Privacy policy

This Privacy Policy governs your use of www.getrelatio.com (the “Website”) and describes the data we collect, how it is stored, how that data may be used, with whom it may be shared, and your choices about such uses and disclosures. Please be sure to carefully read the entirety of this Privacy Policy when using our Website.

“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, use, and disclose to others.

Check Relatio Terms of Use&Service (the “Terms”) for the meaning of defined words (those with capital letters) not explicitly defined in this Privacy Policy.

1. PERSONAL DATA CONTROLLER

Brora Corp, having its registered address at 3500 South Dupont Highway, Dover, DE 19901, County of Kent, USA will be the controller of your personal data

2. WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?

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 Website (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 Website, for example, when you create a user profile (“Profile”), respond to our emails, or report a problem. The data that you give us includes:

Profile data. This includes your email address and password.

By providing Profile data you agree and understand that you are this data will be publicly available. Please do not provide personal data to your Profile that you would not want to be publicly available.

2.2. Data we collect automatically:

Data about how you found us. We collect data about your referring URL (that is, the place on the Web where you were when you tapped on our ad).

Cookies and other similar technologies. As further described in our Cookie Policy, our Website use cookies that record data about the use of our website to distinguish you from other users. You can control cookies through your browser settings.

Browser and Device data. We collect data from or about the devices from which you access the Website, depending on the permissions you’ve granted. We may associate the data we collect from your different devices, which helps us provide consistent Services across your devices Examples of such data include: language settings, IP address, location, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

We also collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

Transaction data. When you make payments through the Website, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data and data about the transaction, including: date, time and amount of the transaction, and the type of payment method used.

Usage data. We record how you interact with our Website. For example, we log the features, and content you interact with, how often and long you use the Website, what sections you use, and other interactions.

3. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data:

3.1. To provide services to you.

This includes enabling you to use the Website in a seamless manner and preventing or addressing Website errors or technical issues. For example, we use your data to authenticate you and authorize access to our Website.

3.2. To research and analyze your use of the Website

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Website and our new products. We conduct surveys, research, and test features in development. We analyze the data we have to evaluate our Website, and conduct audits and troubleshooting activities to improve our Website content and layouts. As a consequence, we often decide how to improve the Website based on the results obtained from this processing. For example, if we discover that users do not often use certain section of the Website, we may focus on improving this section.

3.3. To customize the Website 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 Website. 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 Website .

3.5. To enforce the Terms and to prevent, detect, investigate, and resolve disputes and/or remediate malicious activities, fraud, other cybercrimes, take legally-required actions, or make sure you are a real person and avoid the creation of fake accounts.

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with the Terms).

3.6. To communicate with you regarding your use of our Website

We may communicate with you, for example, by email or directly on the Website, including through push notifications. As a result of such processing, we may send you messages about your statistics.

3.7. 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 Website, 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 clicking here: unsubscribe

3.8. To provide you customer service and support

As a result of such processing, we will send you messages about the availability of our Website security, payment transactions, status of your orders, legal notices, or other Website-related information.

3.9. 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.

3.10. 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.

4. LEGAL BASIS FOR DATA PROCESSING (EEA ONLY)

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 grounds:

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. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Website more often. We also take into account the potential benefits to you.

Our legitimate interest for this purpose is our interest in improving our Website so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website 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 Website in a measured and appropriate way.

The legitimate interest we rely on for this processing is our interest to promote our Website in a reasonably targeted way.

Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Website, non-compliance with the Terms.

4.4. to comply with legal obligations. Under this legal basis we, in particular, verify your identity.

5. CALIFORNIA PRIVACY RIGHTS

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.

For more details about the personal information we have collected, including the categories of sources, please see Section 3 above. We collect this information for purposes described in Section 4 this Privacy Policy. We may also share your information with certain categories of third parties as indicated in Section 10. We do not sell (as such term is defined in the CCPA) the personal information we collect.

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 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

We will retain personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

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. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

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

We may use and disclose personal data to enforce the Terms, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

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.

8. INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Website set forth in the Terms and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

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).

9. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy at any time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Website after those changes become effective, you agree to be bound by the revised Privacy Policy.

10. AGE LIMITATION

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].

11. PRIVACY RIGHTS

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 Website. You may also request a copy of your personal data collected during your use of the Website 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.

12. HOW DO WE HANDLE “DO NOT TRACK” REQUESTS?

Except as otherwise stipulated in this Privacy Policy, the Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

13. CONTACT US

If you have any questions or concerns about this Privacy Policy or our collection, use, or storage or your data, please do not hesitate to contact us at:

E-mail: [email protected].