Privacy Notice

WELL DONE! YOU CARE ABOUT YOUR PRIVACY!

We don’t use your personal information for any other purposes not described in this policy.

We are delighted that you have shown an interest in our company. We are committed to safeguarding the privacy of our customers and partners.

We (“Monedata") and you ("Publishers") are Joint Controllers in accordance with Article 26 GDPR for the Joint Processing in relation to the publishers users data as specified in this Privacy Notice and accordingly with the Terms and Conditions of Use (link, homepage, beside privacy notice).

By using our services, you agree with the practices described in this Privacy Notice and our Terms and Conditions of Use .

The personal data that we collect

Purposes of processing and legal basis

Providing your personal data to others

International transfers of your personal data

Retaining and deleting personal data

Your rights

About cookies

Our details

The personal data that we collect

We may process data about the users of your mobile application (" usage data"). The usage data may include users' IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is you (“Publishers”) with the user's explicit consent.

We may process data enabling us to get in touch with you "contact data". The contact data may include your name, email address, telephone number, postal address, product or service that you are interested in, and any comments that you would like to refer to us. The source of the contact data is you (“Publishers”).

We may process your website user "account data". The account data may include your account identifier, password, name, work email address, business name, account creation and modification dates, website settings, and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our system.

We may process information contained in or relating to any communication that you send to us or that we send to you "communication data". The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

We may process information relating to financial transactions, that you enter into with us through our website "transaction data". The transaction data may include your name, your contact details, vat ID, payment details, and transaction details. The source of the transaction data is you or our payment service providers.

Purposes of processing and legal bas is

Operations - We process your “personal data”, and your users “usage data” for the purposes of operating our website, provide our monetisation services and manage our business. The legal basis for this processing is our legitimate interests.

Relationships and communications - We process ‘contact data”, “transaction data” and “communication data” for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing). The legal basis for this processing is our legitimate interests.

Direct marketing - We process “contact data”, “account data” and “transaction data” for the purposes of promoting our business and communicating marketing messages and offers to our website visitors and service users. The legal basis for this processing is our legitimate interests.

Security - We process your “personal data”, and your users “usage data” for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

Providing your personal data to others

Your personal data held in our platform database will be stored on the servers of our third-party vendor hosting service provider Google Cloud (clique to access their Privacy and Trust White Paper). The vendor does not use or have access to your personal information for any purpose other than cloud storage and retrieval.

We may disclose personal data to our suppliers, subcontractors or partners insofar as reasonably necessary for providing our monetisation services and for website operational reasons. You can find information about our partners privacy policy and practices at Monedata Partners

Financial transactions relating to our products and services may be handled by our payment services providers. You can find information about the payment services providers' privacy policies and practices at Wise.

We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation, exercise, or defense of legal claims or in order to protect your vital interests or the vital interests of another natural person.

International transfers of your personal data

We may transfer your data to third parties that are based in countries located outside of the European Economic Area which are not subject to an adequacy decision by the European Commission.

In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organisational security measures to protect your data.

We also ensure a level of data protection at least equivalent to the one prevailing in the European Union by having an appropriate Standard Contractual Clause agreement in place with these third parties. You may request our SCC agreement by written notice to us at [email protected]

Retaining and deleting personal data

Personal data that we process for any purpose shall not be kept for longer than is necessary for that. We will retain your personal data according to our Data Retention Policy.

Your rights

Your rights under General Data Protection Regulation are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure - you can ask us to erase your personal data;

(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

You may exercise any of your rights in relation to your personal data by written notice to us at [email protected]

Cookies that we use

We only use strictly necessary cookies — These cookies are essential for you to browse our website and use its features, such:

(a) Crisp Chatbox - The Crisp chatbox, that is running on this webiste, uses cookies. Cookies are solely used in accordance with those points:

· Cookies are necessary for chatbox functionalities; they are needed to restore the chat session and messages of a chatbox user when browsing between website pages and/or coming back on the website a few days after.

· Cookies have a default expiration time of 6 months, which is renewed if and when the user comes back to the website and loads the chatbox.

· Cookies bind an user to a single session. If that session contains messages, it is permanent (unless deleted by a website agent); otherwise the session is temporary and is destroyed 30 minutes after the last website access.

· Cookies are not used for tracking purposes. They are solely used to bind an user to a server-side session storage, which is then used for messaging purposes, in the event either the user or a website agent starts a conversation.

· The user IP address is stored in the server-side session storage that's bound to the cookie. If the user leaves without using the chatbox messaging features, the session (and thus the IP address) will be automatically removed from Crisp servers upon session expiration (ie. 30 minutes after last access; as stated above).

· The user IP address is kept indefinitely in the event the user started a chat session with a website on Crisp. We are legally required by the law of France to log those IPs in the event of a legal request (for a minimum duration of 1 year). Though, we keep those IP address longer as we need to aggregate them to protect our chatbox service against botnets and spam attacks, which occur frequently. The Crisp service could not function at the level our customers expect from us without statistics on those collected IP.

· The Site may sometimes contain links to external websites or services that we do not control. Any person following a link to an external website, is encouraged to review the principles for processing of personal data and information about cookies that apply to the website in question.

(b) Matomo Analytics - This website uses the open-source web analysis service Matomo.

· Matomo uses technologies that make it possible to recognize the user across multiple pages with the aim of analyzing the user patterns (e.g. cookies or device fingerprinting). The information recorded by Matomo about the use of this website will be stored on our server. Prior to archiving, the IP address will first be anonymized.

· Through Matomo, we are able to collect and analyze data on the use of our website-by-website visitors. This enables us to find out, for instance, when which page views occurred and from which region they came. In addition, we collect various log files (e.g. IP address, referrer, browser, and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

· The use of this analysis tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

· IP anonymization. For analysis with Matomo we use IP anonymization. Your IP address is shortened before the analysis, so that it is no longer clearly assignable to you.

· Hosting. We host Matomo exclusively on our own servers so that all analysis data remains with us and is not passed on.

Our details

RUHNU DYNAMICS OÜ.

Lasnamäe Linnaosa, Lõõtsa 5-11, 11415,

Tallinn, Estonia.

[email protected]