WHO ARE WE?
The data controller of your Personal Data collected via our Internet Products according to Art. 4(7) GDPR is REMOBY LTD (a company incorporated in Cyprus, company registration no. HE419638) and its registered office is at: 28 Oktovriou, 367, Mediterranean Court, 1st Floor, Office A5, 3107, Limassol, Cyprus (“Journey” or “we”).
HOW IS DATA COLLECTED ABOUT ME AND HOW IS IT USED?
Which Personal Data we Collect
Personal Data any information that identifies you or can be used to identify or contact you (“Personal Data”).
How we Collect and Use Your Personal Data
- Using Our Internet Products
When you choose to use our Internet Products we start to gather information which also contains Personal Data. In addition, we collect data provided directly to us through the personal assistant (chat-bot): responses to special Internet Products including surveys, questionnaires, etc.Purpose for processing
: We utilize data we collect in order to personalize our Internet Products, such as customizing our pricing and to increasing efficiency of our solutions and recommendations selected personally for you. Furthermore, we collect information automatically including Personal Data when you browse our Website or use our Internet Products, such as your, browser type, IP address, error logs operating system, and various other similar information. Aggregated information such as this does not allow us to identify you and is used by us to administer the Website, analyze trends, monitor our Website’s use, and to gather general information about the use of our Website. The legal basis for such processing of your Personal Data are our legitimate interests (Art. 6(1)(f) GDPR) in customizing the content of our services in line with user preferences and in further improving our Internet Products. It is important to note that you are not legally required to provide us with your Personal Data. However, without it we will not be able to provide you with the complete range of our Internet Products.
Should you contact our customer service, we will communicate with you in response to your inquiries, manage your subscription, and to provide the services you request,. We will communicate with you by email, in accordance with your preferences.Purpose for processing
: The legal basis for processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Such processing of your Personal Data is necessary for the performance of our services. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you customer service-related communications.
HOW LONG AND WHERE WE STORE YOUR PERSONAL DATA
Your Personal Data and other information is stored by us for as long as necessary to enable you to use our Website and our Internet Products and to provide our services to you whilst complying with the applicable laws (including those regarding document retention), to resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. Please contact us at the contact details mentioned below if you have a question about a specific retention period for certain types of Personal Data we process about you
Your Personal Data is stored on the secure server at https://cloud.google.com/
The servers is located in the USA.
HOW WE DISCLOSE AND SHARE PERSONAL DATA
We will not sell, share, transfer or otherwise disseminate your Personal Data to third parties, unless required by law according to Art. 6(1)(c) GDPR, unless required for the purpose of your contract according to Art. 6(1)(b) GDPR, unless the third party acts as a data processor on our behalf according to Art. 28 GDPR or you have given us express consent to do so according to Art. 6(1)(a) GDPR.
Some your Personal Data is shared with third-party service providers to facilitate or offer services on our behalf and share your Personal Data with such providers to the extent necessary for such providers to perform their services on our behalf. We use the following service providers:
- Tilda Publishing Ltd
- Google Inc.
We use their following services (Storage of your Personal Data, Analytical services):https://cloud.google.com/https://tilda.cc/
We contracted to the service providers via purchase of their services and via accepting their customers terms and conditions and privacy policies published on their websites:https://policies.google.com/privacy?hl=en-UShttps://tilda.cc/privacy/
We share your Personal Data with, as described above companies which are located outside of the European Economic Area. In particular, Tilda is located in the EU and Google is located in the USA.
Regarding the matter of transferring (importing/exporting) and the processing of personal data falling within the scope of GDPR, Google relies on the EU model (standard) contractual clauses; and Amplitude relies on the EU-US and Swiss-US Privacy Shield.
In order to grant sufficient protection of your Personal Data in this context,
According to Art. 6(1)(c) GDPR. We may also be required to disclose your Personal Data to law enforcement officials or government officials in response to a lawful request by a public authority or if we have to do so to comply with a legal obligation, including to meet law enforcement or national security requirements We can also disclose your information in order to pursue our legitimate interest in applying or enforcing our Terms and Conditions or in responding to any claims, in protecting our rights or the rights of a third party, in protecting the safety of any person or in preventing any illegal activity (including for the purposes of fraud protection and credit risk reduction) according to Art. 6(1)(f) GDPR. If required under applicable data protection laws, we will obtain your prior consent before sharing your Personal Data with other companies. In such cases, the legal basis is Art. 6(1)(a) GDPR.
IS MY PERSONAL DATA USED FOR ANY OTHER PURPOSES?
WHAT ARE MY RIGHTS?
You have the following rights:
- To require access to your personal data (Art. 15 GDPR);
- To require the rectification of your personal data (Art. 16 GDPR);
- To require the erasure of your personal data (Art. 17 GDPR);
- To require the restriction of your personal data processing (Art. 18 GDPR);
- To require the portability of your personal data (Art. 20 GDPR);
- To object to the processing of your personal data (Art. 21 GDPR);
- To object to automated processing (if any) of your personal data (Art. 22 GDPR);
- To withdraw your consent to processing of your personal data, where applicable (Art. 7(3) GDPR);
- To Lodge a complaint with your national supervisory authority (in the EEA) if you believe that your privacy rights have been violated.
You can assert your rights mentioned above by contacting us at the contact details mentioned below.Your consent and your right to withdraw your consent
We will provide you with appropriate information at the point where you come across additional purposes in order to obtain your consent Should we choose to process your personal data for any purpose you do not agree with, (when required) or are able to perform our legal obligations, before commencing any such additional processing activities. Just because We ask for it you are not required to give consent
You can further change your mind and withdraw your consent at a later date by contacting us using the contact details mentioned below if your personal data were processed on the basis of your consent. However, your consent withdrawal will not impact the processing of your personal data which took place before your withdrawal.Objecting to data processing (your rights)
You can also ask Us to stop processing your personal data and to remove you from the mailing list, by contacting us using the contact details mentioned below. If your personal data was processed without your given consent (based on the legitimate interest). However, your request will not impact the processing of your personal data which took place before such a request was made.
If you request Us to rectify, erase your personal data or to restrict processing your data (to stop processing or by withdrawing your consent), We will inform you as soon as your request is satisfied.Lodging a complaint (Your rights)
If your question is not resolved satisfactorily or simply not resolved, you have the right to contact your local data protection authority. You can find the contact details of your local data protection authority below: https://edpb.europa.eu/about-edpb/board/members_en
AUTOMATED INDIVIDUAL DECISION-MAKING
Decisions with legal or similar effects are not made using your Personal Data they are based on the automated processing of your Personal Data only.
WHAT IF I HAVE ANY PRIVACY QUESTIONS? WHO DO I CONTACT?
Effective Date: August 8, 2022