Last updated 22.12.2022.
“GDPR” means the General Data Protection 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.
“EEA” includes all current member states to the European Union and the European Economic Area.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
Table of Contents:
Advelo Marketing Solutions OÜ, Harju maakond, Tallinn, Nõmme linnaosa, Pärnu mnt 388b, 11612, will be the controller of your personal data.
We collect data you make available to us voluntarily (for example, email address, name, date of birth). We also collect data automatically when you use the Service (for example, your IP address, device type).
2.1 Data you give us
You provide us data about yourself when you register for and/or use the Service, for example, when you create a user profile (“Profile”), respond to our emails, or report a problem. The data that you give us includes:
2.2 Data we collect automatically:
We process your personal data:
3.1 to provide Services to you.
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. For example, we use your data to authenticate you and authorize access to our Services, to suggest your Profile to users who search for Profiles with data that at least partially corresponds to data provided in your Profile.
3.2 to research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We conduct surveys, research, and test features in development. We analyze the data we have to evaluate our Service, and conduct audits and troubleshooting activities to improve our Service content and layouts. As a consequence, we often decide how to improve the Service based on the results obtained from this processing. For example, if we discover that users do not often use certain section of the Service, we may focus on improving this section.
3.3 to customize the Service for you
We select the payment processor available to you; we may also use your data to determine your eligibility for promotions, sweepstakes, and contests.
3.4 to process your payments
We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for paid features of the Service.
3.5 to verify your identity, including during account verification and background checks.
3.7 to communicate with you regarding your use of our Service.
We may communicate with you, for example, by email or directly on the Service, including through push notifications. As a result of such processing, we may send you messages about your statistics, such as who visit your Profile, add you to favorites list, like you or send you a message.
3.8 to show and/or send you marketing communications.
We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our Service, features, offers, promotions, contests, and events or provide other news or information about third party services that may be of interest to you. You can opt out of advertisement and/or commercial emails by contacting us at [email protected].
3.9 to provide you customer service and support.
As a result of such processing, we will send you messages about the availability of our Service, security, payment transactions, status of your orders, legal notices, or other Service-related information.
3.10 to personalize our ads.
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time.
3.11 to comply with legal obligations.
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.
We process your personal data under the following legal bases:
4.1 your consent;
4.2 to perform our contract with you;
Under this legal basis we:
4.3 for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
This includes, for example, sending you notifications indicating that you have received a new message. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you.
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Service easier and more enjoyable, or to introduce and test new features).
The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
4.4 to comply with legal obligations. Under this legal basis we, in particular, verify your identity.
This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected]. We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.
Access rights under California’s Shine the Light
California also provides its residents with additional access rights. Under Shine the Light law, the residents have the right to ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to us [email protected], which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
6. DATA RETENTION
Please note that we have a variety of obligations to retain the data that you provide to us, including to ensure that transactions can be appropriately processed, settled, refunded, or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if you disable/delete your Profile, we will retain certain data to meet our obligations.
7.1. Service providers.
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
7.2. Law enforcement agencies and other public authorities.
7.3. Third parties as part of a merger or acquisition.
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the EU-U.S. Privacy Shield Framework (details available here), or (iii) the European Commission adequacy decisions about certain countries (details available here).
We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at [email protected]
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided to us. You control your Profile; thus, you may access your profile data at any time and to correct or update it at any time by logging in to the Service. You may also request a copy of your personal data collected during your use of the Service at [email protected]
Deleting your personal data. You can request erasure of your personal data by sending us an email at [email protected]
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at [email protected]
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request at [email protected]
You may submit requests through an authorized agent, in which case we will need to verify the agent’s identity, your identity, and their authority to act on your behalf before we can process the request.
Customer Support: [email protected]