Privacy policy

PRIVACY POLICY

Updated: February 2024

Your privacy is important to Primuvoplatu (hereinafter referred to as Primuvoplatu, the Service, we). We are committed to protecting your personal data and providing transparency regarding the personal data we store and use, as well as, where possible, giving you control over how we use your personal data.

Your use of the Website is governed by this Privacy Policy (hereinafter referred to as "Privacy Policy", "Policy"). By using the website https://primuvoplatu.com (hereinafter referred to as the Website) and/or the services of the Primuvoplatu Service, you agree to the terms set out in the Privacy Policy and the Primuvoplatu User Agreement. Please regularly refer to the Privacy Policy to ensure your continued agreement with all actions of Primuvoplatu regarding your personal data. Continued use of any part of the Website and/or the Primuvoplatu Service after the posting of an updated Privacy Policy will signify your full agreement with any changes.

In this Privacy Policy, the words "User", "You" and "Your" refer to any person using the website https://primuvoplatu.com/. This Privacy Policy defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by Primuvoplatu.

1. Changes to the Privacy Policy

We reserve the right to periodically make changes to this Privacy Policy. If we make any substantial changes, we will notify you via email (if you have provided us with an email address), through the Website, or provide you with a new version of this Privacy Policy for acceptance, for instance, if we add new types of processing or collect additional Personal Data from you. All Personal Data collected by Primuvoplatu will be processed in accordance with the Privacy Policy in effect at the time of such collection. If the Privacy Policy undergoes any significant changes, Primuvoplatu will not (without your permission) use your Personal Data in a manner inconsistent with the Privacy Policy in effect at the time of collection of your information.

2. Personal Data We Collect About You

General personal data:
- Contact information, such as name, user identifier, email address, Telegram username.
- Preference information you provide when using the Website and Service, such as interest in products or content, communication and marketing preferences.
- Information about how you interact with us, such as viewed content and sections of the Website you visit.
- Device and usage information, which may include data related to your mobile device (e.g., identifier, brand, model, type, operating system, advertising identifier, and similar information); information about your use of features, functions, or notifications on the device; signal level related to Wi-Fi or Bluetooth features, temperature, battery charge level, and similar technical data; information about your mobile carrier.
- Your IP address and cookies when you visit the Website.

If the information contained in this section is aggregated or anonymized in such a way that it is no longer associated with an identified or identifiable individual, we may use it for any business purpose. To the extent that the information specified in this section is associated with an identified or identifiable individual and protected as personal data under applicable data protection laws, it is referred to in this Privacy Policy as "Personal Data."

The User has the opportunity to give us permission to save their email address and Telegram username on our server. By filling out a contact form on the Website or writing to us by email or in Telegram, the user agrees that we may send promotional information and commercial offers to the specified email address and/or in Telegram private messages. We will not disclose the information received from the User, including their email address, Telegram username to third parties. You can opt-out of marketing communications at any time by sending us an email at ask@primuvoplatu.com.

Please note that even if you opt-out of receiving marketing messages, you will still receive administrative notifications from us, such as order confirmations or other transactions, account activity notifications (e.g., account confirmations, password changes, etc.), and other important announcements not related to marketing.

3. How We Use Your Personal Data

We may use information about you, including your Personal Data, and by accepting this Privacy Policy, you give us your explicit consent to use it for the following purposes:
- For analyzing, operating, maintaining, and improving the Service and marketing activities, adding new features and services;
- Example: We may process your Personal Data to provide you with the core functionality of the Website and the Service.
- To evaluate your needs to determine suitable products or services;
- Example: We may analyze your usage patterns to better understand which features of the Website you like the most.
- To send updates or information about the Service;
- Example: We may use some of your contact details to notify you about Service updates.
- To respond to your comments, questions, and requests and provide User support;
- Example: If you email us, we may use your personal data to respond.
- To send you marketing messages via various communication channels, such as email, pop-ups, etc.;
- Example: We may use some of your contact details to send you a discount offer.
- Note: You can disable this feature by sending us an email at ask@primuvoplatu.com.
- To improve our Service and marketing campaigns;
- Example: We may study your Personal Data and create new Service features based on it.
- For conducting research and analysis;
- Example: We may use some of your data (in anonymized form) for business research purposes.
- For any other purposes disclosed to you at the time of collecting Personal Data or any other purposes specified in this Privacy Policy.

4. Your Rights to Data Protection

We are committed to providing you with broad privacy rights, regardless of where you reside and what citizenship you hold.

Correction of Personal Data: You are responsible for ensuring the accuracy of your Personal Data that you provide to us. Inaccurate information will affect your experience using the Website and Service tools and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is inaccurate, you have the right to contact us and ask us to correct such Personal Data by contacting us at ask@primuvoplatu.com.

Restriction of Processing Personal Data: You have the right to restrict processing if you dispute the accuracy of the Personal Data and want to restrict processing for a period that allows Primuvoplatu to verify the accuracy of the Personal Data; if you believe that the processing is illegal but oppose the deletion of the Personal Data and instead request to restrict the use of such data; you believe that we no longer need your Personal Data for processing purposes, but the data is necessary for you to protect your rights; or if you object to the processing pending verification of whether there are legitimate grounds for processing the Personal Data that override your right to data deletion.

Access to Your Personal Data and Data Portability: You have the right to request information about whether we hold any Personal Data about you and obtain a copy of it, access your Personal Data (including in a structured and portable format, such as .json).

Deletion of Personal Data: If you believe that your Personal Data is no longer necessary in connection with the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent or objected to the processing of your Personal Data, or in cases where the processing of your Personal Data does not comply with applicable law, you have the right to contact us and ask us to delete such Personal Data.

Right to Object to the Processing of Personal Data: In some cases, you may object to the processing of your Personal Data. Please note that deleting some Personal Data may affect your ability to use the Service and its features.

Right to Notification: If required by applicable law, we commit to notifying you and your data protection authority within the reasonable timeframes specified in applicable law about any data breaches related to the Service.

Data Protection Authorities: You also have the right to lodge a complaint with your local data protection authority regarding any of our actions that you believe do not comply with applicable law.

How to Exercise Your Rights?
Simply contact us at ask@primuvoplatu.com. Please note that in the case of an unclear request regarding correction, restriction of processing, access to data, or data portability, as well as any other request within the framework of exercising the aforementioned rights, we may engage in a dialogue with you to better understand the reasons for the request and obtain the necessary information. If this is not possible, we reserve the right to refuse to fulfill your request. We may also require you to confirm your identity (e.g., by requesting an ID or any other reasonable proof of identity or by asking you to confirm certain data about yourself) to ensure that your request does not violate the rights of third parties and that the rights described in this section are exercised by the actual data subject or an authorized person.

5. Transfer of Personal Data to Third Parties

We will transfer your Personal Data and information to third parties only in the ways described in this Privacy Policy.

General Cases: We may disclose your Personal Data:
- As required by law, such as to comply with a court order or similar legal requirement;
- If we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests;
- If we are involved in a merger, acquisition, or sale of all or part of our assets, you will be notified via email and/or a prominent notice on our Website of any changes in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data;
- To any other third party with your prior explicit consent.

Transfer of Personal Data to Ensure Service Operation:
We may transfer some of your Personal Data to third-party service providers and processors who agree to comply with applicable data protection laws (e.g., GDPR for

EU residents). Our third-party service providers and processors may transfer your Personal Data to their own third-party service providers and processors provided they have appropriate data protection safeguards in place and process your Personal Data in accordance with the original purpose.

Opting Out of Personal Data Sale:
Please note that we will never sell, rent, assign, transfer for remuneration, loan, or otherwise provide your Personal Data to third parties for any compensation, whether monetary or non-monetary. We are committed to transferring your Personal Data only to third parties acting on our behalf and following our instructions as service providers.

Aggregated Information:
We may also share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you.

6. Use of Cookies

The Website uses cookies and similar technologies to ensure maximum convenience for all Users, promptly providing personalized information. The website https://primuvoplatu.com uses cookies to obtain statistical data about Users' visits to the Website to improve the services of the Website and ensure your maximum convenience when visiting the Website's pages. By staying on the Website, you confirm your consent to the use of cookies in accordance with this Privacy Policy regarding this type of file. If you do not agree with the Website's use of this type of file, you should configure your browser settings accordingly or not use the Website.

While browsing any page of the Website, the page itself may be downloaded to your device, as well as small text files called cookies. Cookies are small text files, often containing a unique anonymous identifier, sent to the User's browser by the Website and stored on the User's device. Thus, thanks to cookies, websites can remember User actions and preferences (language, font size, etc.) to identify them on the next visit and respond accordingly.
Cookies are used to improve efficiency and obtain analytical information.

The information the Website obtains through cookies helps us provide you with the Primuvoplatu Service in the most convenient way and may help us form an idea of potential clients. Cookies ensure your personalized experience of using the Website and ease navigation, help track the most visited web pages, determine the effectiveness of advertisements and internet searches, and prevent loss of form data in case of a page refresh.

The Website uses both first-party and third-party cookies. First-party cookies are those placed by the Website and processed solely for improving the Website's performance. Third-party cookies are those placed in a domain other than the Website's domain. If a third party places cookies through the Website, such cookies are called third-party cookies. Thanks to these files, we can collect information to improve the functionality and effectiveness of the Service and make it more convenient for visitors.

The Website uses two types of cookies: persistent and session cookies. Session cookies save data only while you are on the site and are deleted after you leave the site. Persistent cookies save data to be accessible and used for more than one session.

The Website uses different types of cookies:

- Strictly Necessary Cookies: These cookies are necessary for the Website to work correctly, allowing Users to navigate the Website and use its features. These files do not identify the User as an individual. If you do not agree to use this type of file, it may affect the performance of the Website or its components.
- Performance Cookies: These cookies collect information about how the Website is used. All information collected using these cookies is for statistical purposes and remains anonymous. These files help understand how Users interact with the Website, providing information about the areas they visited and the amount of time they spent on the Website, and indicate problems with the Website's performance, such as error messages. This helps improve the Website's performance. Analytics cookies also help us measure the effectiveness of advertising campaigns and optimize the Website's content. This type of cookies cannot be used to identify the User. All information collected and analyzed is completely anonymous.
- Functionality Cookies: These cookies collect and remember information about the User's choices on the site. The information provided by functionality cookies does not allow the User to be identified and does not track the User's activity on third-party websites unrelated to the Service. These cookies are used to recognize Users returning to the Website. They allow for personalized Website content for you. If you block this type of cookie, it may affect the performance and functionality of the Website and limit your access to the Website's content.
- Advertising Cookies: These cookies record information about Users' online activities, including visits to sites and pages, as well as data about links and ads that Users choose to view. One goal is to display content on websites that is most oriented towards the User. Another goal is to ensure the ability to provide advertising or other information in a more accurate match with the User's interests.

You can disable cookie storage, limit their creation to specific websites, or set up notifications about sending cookies in your browser. You can delete cookies from your device at any time. However, if you choose to block all cookies (including strictly necessary cookies), you will not be able to access the Website or parts of it, or the pages may display incorrectly or in a limited manner. If you have any questions about how we use cookies, you can contact us at ask@primuvoplatu.com.

If you have configured your device to completely prohibit the acceptance of cookies, you can still visit the Website anonymously until you wish to use the Service. Please note that if cookies are completely disabled, some Service features cannot be provided to you, and you will not be able to access all sections of the Website.

Some cookies operate from the moment the User enters the Website until the end of the current browser session. These cookies become unnecessary and are automatically deleted when the browser is closed. Some cookies are stored on the device between browser sessions - they are not deleted after the browser is closed. Such cookies are called "persistent."

The Website does not control the use of third-party cookies by Users, so when using such files, you should contact the relevant third-party service website for more information.

7. Data Security

The security of your Personal Data is very important to us. When you provide us with your Personal Data, considered sensitive or falling under "special categories of data" under applicable law, we encrypt the transmission of this information using Secure Socket Layer (SSL) technology. We follow industry-accepted standards to protect the Personal Data provided to us both during transmission and after we receive it.

- Pseudonymization and tokenization of certain categories of your Personal Data;
- Data integrity protection;
- Encryption of your Personal Data during transmission and storage;
- Systematic vulnerability scanning and penetration testing;
- Organizational and legal measures. For example, our employees have different levels of access to your Personal Data, and only those responsible for data processing have access to your Personal Data and only for limited purposes necessary for the operation of the Service. We hold our employees strictly accountable for any disclosure, unauthorized access, alteration, destruction, or improper use of your Personal Data.
- Conducting periodic data protection impact assessments to ensure the application fully complies with the principles of "privacy by design," "privacy by default," and other internationally recognized data protection principles. We also commit to conducting a privacy audit in the event of a merger or acquisition of the company.
- Password or credential reset in the event of a suspected security incident or taking other reasonable actions that may be required to mitigate the consequences of any alleged security incident.

Please note that no method of data transmission or electronic storage method is 100% secure. Therefore, we cannot guarantee absolute security. If you have any questions about the security of our application, you can contact us at ask@primuvoplatu.com.

8. Data Retention and Processing

We will retain your Personal Data for as long as necessary to provide you with the Service. If you cease using the Service, we will delete all your Personal Data within 12 months and will use copies of your Personal Data only if necessary to fulfill our legal obligations, resolve disputes, and enforce our contractual obligations. We retain your Personal Data for the specified period to allow you to recover all your information and settings if you decide to use the Service again. If you wish to request that we no longer use your information to provide you with the Service or want to delete all your information and Personal Data permanently, contact us at ask@primuvoplatu.com.

In some cases, we may anonymize your Personal Data in such a way that it will never be able to identify you, factually or potentially. We may use such anonymized data for various purposes, such as training artificial intelligence.

9. Protection of Minors' Personal Data

The Website, Service, and any available Primuvoplatu products are not intended for individuals under 18 years of age. However, Primuvoplatu recognizes that individuals under 18 may potentially visit the Website. Parents and legal guardians may request Primuvoplatu to review, delete, or stop collecting and processing any personal data about their child (children). You can do this by contacting us at ask@primuvoplatu.com.

The Service does not collect Personal Data from individuals under 18 years of age. If you know anyone under 18 using the Website and any available Primuvoplatu products, please let us know at ask@primuvoplatu.com, and we will remove such a user and all their Personal Data.

10. Contact Information

If you have any questions or concerns regarding the privacy of your data, any provisions of this Privacy Policy, or any of your rights, you can contact us at ask@primuvoplatu.com.