International and EU GDPR
I. any information the Company collects about the User when he/she visits the Company’s Website, and/or otherwise interacts with any member of the Company’s Team;
II. how the Company uses, shares, stores, and secures the information; and
III. how the User may access and control that information.
1. User Information.
1.1. The Company may collect any ”Personal Information”, which is any data, information, or combination of data and information that is provided by the User to the Company, or through the use of the Company’s Website and that relates to an identifiable individual.
1.2. The Company collects the Personal Information when it is provided by the User or when the User visits the Website.
1.3. The Company does not collect sensitive data or special category data about the User. This includes details about race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.
1.4. The Company does not collect or share and/or transmit to third parties personal or sensitive user data like users’ Installed Application Information or users’ IP addresses; however the Meta/Facebook SDK may do so automatically and without the Company’s express consent.
2. Information Usage.
2.1. The Company will only use any Personal Information that the applicable law allows to and in particular:
● 2.1.1. to provide customer support and personalized features, and to protect the safety and security of the Website;
● 2.1.2. to satisfy a legitimate interest which is not overridden by the User’s fundamental rights or data protection interests, for example for research and development, and in order to protect the Company’s legal rights and interests;
● 2.1.3. when the User consents to do so for a specific purpose;
● 2.1.4. when the Company needs to comply with a legal or regulatory obligation arising from any Country.
2.2. When the User has given consent to use any Personal Information for a specific purpose, he/she has the right to withdraw said consent at any time by contacting the Company, but this will not affect any use of the Personal Information that has already taken place.
2.3. The Company does not share any Personal Information with any company outside its own group, if applicable, for marketing purposes, unless there is an express specific consent to do so.
2.4. For visitors to or users of the Website who are located in the European Union, the legal bases for processing their information are published in the Legal Bases Table at the end of this Policy under Clause 9.
3. Information Sharing.
3.1. The Company may share Personal Information with third parties that help it operate, provide, support, improve, and market its Website, others products and services, for example, third-party service providers who provide website and application development, data storage and backup, infrastructure, payment processing, customer support, business analytics, Anti-Money Laundering (”AML”) and Know Your Customer checks (”KYC”) and other relevant services.
3.2. Third-party service providers have access to Personal Information only for the purpose of performing their services and in compliance with applicable laws and regulations. These third-party service providers are required to maintain confidentiality and security of all Personal Information that they process on the Company’s behalf and to implement and maintain reasonable security measures to protect the confidentiality, integrity, and availability of any Personal Information.
3.4. The Company may share Personal Information on an aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help the improvement of products and services.
3.6. Some parts of the Website may contain links, ads, or connection to third-party websites over which the Company has no control. If the Users follow a link to any of these websites or submit information to them, any Personal Information will be governed by their policies. We encourage the User to review the privacy policies of third-party websites before submitting any information to them.
3.7. The Company may share any Personal Information with government and law enforcement officials to comply with applicable laws or regulations arising from any applicable jurisdiction, even if different from that of the User or the Company.
4. Information Storage
4.1. All Personal Information provided by the User is stored on the Company’s servers or on a third-parties server to which only the Company has access to within the boundaries of relevant laws and regulations.
4.2. The Company only retains Personal Information for so long as it is reasonably necessary to fulfill the purposes they were collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
5.2 The term “cookie”, as used herein, shall be deemed to be a small piece of information that a website assigns to your device while you are viewing a website. Cookies are beneficial and may be used for various purposes. including allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother.
5.3 The Company’s website shall use the following types of cookies:
● (a) Strictly Necessary Cookies: These cookies are essential to enable you to log in, navigate a website, and use its features or to provide a service requested by you. The Company shall not need to obtain your consent in order to use these cookies.
● (b) Functionality Cookies: These cookies allow the Website to remember choices you make (such as your username, language, or the region you reside in) and provide enhanced, more personal features. The information these cookies collect remains anonymous, and they cannot track your browsing activity on other websites.
● (c) Performance cookies: These cookies collect information about how you use a website, for example, which pages you go to most often, record difficulties you may experience while using the Website such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the Website.
● (d) Targeting Cookies or Advertising Cookies: These cookies are used to deliver advertisements tailored to you and your interests specifically. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. It may be the case that targeting or advertising cookies shall be linked to the sites functionality provided by the other organizations.
5.4 You may remove these cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of the Company’s Services may not operate properly, and your online experience may be limited.
6. International Transfer of Information
6.1. The Company collects any Personal Information globally and transfers, processes, and stores any Personal Information outside the User’s country of residence where the Company’s or any third-party service providers operate for the purpose of providing the products and services.
6.2. Some of the Countries in which the Company or third-party service providers are operating from or are located in may not have the privacy and data protection laws that are equivalent to those in the User’s country of residence. When Personal Information is shared with these companies or third-party service providers, use is made of contractual clauses, corporate rules, and other appropriate mechanisms to safeguard the transfer of any Personal Information, within reason.
7. User’s rights
7.1. The User has the following right to:
● 7.1.1. be informed of what the Company does with the relevant Personal Information;
● 7.1.2. request a copy of relevant Personal Information the Company holds;
● 7.1.3. require the Company to correct any inaccuracy or error in any Personal Information held;
● 7.1.4. request erasure of any relevant Personal Information, except the one held for record-keeping purposes, to complete transactions, or to comply with legal obligations);
● 7.1.5. object to or restrict the processing of any relevant Personal Information (including for marketing purposes);
● 7.1.6. request to receive some of the relevant Personal Information in a structured, commonly used, and machine-readable format, and request that it is transferred to another party; and
● 7.1.7. withdraw consent at any time where the Company is relying on consent to process the relevant Personal Information (although this will not affect the lawfulness of any processing carried out before such consent withdrawal).
7.2. The Platform and the App enable Users to update certain information about themselves.
7.3. The User may opt-out of receiving marketing materials from the Company by expressly contacting it. However, the User will continue to receive notifications or information that are necessary for the use of the Company’s products or services.
7.4. As a security measure, the Company may need specific information from the User to help confirm his/her identity when processing any privacy requests or when you exercise the rights stated in this Clause.
7.5. Any request under paragraph 6.1 will normally be addressed free of charge. However, the Company may charge a reasonable administration fee if the request is clearly unfounded, repetitive, or excessive.
7.6. The Company will respond to all legitimate requests approximately within one (1) month. Occasionally, it may take longer than one (1) month if the request is particularly complex or if the users have made a number of requests.
8. Policy Changes
9.1. The Company’s products and services are not directed or intended for individuals not major of age in their Country of residence. The Company does not knowingly collect any personal information from individuals not major of age and if this will be detected, steps will be taken to delete such information.
10. European Union Users – GDPR
10.2. The Legal Bases for collecting and using any relevant Personal Information if the User is a citizen or resident of the EU, will depend on the Personal Information concerned and the specific context in which it is collected:
● Performance of a contract. The use of any relevant Personal Information may be necessary to perform the terms and conditions or other policies under which we operate the Website.
● Consent. The User consent is needed if technical information such as cookie data and geolocation data is necessary, and any relevant Personal Information is used for marketing purposes. The User may withdraw his/her consent at any time by contacting the Company directly.
● Legitimate interests. The Company may use any Personal Information for its legitimate interests to improve its Website, for security purposes, and fraud prevention, and to share information with any affiliates for internal administration. In such circumstances, the Company ensures that these interests are not overridden by the User’s data protection interests or fundamental rights and freedoms.
10.3.Legal Bases Table
To enable the User to access any products and services
To administer and maintain the safety and security of the Website
To study the usage of any products or services
To gather feedback on any products, services, or features
Type of data processed
Account Data, Transaction Data, Support Data, Technical Data
Transaction Data, Support Data, Technical Data, Usage Data
Contract performance User Content
Legitimate interest to improve the website
Legitimate interest to improve the website
10.4. Rights under EU law:
If the User’s relevant Personal Information is subject to the protections offered by EU law, he/she may:
● Access, correct, update or request deletion of any relevant Personal Information, at any time by contacting the Company using the contact details provided on the Website (in accordance with applicable data protection laws), provided that the Company may charge a reasonable fee for any manifestly unfounded, excessive or repetitive requests;
● Object to the processing of any relevant Personal Information, ask the Company to restrict processing of any relevant Personal Information or request portability of any relevant Personal Information for the legitimate interests set out above. In certain circumstances, the Company may not be able to stop using the Personal Information, with motivated cause.
● Withdraw consent at any time if the Company collected and processed any relevant Personal Information with consent;
● Opt-out of any marketing communications that the Company (or any third party to whom the Company disclosed the Personal Information with consent) may send;
● Complain to a data protection authority about the Company’s collection and use of any relevant Personal Information.
These rights apply only to Users who are subject to EU law.
10.5. The Company is the Data Controller in relation to its Website and is responsible for any relevant Personal Information, save for what pertains to other third-party service providers connected. The User may contact the Company through its Website if he/she has any concerns about this Policy and any relevant Personal Information.
11. Law and Jurisdiction
11.1. To the extent permitted by applicable law, this Policy and any disputes or claims arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims) are governed by and construed in accordance with the laws of the Liberia applicable to non-resident domestic companies. You irrevocably agree that the Courts of Liberia shall have exclusive jurisdiction to settle any dispute or claim that
arises out of this Policy