and Conditions governing the use of this Service and the agreement that operates between You and the Company. These Terms and Conditions set out the rights and obligations of all users regarding the use of the Service.

Your access to and use of the Service is conditioned on Your acceptance of and compliance with these Terms and Conditions. These Terms and Conditions apply to all visitors, users and others who access or use the Service.

By accessing or using the Service You agree to be bound by these Terms and Conditions. If You disagree with any part of these Terms and Conditions then You may not access the Service.

You represent that you are over the age of 18. The Company does not permit those under 18 to use the Service.

Your access to and use of the Service is also conditioned on Your acceptance of and compliance with the Privacy Policy of the Company. Our Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your personal information when You use the Application or the Website and tells You about Your privacy rights and how the law protects You. Please read Our Privacy Policy carefully before using Our Service.

Intellectual Property

The Service and its original content (excluding Content provided by You or other users), features and functionality are and will remain the exclusive property of the Company and its licensors.

The Service is protected by copyright, trademark, and other laws of both the Country and foreign countries.

Our trademarks and trade dress may not be used in connection with any product or service without the prior written consent of the Company.

Links to Other Websites

Our Service may contain links to third-party web sites or services that are not owned or controlled by the Company.

The Company has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party web sites or services. You further acknowledge and agree that the Company shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods or services available on or through any such web sites or services.

We strongly advise You to read the terms and conditions and privacy policies of any third-party web sites or services that You visit.

Termination

We may terminate or suspend Your access immediately, without prior notice or liability, for any reason whatsoever, including without limitation if You breach these Terms and Conditions.

Upon termination, Your right to use the Service will cease immediately.

Limitation of Liability

Notwithstanding any damages that You might incur, the entire liability of the Company and any of its suppliers under any provision of this Terms and Your exclusive remedy for all of the foregoing shall be limited to the amount actually paid by You through the Service or 100 USD if You haven’t purchased anything through the Service.

To the maximum extent permitted by applicable law, in no event shall the Company or its suppliers be liable for any special, incidental, indirect, or consequential damages whatsoever (including, but not limited to, damages for loss of profits, loss of data or other information, for business interruption, for personal injury, loss of privacy arising out of or in any way related to the use of or inability to use the Service, third-party software and/or third-party hardware used with the Service, or otherwise in connection with any provision of this Terms), even if the Company or any supplier has been advised of the possibility of such damages and even if the remedy fails of its essential purpose.

Some states do not allow the exclusion of implied warranties or limitation of liability for incidental or consequential damages, which means that some of the above limitations may not apply. In these states, each party’s liability will be limited to the greatest extent permitted by law.

“AS IS” and “AS AVAILABLE” Disclaimer

The Service is provided to You “AS IS” and “AS AVAILABLE” and with all faults and defects without warranty of any kind. To the maximum extent permitted under applicable law, the Company, on its own behalf and on behalf of its Affiliates and its and their respective licensors and service providers, expressly disclaims all warranties, whether express, implied, statutory or otherwise, with respect to the Service, including all implied warranties of merchantability, fitness for a particular purpose, title and non-infringement, and warranties that may arise out of course of dealing, course of performance, usage or trade practice. Without limitation to the foregoing, the Company provides no warranty or undertaking, and makes no representation of any kind that the Service will meet Your requirements, achieve any intended results, be compatible or work with any other software, applications, systems or services, operate without interruption, meet any performance or reliability standards or be error free or that any errors or defects can or will be corrected.

Without limiting the foregoing, neither the Company nor any of the company’s provider makes any representation or warranty of any kind, express or implied: (i) as to the operation or availability of the Service, or the information, content, and materials or products included thereon; (ii) that the Service will be uninterrupted or error-free; (iii) as to the accuracy, reliability, or currency of any information or content provided through the Service; or (iv) that the Service, its servers, the content, or e-mails sent from or on behalf of the Company are free of viruses, scripts, trojan horses, worms, malware, timebombs or other harmful components.

Some jurisdictions do not allow the exclusion of certain types of warranties or limitations on applicable statutory rights of a consumer, so some or all of the above exclusions and limitations may not apply to You. But in such a case the exclusions and limitations set forth in this section shall be applied to the greatest extent enforceable under applicable law.

Governing Law

The laws of the Country, excluding its conflicts of law rules, shall govern this Terms and Your use of the Service. Your use of the Application may also be subject to other local, state, national, or international laws.

Disputes Resolution

If You have any concern or dispute about the Service, You agree to first try to resolve the dispute informally by contacting the Company.

For European Union (EU) Users

If You are a European Union consumer, you will benefit from any mandatory provisions of the law of the country in which You are resident.

United States Legal Compliance

You represent and warrant that (i) You are not located in a country that is subject to the United States government embargo, or that has been designated by the United States government as a “terrorist supporting” country, and (ii) You are not listed on any United States government list of prohibited or restricted parties.

Severability and Waiver

Severability

If any provision of these Terms is held to be unenforceable or invalid, such provision will be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law and the remaining provisions will continue in full force and effect.

Waiver

Except as provided herein, the failure to exercise a right or to require performance of an obligation under these Terms shall not affect a party’s ability to exercise such right or require such performance at any time thereafter nor shall the waiver of a breach constitute a waiver of any subsequent breach.

Translation Interpretation

These Terms and Conditions may have been translated if We have made them available to You on our Service. You agree that the original English text shall prevail in the case of a dispute.

Changes to These Terms and Conditions

We reserve the right, at Our sole discretion, to modify or replace these Terms at any time. If a revision is material We will make reasonable efforts to provide at least 30 days’ notice prior to any new terms taking effect. What constitutes a material change will be determined at Our sole discretion.

By continuing to access or use Our Service after those revisions become effective, You agree to be bound by the revised terms. If You do not agree to the new terms, in whole or in part, please stop using the website and the Service.

Contact Us

If you have any questions about these Terms and Conditions, You can contact us:

Privacy Policy

Privacy Policy

Last updated: December 16, 2024

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
  • CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”).
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Safenetkey Ltd, Ramazan Shijaku St., Building No.10, 1st Floor, 1001 Tirana, Albania. For the purpose of the GDPR, the Company is the Data Controller.
  • Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: Albania
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • GDPR refers to EU General Data Protection Regulation.
  • Personal Data is any information that relates to an identified or identifiable individual.For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
    For the purpose of the GDPR, Service Providers are considered Data Processors.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to SafeNetKey, accessible from www.safenetkey.com
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Privacy Policies website article.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential CookiesType: Session CookiesAdministered by: UsPurpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA/CPRA Privacy Notice

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

  • Category A: Identifiers.Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.Collected: Yes.
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.Collected: Yes.
  • Category C: Protected classification characteristics under California or federal law.Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).Collected: No.
  • Category D: Commercial information.Examples: Records and history of products or services purchased or considered.Collected: No.
  • Category E: Biometric information.Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.Collected: No.
  • Category F: Internet or other similar network activity.Examples: Interaction with our Service or advertisement.Collected: Yes.
  • Category G: Geolocation data.Examples: Approximate physical location.Collected: No.
  • Category H: Sensory data.Examples: Audio, electronic, visual, thermal, olfactory, or similar information.Collected: No.
  • Category I: Professional or employment-related information.Examples: Current or past job history or performance evaluations.Collected: No.
  • Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.Collected: No.
  • Category K: Inferences drawn from other personal information.Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Collected: No.
  • Category L: Sensitive personal information.Examples: Account login and password information, geolocation data.Collected: Yes.

Under CCPA/CPRA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA/CPRA’s scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service.
  • Indirectly from You. For example, from observing Your activity on our Service.
  • Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
  • From Service Providers. For example, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA/CPRA), which may include the following examples:

  • To operate our Service and provide You with Our Service.
  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
  • Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Share of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

  • Service Providers
  • Our affiliates
  • Our business partners
  • Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information

As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, and these may be deemed a sale under CCPA/CPRA.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
    • The categories of personal information We collected about You
    • The categories of sources for the personal information We collected about You
    • Our business or commercial purposes for collecting or selling that personal information
    • The categories of third parties with whom We share that personal information
    • The specific pieces of personal information We collected about You
    • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
      • The categories of personal information categories sold
      • The categories of personal information categories disclosed
  • The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the “Do Not Sell My Personal Information” section or contact Us.
  • The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.
  • The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the “Limit the Use or Disclosure of My Sensitive Personal Information” section or contact Us.
  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
    • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
    • Denying goods or services to You
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to You
    • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

Please see the “Do Not Sell My Personal Information” section and “Limit the Use or Disclosure of My Sensitive Personal Information” section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

  • Verify Your identity or authority to make the request
  • And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, and these may be deemed a sale under CCPA/CPRA.

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the “Use of Your Personal Data” section or contact us.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: