Privacy notice

Last updated: February 10, 2025

This Privacy Notice explains how We collect, process, and use personal data of consumers (hereinafter referred to as "Consumer," "You," or "Your") when interacting with the website https://www.flatrover.com (hereinafter referred to as the "Site" or "Platform"). We are committed to ensuring the security of Your data in accordance with applicable legislation.
Before accessing or using Our Platform, please familiarize yourself with this Privacy Notice (hereinafter referred to as the "Notice"), which explains what We will do with Your personal information that You provide to Us.
This document has been developed with high privacy standards in mind and complies with the General Data Protection Regulation (GDPR) and other relevant regulations.
1. GENERAL INFORMATION
The use of the Platform by the Consumer means agreement with this Notice and the terms of processing the Consumer’s personal data. We kindly ask you to read this Notice carefully so that You understand our approach and practices regarding the processing of your personal data.
This Notice describes Our interaction with you related to the collection of personal information through this Platform. Your access to this Platform and all communications between You and Us are governed by this Notice.
You can browse the Site without disclosing your personal data. However, using the full functionality of the Platform requires providing personal data. By providing personal data, You explicitly consent to the collection, use, disclosure, and storage of Your personal information as described in the Notice.
If you do not agree with the terms of this Privacy Notice, please discontinue using the Platform.
This Notice applies to the Site and does not control third-party websites that the Consumer may visit via links available on the Platform.
The administration does not verify the truthfulness of the personal data provided by the Consumer.
2. INFORMATION ABOUT THE DATA CONTROLLER
EuroAFF.com S.à r.l. (hereinafter he Company," "We," or "Us"), a legal entity duly incorporated and existing under the laws of the Grand Duchy of Luxembourg, registered at 21 Rue du Puits Romain, 8070 Bertrange, Luxembourg, with Registration Number B280385.
3. PURPOSES OF PERSONAL DATA PROCESSING
The Platform provides the technical means for communication between Consumers, including Owners and Sitters. Although we do not directly interfere in their communication and agreements, we aim to create a safe, transparent, and efficient environment for all participants.
To this end, we process personal data, which allows us not only to maintain the stable operation of the Platform but also to prevent potential misconduct by Consumers. The collection and analysis of data helps us identify potential risks, verify the provided information, ensure Consumer verification and identification, and respond to violations of the Platform's terms of use.
We adhere to the principle of data minimization and only use the information necessary to achieve the specified purposes.
Platform and Account Administration
To provide access to the Platform and its functionalities, it is necessary to process the personal data of Consumers. This includes creating and maintaining accounts, managing access, authenticating Consumers, and verifying their identity.
The Platform uses a third-party service, Kycaid, for identity verification, which performs document verification, selfie verification, and background checks. Accordingly, during the verification process, data is provided directly to this service and is processed in accordance with Kycaid’s Privacy Notice. The Platform does not control the data processing procedures of this service and is not responsible for its notice on personal data protection.
Our platform uses the TalkJS service (Klets B.V.) to provide chat functionality. TalkJS acts as a data processor, processing user data solely for the purpose of delivering chat services in compliance with applicable data protection laws. You can review the details of TalkJS’s data processing practices in its Data Protection Terms.
Providing Services on the Platform
The Platform processes Consumers' data to enable interaction between them, including organizing contacts between Owners and Sitters. This includes:
  • Personalizing profiles and recommendations, setting up search filters.
  • Automating the selection of suitable Sitters for Owners.
  • Enabling Consumers to create accounts and manage their personal information.
  • To ensure transparency in interactions, Consumers can leave reviews and ratings, which also involves processing personal data.
    Payment Processing and Financial Transactions
    To carry out financial operations, the Platform processes Consumers' payment data, including information about bank cards, accounts, and tax details, if necessary for financial accounting. The Platform operates on a subscription basis, so payment data is used for:
  • Payment of subscriptions and automatic renewal.
  • Processing requests for changes to the payment method or subscription cancellation.
  • Fulfilling financial obligations to tax authorities in accordance with the law.
  • Payment processing is carried out exclusively through third-party payment service providers, including the payment system Stripe, which acts as an independent data controller. All financial transactions are processed directly through Stripe's servers. Consumers can review Stripe's Privacy Notice and terms for processing payment data via the following link: Stripe Privacy Notice.
    Analytics and Platform Improvement
    We strive to make the use of the Platform more convenient and efficient, so we analyze how Consumers interact with the service. This allows us to adapt functionality, increase speed, address technical issues, and improve the mechanisms for matching suitable Sitters and Owners.
    The collected data helps us understand which features are most useful, what needs improvement, and enables us to optimize navigation and processes on the platform. To achieve this, technologies for analyzing traffic, behavioral trends, and technical errors may be used.
    The Company adheres to the principle of data minimization: all information used for statistical analysis is processed in an anonymized form and does not contain information that could directly identify a Consumer. Consumers can also manage their privacy settings, limiting the use of analytical data in their account or browser settings.
    Marketing and Advertising Campaigns
    The Company may use the contact details of Consumers to inform them about new service features, special offers, and updates to the Platform’s functionality.
    Marketing communications may be sent in the following forms:
  • Emails with personalized offers and service updates.
  • Push notifications to the Consumer’s device, if they have granted the appropriate permission in their browser.
  • Targeted advertising through third-party platforms, such as Google Ads, Facebook Ads, Instagram Ads, YouTube Ads, which may be adapted according to the Consumer’s preferences and activity on the Platform.
  • The Company provides Consumers with the ability to control the receipt of marketing communications. Consumers can unsubscribe from promotional newsletters at any time through their account settings, by sending a request to customer support, or by clicking the unsubscribe link in the email.
    However, the Company does not transfer personal data to advertising platforms without appropriate legal grounds and always acts within the framework of applicable laws, including the GDPR and other international data protection standards.
    Compliance with Legal Obligations
    FlatRover processes personal data in accordance with the requirements of applicable legislation, including Regulation (EU) 2016/679 (GDPR), as well as the legislative requirements of the countries in which it operates. This means that personal data processing may occur for the following purposes:
  • To fulfill financial, accounting, and tax obligations, including in compliance with the requirements of tax and financial regulators.
  • To provide information to competent state authorities in response to official requests that meet legal standards (e.g., as part of investigations or upon judicial authority requests).
  • To protect the Company’s legitimate rights and interests in the event of legal disputes, administrative proceedings, or other legal processes related to the Platform’s operations.
  • Personal data may be transferred to government agencies or other parties solely in cases provided for by law and where proper legal grounds exist. The Company ensures that any request for disclosure of information will be thoroughly reviewed for compliance with legal requirements and international data protection standards.
    Ensuring Security and Preventing Fraud
    The Company uses Consumers' data to detect, investigate, and prevent fraudulent activities, abuse, or violations of the Platform’s rules. This includes:
  • Verifying the accuracy of provided data through a verification system.
  • Analyzing activity to detect suspicious actions on the Platform.
  • Responding to rule violations, including temporarily restricting access or removing Accounts.
  • Data Protection and Compliance with International Standards
    The Company implements measures to ensure the security of personal data, including activity monitoring, encryption mechanisms, and protection against unauthorized access. All processed data is stored in accordance with international information protection standards and can only be accessed by authorized personnel responsible for the Platform's operation.
    4. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
  • Consent. We may process your personal data if You have given Us consent to use Your personal data for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract. We may process your personal data when we deem it necessary to fulfill our contractual obligations to You, including providing our services or at your request prior to entering into a contract with you.
  • Legal Obligations. We may process your personal data when we believe it is necessary to comply with our legal obligations, such as cooperating with law enforcement or regulatory authorities, exercising or defending our legal rights, or disclosing your information as evidence in a legal proceeding we are involved in.
  • Vital Interests. We may process your personal data when we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving a potential threat to the safety of any individual.
  • 5. PERSONAL DATA WE COLLECT
    This section contains information about the personal data of Consumers that We may collect during their use of our services, as well as personal data that We may receive from other sources.
    The table below defines the categories of personal data that We collect, use, store, transfer, or otherwise process:
    Categories of personal informationExamples of personal data collectedCategories of personal data sources
    IdentifiersFirst name, last name, date of birth, age, gender, information about social media posts, other account data, and IP address.Directly from You or through Your use of the Platform; Cookies and other tracking technologies; Third parties (Kycaid).
    Registration dataIf You register or log in to your account using a third-party service like Google or Facebook, We receive certain information, such as Your registration details and profile from that service. This information includes, for example, your email address, name, and profile picture, but may vary and is controlled by that service or based on Your privacy settings with that service.Directly from You or through Your use of the Platform; Third parties (Google, Facebook).
    Contact informationPhysical address, email address, phone number, additional number, social media links (Telegram, LinkedIn, Instagram, Facebook), contacts from other messengers (Viber, WhatsApp, Signal, Telegram), and any other contact information You provide to us.Directly from You or during Your use of the Platform; Third parties.
    Activity on the Internet or other networks or devices, including cookie informationUnique identifiers of devices and applications, browsing history or other usage data, the web browser and operating system you are using, the URL or advertisement that redirected You to the Platform, search terms you entered in a search engine that led You to the Platform, the section of the Platform You visited, the links you clicked on, the pages or content You viewed and how long, other similar information and statistics about Your interaction, such as response time of content, loading errors, and duration of visit to specific pages, and other information typically transmitted when browsers interact with websites.Directly from You or during Your use of the Platform; Cookies and other tracking technologies.
    Information about approximate geolocationYour approximate location.Directly from You or during Your use of the Platform; Cookies and other tracking technologies.
    Payment informationInformation about bank account, credit or debit cards.Directly from You; Third parties (payment processors).
    Usage dataInformation about how You use Our Platforms, products, and services.Cookies and other tracking technologies.
    Marketing and communication dataYour preferences regarding receiving marketing information from Us and Our third parties, as well as Your preferences for communication.Directly from You or during Your use of the Platform; Cookies and other tracking technologies; Third parties.
    Other information that identifies You or may be reasonably linked to YouContent created by Consumers, photos, information about work You have previously done, skills, awards, and other information You provide to us.Directly from You or Your use of the Platform; Third parties.
    Other, non-mandatory informationHobbies and interests, presence of children, marital status, information about public conflicts, tax identification number (TIN), and other information You provide to Us.Directly from You or during Your use of the Platform.
    Additional information defined by the Consumer for public accessDetails about the Home’s conditions, Pets, their characteristics, potential health issues, as well as other data provided voluntarily by the Consumer and not required for the use of the Platform.Directly from You.
    The Consumer may choose not to provide this information, but it may hinder the use or access to certain features of the Platform.
    If You decide to register a Consumer account, You are responsible for maintaining the security of Your account data. We recommend that You do not share Your username, password, or other access details with anyone else. If You believe Your account has been compromised, please contact Us immediately.
    Before providing Us with personal data about another individual, You must obtain that individual's consent for both the disclosure and processing of their personal information in accordance with this Notice.
    We also collect, use, and disclose "Aggregate Data" (if the data has been combined or collected in a summary or other form that cannot identify an individual) or "Anonymized Data" (where personal data has been removed so that other data cannot reasonably be linked to an identified individual) for any purposes. Aggregate Data and Anonymized Data may be derived from personal data but are not considered personal data as they do not directly or indirectly reveal Your identity.
    Any information We receive from third parties will be treated in accordance with this Notice. We are not responsible for the accuracy of information provided to Us by third parties, nor are We responsible for the notices or practices of any third party.
    6. PROCESSING OF PERSONAL DATA OF MINORS
    In order to respect the privacy of minors, We consciously do not collect, store, or process personal data provided through the Platform by individuals under the age of 18.
    If You are a parent or guardian of a child who has provided Us with their personal information, You may contact Us using the contact details provided below to request that it be deleted.
    As of the date this Notice takes effect, We have no actual knowledge that We "share" or "sell" personal information of individuals under the age of 18.
    7. COOKIES USAGE NOTICE
    Our Site uses cookies. A Cookie is a text file that contains a small amount of information, which is sent to the web browser and stored on the Consumer's device. These files contain information that allows the Site to remember important data, making the use of the Site more efficient and useful for Consumers. For example, we use cookies to ensure proper navigation between the pages of the Site.
    We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and can be used by your browser during subsequent visits to the Site.
    By using cookie technology, We collect only anonymous statistical data to improve the Consumer's experience on the Site. We do not collect any data that would allow us to identify the Consumer.
    Types of Cookies We use:
  • Strictly Necessary Cookies are essential for the proper functioning of the Site and for providing services requested by the Consumer. The duration for which this type of cookie is stored depends on its type. They are used to save long-term settings for the Consumer.
  • Third-Party Analytical Cookies are necessary to improve the functioning of our Site. We use third-party services such as Google Analytics to analyze site traffic, identify popular sections, and improve the functionality of the Site. For more details on how Google processes the collected data, you can review it at the following link: Google's Privacy & Terms, Safeguarding your data.
  • Advertising Cookies are used to track Consumers of the Site. These cookies enable the Platform to provide advertising content that is more aligned with the specific interests of the Consumer. To achieve this, We may use advertising tools from the following providers and their corresponding Cookies:
  • Google Ads – Cookies used by Google for setting up ads in its services, such as in the search engine or for displaying ads online.
  • Facebook Ads (Facebook pixel) – Cookies used to match ads in Facebook services with the recipient's individual preferences.
  • Instagram Ads – Cookies used for setting up and personalizing ads on Instagram, taking into account consumer actions, interests, and interactions in the Instagram app.
  • YouTube Ads – Cookies used for targeting and personalizing video ads on the YouTube platform, considering consumer views, their activity, and preferences to display relevant content.
  • You can opt out of accepting cookies by enabling the settings in your browser that allow you to reject cookie settings. Information on how to manage cookies in specific browsers can be found on the pages dedicated to those browsers:
    However, please note that our Site may not function properly if all cookies are turned off.
    If You have not configured your browser to refuse cookies, our system will generate them when You log into our Site.
    8. RETENTION PERIOD OF PERSONAL DATA
    The Company stores and processes Consumers' personal data for the period necessary to fulfill contractual obligations, ensure the functionality of the Platform, and comply with applicable legal requirements.
    Consumers' personal data is retained no longer than necessary for the purposes for which it was collected, except in cases where retention is required to fulfill legal obligations, resolve potential disputes, or protect the legitimate interests of the Company.
    General Retention Periods for Personal Data
    Consumers' personal data is stored for the following periods:
  • Account Data (name, contact information, profile data) – stored for the entire period of using the Platform, and partial information is stored up to 12 months after the account is deleted.
  • Financial Information (payment data, account details) – stored for at least 5 years after the completion of the financial transaction, in accordance with accounting and tax requirements.
  • Technical Support Communication Data – stored for up to 24 months from the last interaction to ensure service quality.
  • Analytical and Statistical Data – may be stored in anonymized form for up to 5 years. Data from consumers who have not created an Account – stored for 6 months after the last activity, after which it is deleted or anonymized.
  • Marketing Data – stored until consent is withdrawn by the Consumer, but no longer than 24 months from the last activity on the Platform.
  • Deletion or Anonymization of Personal Data
    The Consumer has the right to withdraw consent for the processing of their personal data at any time or to request its deletion. In such a case:
  • The Account will be deactivated immediately, and personal data will be deleted or anonymized within 90 days after receiving the relevant request.
  • Financial and tax data that must be retained in accordance with the law will be stored for the legally defined period.
  • After the expiration of the specified retention periods, personal data will be permanently deleted or anonymized unless its further use is necessary.
  • To submit a request for the deletion of personal data or to obtain additional information about their retention periods, the Consumer can contact the Company using the contact details provided in Section 17 of this Notice.
    Exceptions to General Personal Data Retention Rules
    The Company has the right to extend the retention period of personal data in the following cases:
  • The occurrence of legal disputes, court proceedings, or regulatory checks – until the relevant matter is resolved.
  • Compliance with legislative and regulatory requirements that obligate the Company to retain certain categories of personal data for a specified period.
  • The need to protect the legitimate rights and interests of the Company in accordance with applicable law.
  • 9. CONSUMER RIGHTS REGARDING PERSONAL DATA
    All Consumers of the Platform have the following rights:
  • The right to know the sources of collection, the location of their personal data, the purpose of its processing, and the location of the Data Controller.
  • The right to access their personal data and the right, upon request, to receive a copy of it.
  • The right to correct their personal data.
  • The right to delete their personal data, provided there is no breach of obligations and no need to retain the data.
  • The right to restrict or block the processing of their personal data if the Consumer objects to such processing, doubts the accuracy of their data, believes that its processing is unlawful, or if it is necessary for the establishment, exercise, or defense of the Consumer's rights in court.
  • The right to receive the personal data provided to Us (in a structured, commonly used, and machine-readable format), and to reuse it elsewhere or request Us to transfer it to a third party of the Consumer's choice.
  • The right to withdraw consent for processing.
  • The right to request the cessation of the processing of their personal data, and We will do so, except in cases where there are legitimate and imperative reasons for such processing.
  • The right to file a complaint with Us regarding any processing of their personal data or to contact the supervisory authorities in the country where the Consumer resides or works.
  • The right to opt out of processing their personal data for analytical purposes.
  • The right to opt out of processing their personal data for targeted advertising.
  • Other rights provided by law.
  • Please note that some of these rights may be restricted if We have a legitimate interest or legal obligation to continue processing the data, or if the data may be exempt from disclosure due to legal professional privileges or obligations to maintain professional secrecy.
    10. DISCLOSURE OF CONSUMERS' PERSONAL DATA TO THIRD PARTIES
    We do not transfer personal data to third parties, except in cases where such transfer is required by applicable law, at the request of the data subject, or in other cases specified in this Notice.
    Access to Consumers' personal data may be granted to individuals who need such access for the purposes of supporting, ensuring the quality, operation, or improvement of the Platform and our services. These individuals include:
  • Our Employees. Our employees process your personal data to provide services, customer support, technical support, marketing, and other operational purposes of the company. All employees are required to comply with appropriate measures for personal data protection. Your data is used exclusively in the course of fulfilling the tasks and responsibilities of employees, ensuring the confidentiality and protection of your personal information.
  • Affiliates. We may provide information about You that we collect to any of our current or future subsidiaries or affiliated companies, which may use it in accordance with this Notice.
  • Service Providers and Partners. We may provide information about You that we collect to our partners, contractors, and service providers who perform functions on our behalf, such as supporting the operation of the Platform, data hosting, and others.
  • Government Authorities. We may share information with government authorities in accordance with legal requirements, including (without limitation) in response to lawful requests from government bodies to fulfill national security or law enforcement requirements, as well as in connection with income reporting. We cooperate with government and law enforcement agencies to ensure compliance with and enforcement of the law.
  • By visiting the Platform and providing your personal data, You consent to their processing by third parties as outlined above, unless separate consent is required.
    All individuals who have access to Consumers' personal information are required to comply with all applicable legal requirements regarding the protection of Consumers' personal data and their confidentiality.
    With the Consumer's consent, the Platform may interact with other third-party websites or services operated by third parties. We do not control the operation of such third-party websites or services, and this Privacy Notice does not apply to them unless explicitly stated otherwise.
    We recommend that Consumers carefully review the Notice and Personal Data processing practices of any third-party website or service before providing any personal data or other information that could be used for identification.
    11. PROTECTION OF PERSONAL DATA
    We use widely accepted technological and operational security standards, a combination of administrative, technical, personnel, and physical measures to protect the information and personal data we collect from loss, misuse, disclosure, alteration, or destruction.
    However, no one can guarantee the complete security of your information and absolute protection from any threats beyond our control. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe the security of any account you may have with us has been compromised), please immediately notify us about the issue by contacting customer support according to the instructions provided below.
    We recommend that Consumers do not use unsecured channels to transmit confidential information to Us.
    12. CHANGES TO THE PRIVACY NOTICE
    We may update this Notice by posting a new version on our Site. If We update it in a way that significantly changes how We use Consumers' personal data, We will notify them about these changes if it is reasonable and feasible. Otherwise, We recommend that Consumers periodically review this Notice to stay informed about any other changes.
    The "Last Updated" date above will indicate when the Terms were last reviewed. By continuing to use the Platform after this date, You agree to the changes.
    13. REGIONAL PRIVACY PROVISIONS: AUSTRALIA
    This section applies to Consumers accessing the Platform from Australia and outlines additional rights and obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), as amended by the Privacy and Other Legislation Amendment Act 2024.
    Compliance with Australian Privacy Law
    Company, acknowledges and complies with the requirements of the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the amendments introduced by the Privacy and Other Legislation Amendment Act 2024. This Notice explains how We collect, use, disclose, and store the personal data of Consumers in Australia, as well as their rights under the applicable laws.
    Collection and Use of Personal Data
    In addition to the categories of personal data described in Section 5 of this Notice, We collect, use, and disclose personal data of Australian Consumers for the following purposes:
  • Platform Administration: Ensuring seamless access to the Platform and maintaining its core functionalities.
  • Consumer Authentication and Security: Verifying identity, preventing unauthorized access, and ensuring secure transactions.
  • Compliance with Australian Legal Requirements: Responding to requests from law enforcement, regulatory authorities, and fulfilling tax and legal obligations.
  • Marketing and Communication Preferences: Processing Consumer preferences regarding direct marketing communications, in accordance with the Spam Act 2003 (Cth).
  • Cross-Border Data Transfers
    The Company is incorporated under the laws of the Grand Duchy of Luxembourg and processes personal data using infrastructure located outside Australia. By using the Platform, Australian Consumers acknowledge and consent to the transfer of their personal data outside Australia, including to the European Economic Area (EEA) and other jurisdictions where the Company or its service providers operate. In accordance with the Privacy and Other Legislation Amendment Act 2024, the Company must take additional security measures to protect personal data transferred outside Australia. If a data breach occurs, affected Australian Consumers will be notified without undue delay, and the breach will be reported to the Office of the Australian Information Commissioner (OAIC) as required by law.
    Consumer Rights Under Australian Law
    In addition to the rights outlined in Section 9 of this Notice, Australian Consumers have the following rights under the Privacy Act 1988 (Cth), as amended:
  • Consumers may request access to personal data held by Us, subject to legal exceptions.
  • Consumers may request corrections to inaccurate, incomplete, or outdated personal data.
  • Consumers may object to certain data processing activities, including direct marketing.
  • Where We rely on consent as the legal basis for processing, Consumers may withdraw such consent at any time.
  • If a Consumer believes their privacy has been seriously breached, they may have a statutory right to initiate legal proceedings for serious invasion of privacy, as per amendments introduced in the Privacy and Other Legislation Amendment Act 2024.
  • To exercise these rights, Consumers may contact Us using the details provided in Section 17.
    Complaints and Dispute Resolution
    If an Australian Consumer has a concern regarding how We handle their personal data, they may lodge a complaint by contacting Us at the details provided below. We will acknowledge receipt of the complaint and aim to respond within 45 days. If the Consumer is not satisfied with Our response, they may escalate the complaint to the Office of the Australian Information Commissioner (OAIC).
    14. REGIONAL PRIVACY PROVISIONS: CANADA
    This section applies to Consumers accessing the Platform from Canada and outlines additional rights and obligations under the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the Consumer Privacy Protection Act (CPPA), introduced as part of Bill C-27.
    Compliance with Canadian Privacy Law
    The Company acknowledges and complies with the requirements of PIPEDA and, where applicable, CPPA. This Notice explains how We collect, use, disclose, and store the personal data of Consumers in Canada, as well as their rights under the applicable laws.
    Collection and Use of Personal Data
    In addition to the categories of personal data described in Section 5 of this Notice, We collect, use, and disclose personal data of Canadian Consumers for the following purposes:
  • Platform Administration: Ensuring seamless access to the Platform and maintaining its core functionalities.
  • Consumer Authentication and Security: Verifying identity, preventing unauthorized access, and ensuring secure transactions.
  • Compliance with Canadian Legal Requirements: Responding to requests from law enforcement, regulatory authorities, and fulfilling tax and legal obligations.
  • Marketing and Communication Preferences: Processing Consumer preferences regarding direct marketing communications, in accordance with the Canadian Anti-Spam Legislation (CASL).
  • Cross-Border Data Transfers
    The Company is incorporated under the laws of the Grand Duchy of Luxembourg and processes personal data using infrastructure located outside Canada. By using the Platform, Canadian Consumers acknowledge and consent to the transfer of their personal data outside Canada, including to the European Economic Area (EEA) and other jurisdictions where the Company or its service providers operate. In accordance with PIPEDA and CPPA, the Company must take additional security measures to protect personal data transferred outside Canada. If a data breach occurs, affected Canadian Consumers will be notified without undue delay, and the breach will be reported to the Office of the Privacy Commissioner of Canada (OPC) as required by law.
    Consumer Rights Under Canadian Law
    In addition to the rights outlined in Section 9 of this Notice, Canadian Consumers have the following rights under PIPEDA and, where applicable, CPPA:
  • Consumers may request access to personal data held by Us, subject to legal exceptions.
  • Consumers may request corrections to inaccurate, incomplete, or outdated personal data.
  • Consumers may object to certain data processing activities, including direct marketing.
  • Where We rely on consent as the legal basis for processing, Consumers may withdraw such consent at any time.
  • Under CPPA, Consumers may request their personal data in a structured, commonly used, and machine-readable format.
  • If a Consumer believes their privacy has been seriously breached, they may file a complaint with the Office of the Privacy Commissioner of Canada (OPC).
  • To exercise these rights, Consumers may contact Us using the details provided in Section 17.
    Complaints and Dispute Resolution
    If a Canadian Consumer has a concern regarding how We handle their personal data, they may lodge a complaint by contacting Us at the details provided below. We will acknowledge receipt of the complaint and aim to respond within 45 days. If the Consumer is not satisfied with Our response, they may escalate the complaint to the Office of the Privacy Commissioner of Canada (OPC).
    15. REGIONAL PRIVACY PROVISIONS: UNITED STATES OF AMERICA
    This section applies to Consumers accessing the Platform from the United States and outlines additional rights and obligations under federal and state data privacy laws.
    Compliance with U.S. Privacy Law
    Company acknowledges and complies with applicable U.S. federal privacy laws. Additionally, We comply with state-specific laws, including:
  • California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA): California residents have specific rights regarding their personal data, including the right to access, delete, and opt out of the sale of their data.
  • Virginia Consumer Data Protection Act (VCDPA): Virginia residents have rights to access, correct, delete, and opt out of processing for targeted advertising.
  • Colorado Privacy Act (CPA): Colorado residents have rights to access, correct, delete, and opt out of data processing for targeted advertising.
  • Connecticut Data Privacy Act (CTDPA): Connecticut residents have rights to access, correct, delete, and opt out of data processing for targeted advertising.
  • Utah Consumer Privacy Act (UCPA): Utah residents have rights to access, delete, and opt out of the sale of their personal data.
  • Collection and Use of Personal Data
    In addition to the categories of personal data described in Section 5 of this Notice, We collect, use, and disclose personal data of U.S. Consumers for the following purposes:
  • Platform Administration: Ensuring seamless access to the Platform and maintaining its core functionalities.
  • Consumer Authentication and Security: Verifying identity, preventing unauthorized access, and ensuring secure transactions.
  • Compliance with U.S. Legal Requirements: Responding to requests from law enforcement, regulatory authorities, and fulfilling tax and legal obligations.
  • Marketing and Communication Preferences: Processing Consumer preferences regarding direct marketing communications in accordance with applicable laws.
  • Cross-Border Data Transfers
    The Company is incorporated under the laws of the Grand Duchy of Luxembourg and processes personal data using infrastructure located outside the United States. By using the Platform, U.S. Consumers acknowledge and consent to the transfer of their personal data outside the U.S., including to the European Economic Area (EEA) and other jurisdictions where the Company or its service providers operate. In compliance with U.S. privacy laws, the Company must take additional security measures to protect personal data transferred outside the United States. If a data breach occurs, affected U.S. Consumers will be notified without undue delay, and the breach will be reported to the appropriate regulatory bodies in accordance with applicable laws.
    Consumer Rights Under U.S. Law
    In addition to the rights outlined in Section 9 of this Notice, U.S. Consumers have the following rights under federal and state privacy laws:
  • Consumers may request access to personal data held by Us, subject to legal exceptions.
  • Consumers may request corrections to inaccurate, incomplete, or outdated personal data.
  • Consumers may request deletion of their personal data, subject to certain legal exceptions.
  • Consumers may opt out of the sale of their personal data to third parties if applicable.
  • Where We rely on consent as the legal basis for processing, Consumers may withdraw such consent at any time.
  • Consumers will not be discriminated against for exercising their data privacy rights.
  • To exercise these rights, Consumers may contact Us using the details provided in Section 17.
    Complaints and Dispute Resolution
    If a U.S. Consumer has a concern regarding how We handle their personal data, they may lodge a complaint by contacting Us at the details provided below. We will acknowledge receipt of the complaint and aim to respond within 45 days. If the Consumer is not satisfied with Our response, they may escalate the complaint to the relevant regulatory bodies.
    16. APPLICABILITY OF THIS NOTICE IN OTHER JURISDICTIONS
    This Privacy Notice applies to all Consumers regardless of their location. However, some countries may have additional requirements for the processing and storage of personal data that are not covered by specific sections of this Notice.
    For Consumers located in countries not included in the list of specific jurisdictions, the general provisions of this Notice apply in accordance with the principles of international law in the field of personal data protection.
    The Company may transfer personal data outside the Consumer's country, including to jurisdictions that may have a different level of protection for personal data.
    If a Consumer has questions regarding the applicability of this Notice in their country or wishes to exercise their rights, they can contact us using the contact details provided in section 17 of this Notice.
    17. CONTACT US
    If You have any comments or questions regarding our Platform or any concerns, feedback, or complaints about our Notice, You can contact our specialist by:
  • Sending an email to: [email protected]
  • We strive to respond to consumers' electronic inquiries without undue delay, but no later than 30 calendar days from receipt. If the request is complex or if we have received a significant number of requests simultaneously, this period may be extended to 90 days, and the Consumer will be informed of the delay along with the reason for it.
    Please note that processing times may vary depending on the legal requirements of your country.
    When You send us an email with a request, We may ask You to provide information necessary to verify your identity.
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