Eltima IBC has created this privacy statement in order to fully disclose its information gathering and dissemination practices for the Eltima IBC Website (“Website”), and the Services offered and provided through the Website (“Services”).
Table of Contents
- A. Background Information
- B. A Word from Eltima IBC
- C. Information Eltima IBC Collects
- D. Purpose of Processing & Use and Disclosure of Information
- E. Data Choices Available to You
- F. Rights of European Users under the General Data Protection Regulation (GDPR)
- Data Controller
- Data Processor
- Legal Basis for Processing
- GDPR Rights:
- Retention Policy
- Cross-Border Data Transfers
- G. Privacy-Related Inquiries and Complaints
A. BACKGROUND INFORMATION
- (1) Description of the types of personally identifiable information (Yours and that of third parties) collected through the Website and Services;
- (2) How collected personally identifiable information is used;
- (3) With whom the collected personally identifiable information may be shared;
- (4) The choices available to You regarding the collection, use, and distribution of such information;
- (5) Security procedures that are in place to protect against the loss, misuse, or alteration of personally identifiable information under Eltima IBC’s control; and
- (6) Instructions on how You can access and correct any inaccuracies in the information collected about You.
A note about the Website and Services: Some of Eltima IBC’s Services, data centers, service providers, affiliates or operating partners and servers may be located in other countries. As such, the Website and Services may be subject to the laws of numerous countries and jurisdictions, some of which may require Eltima IBC to disclose certain information about its users. Eltima IBC is committed to keeping Your information private while using its best efforts to comply with all applicable laws in the jurisdiction(s) in which it operates.
B. A WORD FROM ELTIMA IBC
C. INFORMATION ELTIMA IBC COLLECTS
Information Eltima IBC Collects Through the Website
The Website does not collect personally identifiable information from Your computer when You browse the Website and request pages from Eltima IBC servers. This means that, unless You voluntarily and knowingly provide Eltima IBC with personally identifiable information, Eltima IBC will not know Your name, email address, or any other personally identifiable information.
When You use the Website, Eltima IBC, or trusted authorized third parties, may also collect certain technical and routing information about Your computer (also known as environmental variables) to facilitate Your use of the Website and the Services enabled thereby. When You browse the Internet, Your Internet browser (such as Mozilla Firefox, Google Chrome, or Microsoft Internet Explorer) automatically transmits some information to Eltima IBC every time You access content on one of Eltima IBC’s internet domains. Examples of such information include the URL of the particular web page You visited, the IP address of the computer You are using, or the browser version that You are using to access the Website. All of this information may be collected by Eltima IBC and used to help improve its offerings to You.
Providing Your Information to Eltima IBC
You never have to provide personally identifiable information to Eltima IBC. However, should You choose to withhold certain required information, Eltima IBC may not be able to provide You with some or all of the Services. Some of the information Eltima IBC asks You to provide may be identified as mandatory or optional. If You do not provide the mandatory information with respect to a particular activity, You may not be able to engage in that activity or make such a purchase. Eltima IBC will inform You of the mandatory or optional nature of the requested or required information.
When You submit personal information to Eltima IBC through the Website, You understand and AGREE that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which Eltima IBC and its affiliates and subsidiaries maintain offices. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of Your information may be undertaken by trusted vendors of Eltima IBC. Eltima IBC may use vendors to aid in the facilitation of technical support services that may potentially receive limited access to Your personal information.
FastSpring, Payoneer, PayPal, Tipalti, 2Checkout, Paddle and any other third-party payment service providers designated by Eltima IBC are responsible for payment information You provide through the Website, which will be subject to their respective privacy policies, such as:
When registering for a User Account or otherwise contacting Eltima IBC in connection with Your interest in utilizing Eltima IBC products or Services, Eltima IBC may ask You to provide certain information. Such information may include Your name, email, address, phone number, and other personally identifiable information. It is completely optional and voluntary for You to register for a User Account, engage in activities requiring a User Account, or to provide any personal identifiable information. However, certain information and proper identification may be required in order for You to engage in certain services provided by Eltima IBC.
Once You create a User Account, You will be deemed a Registered User. You may also request to change information associated with Your User Account by contacting Eltima IBC at firstname.lastname@example.org.
If You wish to deactivate your User Account, You may contact Eltima IBC at email@example.com. When You deactivate Your personal account, all information stored and maintained as part of Your User Account may be retained for archival, backup and record purposes.
Third-Party Websites and Service Providers
The Website may contain links to websites owned and operated by third parties. These links are presented for Your convenience and information. Eltima IBC does not control these third-party websites and is not responsible for their privacy practices or content. Eltima IBC does not control the information collection and distribution policies on such websites other than those that are under the control of Eltima IBC itself. Content on third-party websites may not reflect products, services, and/or information provided by Eltima IBC. Third parties may also set their own cookies and/or use web beacons, which may be used to identify some of Your preferences or to recognize You if You have previously had contact with these third parties. Eltima IBC does not control the use of such technology by third parties, the information they collect, or how they use such information. You should direct all concerns regarding any third-party website directly or to the site administrator or webmaster.
Eltima IBC also uses third-party advertising companies to serve ads when You visit the Website. These companies may use general information about Your visits to the Website as well as other websites in order to provide advertisements about goods and services of interest to You. If You would like more information about this practice and Your choices as to not having Your information used by these companies, please direct such concerns to the respective company’s administrator or webmaster, as detailed below under the subheading “Targeting Cookies.”
Information Relating to Children (COPPA)
The Children’s Online Privacy Protection Act (COPPA) was passed by the U.S. Congress in November 1998. COPPA provides parents with specific rights regarding their children’s privacy. For additional information and resources on COPPA, please visit the Federal Trade Commission (FTC) website. The Eltima IBC Website and any Software or Services available thereon are not directed at children under 13 years of age and, therefore, COPPA does not apply. However, Eltima IBC recognizes that children under the age of 13 may potentially access the Website and subscribe to the newsletter, purchase Software and Services, or download software programs. Parents and Legal Guardians may request Eltima IBC to review, delete or stop the collection of any personally identifiable information of their child(ren). You may do so by contacting Eltima IBC by email at firstname.lastname@example.org.
Cookies and Web Beacons
The Website uses “cookie” and “web beacon” technology. “Cookies” are short pieces of data generated by a web server that a website stores on a user’s computer. Certain pages on Eltima IBC’s Website may require the use of a cookie for purposes of keeping information You enter on multiple pages together. Cookies also enable Eltima IBC to customize the Website and offerings to Your needs and provide You with a better online experience with Eltima IBC. In addition, cookies are used to:
- Measure usage of various pages on Eltima IBC’s Website to help make Eltima IBC’s information more pertinent to Your needs and easier for You to access;
- Identify and categorize the internet webpages from which a visitor came to the Website and in order to observe browsing patterns; and
- Provide functionality such as online orders, Eltima IBC Services, and other functionalities that Eltima IBC believes would be of interest and value to You.
In addition, the service providers Eltima IBC uses to serve and host its advertisements may use session or persistent cookies to track the number of times the Website is accessed and whether the Website was accessed via an advertisement. There are no automatically-placed cookies within these advertisements, a cookie is placed on Your computer only if and when You click on an advertisement. The cookie generated from the advertisement does not contain any personally identifiable information and will remain on Your hard drive until You delete it. Furthermore, Eltima IBC may use email tracking services in order to receive read receipts and related information when sending emails, however, these services are used by Eltima IBC for these reasons and not to collect any personal information about You.
You may set your browser to block cookies (consult the instructions for Your particular browser on how to do this), although doing so may adversely affect Your ability to perform certain transactions, use certain functionality, and access certain content on Eltima IBC’s Website.
Web beacons are used in combination with cookies to help website operators understand how visitors interact with their websites. A web beacon is typically a transparent graphic image (usually 1-pixel x 1-pixel) that is placed on a website. As opposed to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on web pages and are about the size of the period at the end of this sentence. These web beacons are not tied to personally identifiable information. The use of web beacons allows a website to measure the actions of the visitor opening the page that contains the web beacon. It makes it easier to follow and record the activities of a recognized browser, such as the path of pages visited on a website. Eltima IBC uses the information provided by web beacons to develop a better understanding of how the Website’s visitors use the Website, and to facilitate those visitors’ interactions with the Website. Eltima IBC may make the aggregate data obtained from web analytics (including from its third-party analytics providers, if applicable) publicly available. If this data is made available, none of the information will be personally identifying information or potentially-personally identifying information.
Unless You are a Qualified Individual (as defined in Section F, below), Eltima IBC uses targeting cookies to record Your Website visits, the pages You viewed and the hyperlinks You followed. Eltima IBC may use this information and share it with third parties to make the Website and advertising more relevant to You.
Eltima IBC’s trusted partners, such as Google, help Eltima IBC to place advertisements on and off the Website, and perform analytics. Please read Eltima IBC’s trusted partners’ privacy and cookies policies below:
- Types of Cookies used by Facebook
- Facebook Ads
- Types of Cookies used by Google
- Google Ads (AdSense and AdWords)
Eltima IBC uses Google Analytics to analyze Website usage, with a performance cookie, which collects standard internet log and visitor information in an anonymized form. The information collected is transmitted to Google and then used to compile aggregate information on Website use. Eltima IBC also uses Google Ads to oversee online advertisements and to determine with which advertisements users most frequently click and respond. These cookies remain on Your device even after You have logged out or quit a session. To opt out of being tracked by Google Ads visit Google Ads Help.
D. PURPOSE OF PROCESSING & USE AND DISCLOSURE OF INFORMATION
How Your Personal Information is Used
Eltima IBC collects information from You in order to record and support Your participation in the activities provided by Eltima IBC. Eltima IBC may use Your email address to send a confirmation email when You sign up for a User Account and, if necessary, may use other information You provide to contact You for help to process or provide a purchase or Service You have selected. Your personal information also may be used to keep You informed about new services, service upgrades, special offers, and other Services.
Disclosure of Information to Third Parties
Eltima IBC may use the services of third parties, such as email service providers, purchase, shipping and order processing merchants and marketing companies that act as independent contractors on behalf of Eltima IBC. These parties are prohibited from using personally identifiable information for any purpose other than for the purpose Eltima IBC specifies. Eltima IBC does provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to Eltima IBC. Eltima IBC prohibits the sale or transfer of personal information to entities outside of the Eltima IBC’s affiliates for their use without Your approval.
Securing the Transmission and Storage of Information
Change of Control
In the event that all or substantially all of Eltima IBC’s stock and/or all or substantially all assets are transferred or sold to another entity, Eltima IBC may transfer personally identifiable information to the acquiring entity. If, as a result of such a business transition, Your personally identifiable information will be used in a materially different manner, You will be given notice as to such changes and the opportunity to re-consent or object to such material changes.
E. DATA CHOICES AVAILABLE TO YOU
Opt-In and Disclosure
You may always choose whether or not to disclose personally identifiable information and that choice will not prevent You from using the Website and having limited access to the Website and Services. Please note, however, if You should choose to withhold certain requested information, Eltima IBC may not be able to provide You with some or all of the Services dependent upon the collection of this information. You will be given an opportunity to “opt-in” and select Your preference choices for any items that are optional and which are not prerequisite for Eltima IBC rendering of Services.
You can choose at any time to opt-out of receiving emails from Eltima IBC by clicking the unsubscribe link at the bottom of any email You receive from Eltima IBC or by contacting Eltima IBC directly at email@example.com. If You elect to opt-out, Eltima IBC will not, as applicable, share Your personal information with third parties or send You emails. However, Eltima IBC may continue to use Your personal information for internal purposes, to enhance Your user experience or as necessary to administer the Website or comply with applicable law.
Registration Email and Contact by Eltima IBC
Eltima IBC reserves the right to send a one-time registration or payment confirmation email, and infrequent service alert messages to users to inform them of specific changes that may impact their ability to use a service that they have previously signed up for, purchased, or used, regardless of email contact opt-in status. Eltima IBC also reserves the right to contact You if compelled to do so as part of a legal proceeding or if there has been a violation of any applicable licensing, warranty, or purchase agreements. Eltima IBC is retaining this right because in limited cases Eltima IBC feels that it may need to contact You as a matter of law or regarding matters that will be important to You. This does not allow Eltima IBC to contact You to market a new or existing service if You have asked Eltima IBC not to do so, and issuance of these types of communications are rare.
User Account Preferences
When You create a User Account with Eltima IBC and/or provide Your email address and other personal identification information, subject to Your personal preferences, You CONSENT to allowing Eltima IBC to periodically contact You via email and provide information about special offers and promotions that may be of interest to You. These communications will relate to Eltima IBC offers and/or the promotions of select, reputable third parties with whom Eltima IBC has a strategic marketing relationship because they offer products or services that Eltima IBC believes would be of interest to You. Eltima IBC may use a third-party email service provider to send emails to You. This service provider is prohibited from using Your email address for any purpose other than to send Eltima IBC-related email. If You do not wish to receive emails with updates and information please unsubscribe by sending an email to firstname.lastname@example.org. In addition, every time You receive an email, You will be provided the choice to opt-out of future emails by following the “unsubscribed” (or similar) instructions provided in the email. You may also opt-out online by updating Your User Account as described under the subheading “User Account” in Section C, above.
To ensure that Your request is honored, You must provide Eltima IBC with information sufficient for Eltima IBC to accurately identify and access Your records. The information Eltima IBC requires is Your full name, address and the email address You provided to Eltima IBC when You requested Services or products. This information or any other information per each individual case, requested is viewed as sufficient for Eltima IBC to ensure You are who You proclaim to be. Eltima IBC reserves the right to contact You to verify that it has accurately identified Your record.
If You are a California resident, You can request a notice disclosing the categories of personal information that Eltima IBC may share with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit Your request to Eltima IBC’s Data Protection Officer at email@example.com. Please allow 30 days for a response. For Your protection and the protection of all of Eltima IBC’s users, Eltima IBC may ask You to provide proof of identity before it can answer such a request. Eltima IBC does not respond to general do not track (DNT) requests.
F. RIGHTS OF EUROPEAN USERS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
Eltima IBC complies with the principles of 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) (“GDPR”). If You are a natural person of the EU within the meaning of the GDPR (“Qualified Individual”), You are afforded certain additional rights by the GDPR as further described within this Section.
If and when Eltima IBC receives Your personal information directly from You via its Website or Services, it performs the functions of a Data Controller, as defined by the GDPR, and has the ability to determine how personal data is collected, for what purposes, and how this data is to be processed. As the data controller, Eltima IBC has implemented many technical and operational measures to ensure the most complete protection of personal data processed through its Website, and Services.
Legal Basis for Processing
Article 6(1)(a) of the GDPR serves as the legal basis for processing operations for which Eltima IBC obtains consent for a particular purpose. If the processing of personal data is necessary for the performance of a contract to which You are a party, as is the case, for example, when processing operations are necessary to provide a service, the processing is based on Art. 6(1)(b). The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning Eltima IBC products or Services. If Eltima IBC is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c). If the processing of personal data may be necessary to protect Your vital interests or that of another Qualified Individual, then the processing is based on Art. 6(1)(d). Finally, processing operations could be based on Article 6(1)(f) if processing is necessary for the purposes of the legitimate interests pursued by Eltima IBC or by a third party, except where such interests are overridden by Your fundamental rights and freedoms under the GDPR.
(i) Right of Confirmation
You may obtain confirmation of whether or not Your personal data is being processed. If You wish to exercise Your right of confirmation, You may contact Eltima IBC using the contact information as provided in Section G, below.
(ii) Right of Access
You may obtain from information about Your stored personal data at any time and a copy of this information. If You wish to exercise Your right of access, You may contact Eltima IBC using the contact information as provided in Section G, below.
(iii) Right to Rectification
You may request the rectification of any inaccurate personal data. Taking into account the purposes of the processing, You have the right to have inaccurate or incomplete personal data completed or deleted, by means of first appropriately identifying Yourself and then providing a supplementary statement. If You wish to exercise Your right of rectification please may contact Eltima IBC in accordance with Section G, below.
(iv) Right to Erasure (Right to be Forgotten)
You may request the erasure of Your personal information by contacting Eltima IBC using the contact information provided in Section G, hereof. Furthermore, You may delete Your User Account information by accessing Your User Account settings page on the Website. Please note that while any changes You make will be reflected in active user databases within a reasonable time, Eltima IBC may retain all information You submit for the prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where Eltima IBC otherwise reasonably believes that it has a legitimate reason to do so, such as for archiving purposes within the public interest.
(v) Right to Restriction of Processing
As a Qualified Individual, You have the right to restrict processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of the controllers use of such data;
- The controller no longer needs the personal data for the purposes of processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims; or
- The data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
(vi) Right to Data Portability
You may request to receive Your personal data in a structured, commonly used and machine-readable format. You have the right to transmit this data to another controller without interference.
Furthermore, You may have the personal data transmitted directly from one controller to another, where technically feasible and where such transmission does not adversely affect the rights and freedoms of others.
(vii) Right to Object and Automated Decision Making
You may object to decisions based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects You, as long as the decision is not (i) necessary for entering into, or the performance of, a contract between You and Eltima IBC; (ii) authorized by European Union or Member State law to which You are subject; or (iii) based on the data subject’s explicit consent.
(viii) Right to Object to Processing
You may object to the processing of Your personal data using the contact information provided in Section G below, unless there are legitimate grounds for the processing within the public interest, or for the establishment, exercise, or defense of legal claims.
If Eltima IBC processes personal data for direct marketing purposes, You shall have the right to object at any time to the processing of Your personal data for such purposes. This right also applies to profiling to the extent that the processing is related to such direct marketing purposes. If You object to Eltima IBC processing Your personal data for direct marketing purposes, then Eltima IBC will no longer process the personal data for such purposes.
Eltima IBC only retains personally identifiable information about You for as long as Your User Account remains active and for as long as it needs to provide You with Services or otherwise fulfill the purposes for which Eltima IBC had initially collected such information, unless otherwise required by law. Eltima IBC will retain and use information as necessary to comply with its legal obligations, for archival purposes, to assist in the resolve of disputes, and to enforce its agreements.
Cross-Border Data Transfers
If and when sharing of information involves cross-border data transfers, for instance to the United States of America and other jurisdictions, Eltima IBC uses EU Standard Contract Clauses or other suitable contracts and safeguards to permit data transfers from the EU to other countries. The Standard Contractual Clauses commit companies transferring and receiving Your personal information to protecting the privacy and security of Your data. Copies of Eltima IBC’s current Standard Contractual Clauses are available on request using the contact details listed below.
G. PRIVACY-RELATED INQUIRIES AND COMPLAINTS
Eltima IBC Inc.
Mailing Address: Office No. 515 & 517, A-1 Building, Ajman Free Zone, Ajman, United Arab Emirates
Please note that if You provide Eltima IBC with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact You with marketing offers and indicating on another occasion that they may not), Eltima IBC cannot guarantee that Your most recent privacy preference will be immediately honored.