Privacy Policy

Effective as of August 21, 2018

1. Purpose and Scope

1.1 We are based out in Florida, USA (hereinafter referred to as the “Company” or “we”) and we strive to comply with applicable laws and regulations related to personally identifiable information protection. This Policy sets forth the basic principles by which we process your personally identifiable information, and indicates the responsibilities while processing personally identifiable information.

1.2 The Company acknowledges and understands that you are aware of and care about your own personal privacy interests, and the Company takes that seriously. This Privacy Policy describes the policies and practices with regard to the collection and use of your personally identifiable information. The Company recognizes that data privacy is an ongoing responsibility, and, therefore, the Company will from time to time update this Privacy Policy.

1.3 We do not have an establishment in the European Union or European Economic Area, we do not offer goods or services to any country of the European Union or European Economic Area, and we do not monitor behaviour of Europeans. All these facts exclude the application of the 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 (General Data Protection Regulation) according to article 3 of the General Data Protection Regulation.

2. Company’s website

2.1 The Company controls and manages (hereinafter the “Website”) which may collect your data for its business purposes when

3. Interaction with children

3.1 The Children's Online Privacy Protection Act (COPPA) governs operators of websites directed toward children under 13 years old that collect information from the children, or operators who know that they collect information from children under the age of 13. We do not knowingly collect and process any information from children under 13 years old. In case if we become aware of any such information from children under 13 years old, we will refuse to process such information further.

4. Your responsibilities

4.1 Read this Privacy Policy carefully.

4.2 If you provide the Company with personally identifiable informat ion about other individuals, the Company will only employ that data for the special reason for which it was provided to the Company. By sending the data, you confirm that you have the right to dispose to process the data on your behalf in accordance with this Privacy Policy.

4.3 Treat your personally identifiable information confidential and secure.

5. Collected data

5.1 The Company collects data when you interact with its Website, especially when you use the Website; the Company calls you; you receive emails from the Company.

5.2 The Company collects the following data: contact details such as your first name, last name, email address and phone number; data that identifies you such as your IP address, login information, browser type and version, time zone setting, browser plug-in types, operating system and version;

data on how you use the Websites such as your URL clickstreams (the path you take through the Websites), services viewed, page response times, download errors, how long you stay on webpages, what you do on those pages, how often, and other actions. The recipients of the collected data are the highest management level of the Company, and other third party service providers which help us provide services.

6. Purposes and legal basis for the processing

6.1 The Company processes the data for providing services, keeping the Website running, improving the Website, customer support, direct marketing purposes.

7. Your rights

7.1 You may choose not to provide the Company with personally identifiable information. If you choose to do so, you can continue to visit the Website and browse its pages.

7.2 You may turn off cookies in your browser via settings. You can block cookies on your browser refusing cookies. You may delete cookies. If you turn off cookies, you can continue to use the Website and browse its pages, but the Website and certain services will not work properly.

8. Security

8.1 The Company have security and organizational measures and procedures to secure the data collected and stored.

8.2 Connections to the Website are encrypted. We access your data and messages via our account through third party service providers which have security mechanisms to protect integrity and security of your data. We have a signed data processing agreement with our hosting company.

8.3The Company use servers that comply with strict international data security standards, including ISO 27001.

8.4 You acknowledge that no perfect security infrastructure exists, no data transmission is guaranteed to be 100% secure, and there may be some security risks.

8.5 You are responsible for your login information and password. You shall keep them confidential.

8.6 In case if your privacy has been breached, please contact the Company immediately.


9.1 Upon being aware of any unauthorized access of data in electronic form containing personal information (the “Breach”) we shall provide notice to the Department of Legal Affairs.

9.2 The notice to the Department of Legal Affairs with regard to any Breach of security shall be provided in case if the Breach affect 500 or more individuals in the state of Florida. Such notice shall be provided to the Department of Legal Affairs as expeditiously as practicable, but no later than 30 days after the determination of the Breach or reason to believe a Breach occurred

9.3 The rules regarding notices to affected individuals are defined by the “Florida Information Protection Act of 2014 or any law which supersedes the Act.

9.4 Good faith access of personal information by an employee or agent of the covered entity does not constitute a Breach of security, provided that the information is not used for a purpose unrelated to the business or subject to further unauthorized use.

10. Identifiable information

10.1 The personally identifiable information collected by the Company is processed, collected and stored at the Company’s offices in the USA.

11. Retention period

11.1 We store your personal data as far as we need such data for providing our services. We may be required by some applicable laws to store data for a longer period of time.

12. Transfer of your personally identifiable information

12.1 We collect and store data in the USA. We do not perform intentionally any type of transfer of data between countries. The mere accessibility of the Website shall not constitute the collection, storage or transfer of any data.

13. Cookies

13.1 Cookies are pieces of data that the Website transfers to your hard drive for record-keeping purposes. The Company uses cookies to provide proper functionality on the Website and aggregate traffic data (e.g., what pages are popular).

13.2 The Website capture limited data (user-agent, HTTP referrer, last URL requested by the user, client-side and server-side clickstream) about visits to the Website. The Company may use this data to analyze patterns and to perform system maintenance.

13.3 You have several options how to manage cookies on your device. All browsers allow you to block or delete cookies from your device. You may consult the privacy features in your browser to understand what you should do if you need to manage cookies.

13.4 For your convenience, you also may use “Privacy Preference Centre” where you can deactivate “Performance Cookies”, “Functional Cookies”, and “Targeting Cookies”.