GDPR Policy
UTRRR.com’s commitment to GDPR
The GDPR (General
Data Protection Regulation) is an important piece of legislation that is
designed to strengthen and unify data protection laws for all individuals
within the European Union.
If your company
needs to ensure it is GDPR-compliant, it also needs to ensure its providers
(i.e. UTRRR.com) are also GDPR compliant. UTRRR.com is GDPR-compliant, and
strictly enforces the regulation as to protect the user data we store.
Last updated: March
13, 2022
Types of Data collected
If you are a
Visitor, User or Business Partner, we may collect one or both of the following
types of data from you when you use or access our website, the Services or when
you interact with the Technology, as applicable.
The first type of
data is aggregated, non-personal, non-identifiable information pertaining to
your use of the website or interaction with the Technology (“Non-personal Data
“). We are not aware of the identity of the individual from which the
Non-personal Data is collected. Non-Personal Data may include your aggregated
usage information and technical information transmitted by your device,
including certain software and hardware information about your device (e.g.,
the device you use, the type of browser and operating system your device uses,
language preferences, access times and the website’s domain name from which you
accessed the Services, etc.), in order to enhance the functionality of the
Services and for security and functionality purposes.
The second type of
information is individually identifiable information, namely information that
identifies an individual or may with reasonable effort identify an individual
(“Personal Data“).
For the avoidance
of doubt, if we combine Personal Data with Non-personal Data, the combined data
will be treated as Personal Data as long as the data types remain combined. We
act as a Processor of a User's Personal Data that we process on behalf of our
Business Partners. We are considered to be the Controller of the Personal Data
we collect from our Business Partners and Visitors.
The types of data
that we collect as well as our reasons for processing such data are specified
in the tables below:
Data We Collect from Business Partners and Visitors
|
Type of Data |
How do we Use it |
|
Data Provided Voluntarily: If you voluntarily contact us
in any manner, whether via our contact form on our website, request a demo,
via email, etc., you may be asked to provide us with your contact information
such as your full name and email address as well as your Company name and job
title. |
We will use this data solely for
the purpose of responding to your inquiries and to provide you with the
support or information you requested. We will retain our correspondence with
you for as long as we find necessary, subject to applicable law. |
|
Business Partner’s Registration: If you wish to partner with
us and integrate the Technology within your Digital Assets you will be
requested to register and create an account. During the registration you will
be requested to provide your contact details such as your name, email
address, phone number and company name. You may also provide us with your
email address through registration or other means of communications if you
choose to download our Technology through third parties' plugin or app
marketplace. |
We will use this data to provide
the Services and designate your account. Your contact details will be used in
order to send you needed information related to our Services and our business
engagement (e.g., send you a welcome message, notify you regarding any
updates to our Services, send inquiries regarding your use of our Technology
and Services for example where we detect you have failed to complete the
download or otherwise reached the offered cap, send applicable invoices, etc.)
and additional occasional communications and updates related to the Services,
as well as provide you with tips related to our Services, and promotional and
marketing emails. We may also use the information in order to verify your
identity, including by sending you a text message for password verification
purposes. We use a third-party payment processor to process the payments in
consideration for our Services. We will not obtain your payment details other
than as needed for validation purposes (e.g., 4 digits, BIN, expiry date).
The processing of your payment details will be subject to the applicable
third-party processor's policies. |
|
Newsletter & Marketing List
Subscription: If you voluntarily subscribe to our newsletter through our
website, or otherwise agree to receive our updates and content, you may be
requested to provide us with your contact information such as your name,
email address and company name. You can unsubscribe at any time using the
unsubscribe option within the body of the applicable email correspondence or
by contacting us directly. |
We use this data solely in order to
provide you with the content that you requested to receive. The Company uses Tawk.to
and Sendinblue for its email marketing services. Please review their privacy
policies here: |
|
IP and Technical Data: When you access our website
or interact with our Services, we may collect certain online identifiers
(e.g. your IP address) as well as technical Non-Personal Data (e.g. the type
of operating system, type of browser, device type, access time and date,
directing URL and your approximate geographical location). |
We use this data for our legitimate
interests of: (i) operating, providing, maintaining, protecting, managing,
customizing and improving our website and the way in which we offer it; (ii)
enhancing your experience; (iii) auditing and tracking usage statistics and
traffic flow; and (iv) protecting the security of our website. We will obtain
your consent, if we are required to do so in accordance with applicable law
when we use third party cookies on our website. |
Data We Collect from Users:
|
Type of Data |
Purpose of Processing |
|
Online Identifiers & Technical
Usage Personal Data: The Company may collect information regarding a User's
interaction with the Services. Such information may include Online
Identifiers such as the User's IP address, Advertising ID and IDFA. We may
also assign a unique ID to your browser. The Company may also collect technical
Data, such as, the type of operating system used, the type of browser, device
type, access time and date, certain browsing data (e.g. directing URL) and
the User's approximate geographical location. |
We use this data for (i) operating,
providing, maintaining, protecting, managing, customizing and improving our
Services and the way in which we offer them as well as. In some cases, to
provide Users with personalized Ads; (ii) enhancing your experience; and
(iii) auditing and tracking usage statistics and traffic flow as well as
calculating payments related to the Services, we provide to Business
Partners. Where required under applicable law, we will require our Business
Partner to obtain your consent to collect such data and share it with us.
Note that, we use Google Ad Manager to operate our advertising campaigns.
Google may use and retain certain types of data subject to its policies.
Additional information can be found here. |
How UTRRR.com collects Data
Depending on the
nature of your interaction with the website or the Services, the above
mentioned data may be collected as follows:
- Voluntarily – In the event you choose to provide us with information,
e.g., when you contact us or if you are a Business Partner and you choose
to share other information with us via your use of the Services.
- Automatically – Your data may be collected automatically
including via cookies (as explained below) and other similar tracking
technologies. We will ask for your consent to collect Personal Data and
offer you the choice to opt-out of such collection if we are required to
do so in accordance with applicable law.
Who do we disclose Information to?
We do not share
your Personal Data with third parties except as specifically mentioned herein:
- Third Party service providers – we may disclose your Personal Data to
third parties that perform services on our behalf (e.g. tracking, servers,
service functionality and support, marketing, etc.). These entities may be
located in a different jurisdiction than you and are prohibited from using
your Personal Data for any purposes other than providing us with the
requested services;
Our third parties
help us use your personal information, as described above, and include:
|
Third-Party |
Privacy Policy and Opt-Out |
|
Wasabi |
https://wasabi.com/legal/privacy-policy/ |
|
Google Cloud |
|
|
Google Analytics |
|
|
Hotjar |
|
|
Mailgun |
|
|
Sendinblue |
|
|
Tawk |
https://www.tawk.to/privacy-policy/ |
|
Stripe |
|
|
Amazon Web Services |
|
|
Google |
|
|
IBM |
|
|
Microsoft Azure |
|
|
|
|
|
Government third parties, including
government agencies, regulatory bodies and law enforcement agencies as
required, authorized or permitted by law |
- Third Party Rights – we may share your Personal Data,
solely to the extent needed to prevent harm to the rights (including
intellectual property rights and other legal rights), property or safety
of us, our Visitors, Business Partners and their Users, yourself or any
other third party.
- Policy Enforcement – we may share your Personal Data,
solely to the extent needed in order to enforce our policies including
investigations of potential violations thereof, to establish or exercise
our rights to defend against legal claims or to detect, prevent, or take
action regarding illegal activities or other wrongdoing, suspected fraud
or security issues;
- Legal Requirement – we may disclose or share your Personal
Data, solely to the extent needed to comply with any applicable law,
regulation, legal process or governmental request (i.e., to comply with a
court injunction, etc.) or for the purpose of collaborating with law
enforcement agencies; or
- Affiliated Companies and Corporate
Transaction –
we may share your Personal Data with a parent company, subsidiaries, joint
ventures, or other companies under common control with the Company
("Affiliated Companies") solely if and when applicable or
necessary. In addition, we may share information, in the event of a
corporate transaction (e.g. sale, merger, consolidation, etc.), provided
however, that our Affiliated Companies or acquiring company will be
subject to the obligations detailed herein with respect to your Personal
Data.
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