Privacy Policy
Effective Date: September 28, 2021.
Last Modified: March 13, 2024.
This privacy notice for WHERE tech Oy (doing business as Rello) ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
- Visit our website ahttps://rello.world/, or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
This Privacy Policy covers personal information that we collect from individuals representing veterinary clinics and veterinarians (“you” or our “client”) through the registration or use of our software application (the “App”) or our website (the “Website”) (collectively, our “Services” or “Rello”) or in other interactions with you.
This Policy does not apply to the collection, storage and other processing of personal information, or any information related to, or gathered in the process of, the treatment of animals that is collected and processed by Rello on your behalf. Any information that we collect on a client’s behalf is subject to the privacy policies of those clients, which we do not control.
By providing us with your information and agreeing to this Privacy Policy, you acknowledge and agree that have read and understand this Policy and the information collection, use, and disclosure practices described herein. If you do not agree with our Policy, please do not provide us with your information. If you have questions or complaints regarding our Privacy Policy or these practices, please contact our privacy officer whose contacts details are in the ‘Contact Information’ section below.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at avasiliukha@gmail.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights?
The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what we do with any information we collect? Review the privacy notice in full.
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights?
The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what we do with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. We also collect information automatically when you use Rello, which may or may not be personal information.
Personal Information Provided by You.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
All personal information that you provide to us must be true, complete, and accurate,
and you must notify us of any changes to such personal information.
Personal information you disclose to us
In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. We also collect information automatically when you use Rello, which may or may not be personal information.
Personal Information Provided by You.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- email addresses
- last names
- telephone numbers
- titles
- address of work offices
All personal information that you provide to us must be true, complete, and accurate,
and you must notify us of any changes to such personal information.
You will also be asked to create a password to access your account. All billing information will be collected and processed by our third-party payment processor.
Information Collected Automatically
When you download, access, and use the App or access our Website, we will use technology to automatically collect:
- Usage Details. When you access and use Rello, we may automatically collect certain details of your access to and use of Rello, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through our Services.
- Device Information. We collect information about your device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
When you use the Website or the App, the following additional information will be collected automatically:
- We use so-called “cookies,” web beacons, and other similar tracking technologies, including from third-party partners such as Google, to be able to better target advertisements and for marketing purposes.
- These technologies allow us the ability to display our promotional material to you when you visit external sites.
We may share information related to your access and engagement on our Website with certain third parties (including third-party websites or social networking platforms) for the purposes of providing you with better targeted advertisements.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your personal information for a variety of reasons, depending on
how you interact with our Services, including:
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your personal information for a variety of reasons, depending on
how you interact with our Services, including:
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm
- To provide you with Rello and its contents, and any other information, products or services that you request from us.
- To assist you to administer your relationship with your customer and their animal.
- If you choose to opt in to our mailing list, we may send you, from time to time, promotional information we think will be of interest to you. You will have the opportunity to opt out of those communications at any time following the instructions in the communication or by contacting us indicating your wishes avasiliukha@gmail.com
The usage and device information we automatically collect helps us to improve our Services and to deliver a better experience by enabling us to:
- Estimate our audience size and usage patterns.
- Recognize when Rello is used and which features are accessed.
We collect this information on an aggregated basis only and will not be linked with your personal information.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary
and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like
with your consent, to comply with laws, to provide you with services to enter into or
fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate
business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain
the valid legal bases we rely on in order to process your personal information. As
such, we may rely on the following legal bases to process your personal information:
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e.,
express consent) to use your personal information for a specific purpose, or in
situations where your permission can be inferred (i.e., implied consent). You
can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to
process your information without your consent, including, for example:
In Short: We only process your personal information when we believe it is necessary
and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like
with your consent, to comply with laws, to provide you with services to enter into or
fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate
business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain
the valid legal bases we rely on in order to process your personal information. As
such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e.,
express consent) to use your personal information for a specific purpose, or in
situations where your permission can be inferred (i.e., implied consent). You
can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to
process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way For investigations and fraud detection and prevention For business transactions, provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section
and/or with the following third parties. We may need to share your personal information in the following situations:
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if this is not
possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from
any further processing until deletion is possible.
In Short: We may share information in specific situations described in this section
and/or with the following third parties. We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- To contractors, service providers, third-party processors, and other third parties we use to deliver the Services.
- As may be required by law or as legitimately requested by law enforcement or pursuant to a legal obligation, in which case we will use reasonable efforts to provide notice to you.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if this is not
possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from
any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational
security measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information. Although
we will do our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should only access the
Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 or that you are the parent
or guardian of such a minor and consent to such minor dependent’s use of the
Services. If we learn that personal information from users less than 18 years of age
has been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at
avasiliukha@gmail.com.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational
security measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information. Although
we will do our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should only access the
Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 or that you are the parent
or guardian of such a minor and consent to such minor dependent’s use of the
Services. If we learn that personal information from users less than 18 years of age
has been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at
avasiliukha@gmail.com.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United
Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater
access to and control over your personal information. You may review, change, or
terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain
rights under applicable data protection laws. These may include the right (i) to
request access and obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of your personal information; (vi)
if applicable, to data portability; and (vii) not to be subject to automated decisionmaking.
In certain circumstances, you may also have the right to object to the
processing of your personal information. You can make such a request by contacting
us by using the contact details provided in the section "HOW CAN YOU CONTACT
US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data
protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to your Member State
data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your
personal information, which may be express and/or implied consent depending on
the applicable law, you have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the contact details
provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
Below.
However, please note that this will not affect the lawfulness of the processing before
its withdrawal nor, when applicable law allows, will it affect the processing of your
personal information conducted in reliance on lawful processing grounds other than
consent.
Opting out of marketing and promotional communications: You can unsubscribe
from our marketing and promotional communications at any time by clicking on the
unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to
the SMS messages that we send, or by contacting us using the details provided in
the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will
then be removed from the marketing lists. However, we may still communicate with
you — for example, to send you service-related messages that are necessary for the
administration and use of your account, to respond to service requests, or for other
non-marketing purposes.
If you have questions or comments about your privacy rights, you may email us at
avasiliukha@gmail.com.
In Short: In some regions, such as the European Economic Area (EEA), United
Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater
access to and control over your personal information. You may review, change, or
terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain
rights under applicable data protection laws. These may include the right (i) to
request access and obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of your personal information; (vi)
if applicable, to data portability; and (vii) not to be subject to automated decisionmaking.
In certain circumstances, you may also have the right to object to the
processing of your personal information. You can make such a request by contacting
us by using the contact details provided in the section "HOW CAN YOU CONTACT
US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data
protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to your Member State
data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your
personal information, which may be express and/or implied consent depending on
the applicable law, you have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the contact details
provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
Below.
However, please note that this will not affect the lawfulness of the processing before
its withdrawal nor, when applicable law allows, will it affect the processing of your
personal information conducted in reliance on lawful processing grounds other than
consent.
Opting out of marketing and promotional communications: You can unsubscribe
from our marketing and promotional communications at any time by clicking on the
unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to
the SMS messages that we send, or by contacting us using the details provided in
the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will
then be removed from the marketing lists. However, we may still communicate with
you — for example, to send you service-related messages that are necessary for the
administration and use of your account, to respond to service requests, or for other
non-marketing purposes.
If you have questions or comments about your privacy rights, you may email us at
avasiliukha@gmail.com.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ("DNT") feature or setting you can activate to signal your
privacy preference not to have data about your online browsing activities monitored
and collected. At this stage no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not currently respond
to DNT browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Virginia, Colorado or Connecticut, you
are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve
(12) months:
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ("DNT") feature or setting you can activate to signal your
privacy preference not to have data about your online browsing activities monitored
and collected. At this stage no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not currently respond
to DNT browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Virginia, Colorado or Connecticut, you
are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve
(12) months:
We will use and retain the collected personal information as needed to provide the
Services or for:
Category B - As long as the user has an account with us
We may also collect other personal information outside of these categories through
instances where you interact with us in person, online, or by phone or mail in the
context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, "HOW DO WE
PROCESS YOUR INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a
written contract between us and each service provider. Learn more about how we
disclose personal information to in the section, "WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration. This
is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. We will not sell
or share personal information in the future belonging to website visitors, users, and
other consumers.
California Residents
California Civil Code Section 1798.83, also known as the "Shine The Light" law
permits our users who are California residents to request and obtain from us, once a
year and free of charge, information about categories of personal information (if any)
we disclosed to third parties for direct marketing purposes and the names and
addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using the contact
information provided below.
If you are under 18 years of age, reside in California, and have a registered account
with the Services, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact us
using the contact information provided below and include the email address
associated with your account and a statement that you reside in California. We will
make sure the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all our
systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer
Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a "residents" as:
(1) every individual who is in the State of California for other than a temporary or
transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and
obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal
information, subject to certain exceptions provided by law, such as (but not limited to)
the exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation, or any processing that may be
required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a
business purpose;
the categories of third parties to whom the personal information was sold,
shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal
information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or to reidentify
individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are
the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we can match it
with information you have previously provided us. For instance, depending on the
type of request you submit, we may ask you to provide certain information so that we
can match the information you provide with the information we already have on file,
or we may contact you through a communication method (e.g., phone or email) that
you have previously provided to us. We may also use other verification methods as
the circumstances dictate.
We will only use personal information provided in your request to verify your identity
or authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. However, if we cannot
verify your identity from the information already maintained by us, we may request
that you provide additional information for the purposes of verifying your identity and
for security or fraud-prevention purposes. We will delete such additionally provided
information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on
your behalf. We may deny a request from an authorized agent that does not
submit proof that they have been validly authorized to act on your behalf in
accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal
information to third parties. Upon receiving an opt-out request, we will act upon
the request as soon as feasibly possible, but no later than fifteen (15) days
from the date of the request submission.
To exercise these rights, you can contact us by submitting a data subject access
request, by email at avasiliukha@gmail.com, or by referring to the contact details at
the bottom of this document. If you have a complaint about how we handle your data,
we would like to hear from you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act
(CPA), you have the rights listed below. However, these rights are not absolute, and
in certain cases we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects ("profiling")
To submit a request to exercise these rights described above, please email
avasiliukha@gmail.com or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our
decision, please email us at avasiliukha@gmail.com. Within forty-five (45) days of
receipt of an appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the
decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data
Privacy Act (CTDPA), you have the rights listed below. However, these rights are not
absolute, and in certain cases we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects ("profiling")
To submit a request to exercise these rights described above, please email
avasiliukha@gmail.com or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our
decision, please email us at avasiliukha@gmail.com. Within sixty (60) days of receipt
of an appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the
decisions.
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting
only in an individual or household context. It does not include a natural person acting
in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an
identified or identifiable natural person. "Personal data" does not include de-identified
data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary
consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and
obligations regarding your personal data.
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects ("profiling")
Exercise your rights provided under the Virginia VCDPA
You may contact us by email at avasiliukha@gmail.com or submit a data subject
access request.
If you are using an authorized agent to exercise your rights, we may deny a request if
the authorized agent does not submit proof that they have been validly authorized to
act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to
verify you and your consumer's request. If you submit the request through an
authorized agent, we may need to collect additional information to verify your identity
before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases,
within forty-five (45) days of receipt. The response period may be extended once by
forty-five (45) additional days when reasonably necessary. We will inform you of any
such extension within the initial 45-day response period, together with the reason for
the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision
and reasoning behind it. If you wish to appeal our decision, please email us at
avasiliukha@gmail.com. Within sixty (60) days of receipt of an appeal, we will inform
you in writing of any action taken or not taken in response to the appeal, including a
written explanation of the reasons for the decisions. If your appeal is denied, you may
contact the Attorney General to submit a complaint.
Services or for:
Category B - As long as the user has an account with us
We may also collect other personal information outside of these categories through
instances where you interact with us in person, online, or by phone or mail in the
context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, "HOW DO WE
PROCESS YOUR INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a
written contract between us and each service provider. Learn more about how we
disclose personal information to in the section, "WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration. This
is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. We will not sell
or share personal information in the future belonging to website visitors, users, and
other consumers.
California Residents
California Civil Code Section 1798.83, also known as the "Shine The Light" law
permits our users who are California residents to request and obtain from us, once a
year and free of charge, information about categories of personal information (if any)
we disclosed to third parties for direct marketing purposes and the names and
addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using the contact
information provided below.
If you are under 18 years of age, reside in California, and have a registered account
with the Services, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact us
using the contact information provided below and include the email address
associated with your account and a statement that you reside in California. We will
make sure the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all our
systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer
Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a "residents" as:
(1) every individual who is in the State of California for other than a temporary or
transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and
obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal
information, subject to certain exceptions provided by law, such as (but not limited to)
the exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation, or any processing that may be
required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a
business purpose;
the categories of third parties to whom the personal information was sold,
shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal
information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or to reidentify
individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are
the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we can match it
with information you have previously provided us. For instance, depending on the
type of request you submit, we may ask you to provide certain information so that we
can match the information you provide with the information we already have on file,
or we may contact you through a communication method (e.g., phone or email) that
you have previously provided to us. We may also use other verification methods as
the circumstances dictate.
We will only use personal information provided in your request to verify your identity
or authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. However, if we cannot
verify your identity from the information already maintained by us, we may request
that you provide additional information for the purposes of verifying your identity and
for security or fraud-prevention purposes. We will delete such additionally provided
information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on
your behalf. We may deny a request from an authorized agent that does not
submit proof that they have been validly authorized to act on your behalf in
accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal
information to third parties. Upon receiving an opt-out request, we will act upon
the request as soon as feasibly possible, but no later than fifteen (15) days
from the date of the request submission.
To exercise these rights, you can contact us by submitting a data subject access
request, by email at avasiliukha@gmail.com, or by referring to the contact details at
the bottom of this document. If you have a complaint about how we handle your data,
we would like to hear from you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act
(CPA), you have the rights listed below. However, these rights are not absolute, and
in certain cases we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects ("profiling")
To submit a request to exercise these rights described above, please email
avasiliukha@gmail.com or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our
decision, please email us at avasiliukha@gmail.com. Within forty-five (45) days of
receipt of an appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the
decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data
Privacy Act (CTDPA), you have the rights listed below. However, these rights are not
absolute, and in certain cases we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects ("profiling")
To submit a request to exercise these rights described above, please email
avasiliukha@gmail.com or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our
decision, please email us at avasiliukha@gmail.com. Within sixty (60) days of receipt
of an appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the
decisions.
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting
only in an individual or household context. It does not include a natural person acting
in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an
identified or identifiable natural person. "Personal data" does not include de-identified
data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary
consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and
obligations regarding your personal data.
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects ("profiling")
Exercise your rights provided under the Virginia VCDPA
You may contact us by email at avasiliukha@gmail.com or submit a data subject
access request.
If you are using an authorized agent to exercise your rights, we may deny a request if
the authorized agent does not submit proof that they have been validly authorized to
act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to
verify you and your consumer's request. If you submit the request through an
authorized agent, we may need to collect additional information to verify your identity
before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases,
within forty-five (45) days of receipt. The response period may be extended once by
forty-five (45) additional days when reasonably necessary. We will inform you of any
such extension within the initial 45-day response period, together with the reason for
the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision
and reasoning behind it. If you wish to appeal our decision, please email us at
avasiliukha@gmail.com. Within sixty (60) days of receipt of an appeal, we will inform
you in writing of any action taken or not taken in response to the appeal, including a
written explanation of the reasons for the decisions. If your appeal is denied, you may
contact the Attorney General to submit a complaint.
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Australia
We collect and process your personal information under the obligations and
conditions set by Australia's Privacy Act 1988 (Privacy Act).
This privacy notice satisfies the notice requirements defined in the Privacy Act, in
particular: what personal information we collect from you, from which sources, for
which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their
applicable purpose, it may affect our ability to provide our services, in particular:
offer you the products or services that you want
respond to or help with your requests
At any time, you have the right to request access to or correction of your personal
information. You can make such a request by contacting us by using the contact
details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE
THE DATA WE COLLECT FROM YOU?"
If you believe we are unlawfully processing your personal information, you have the
right to submit a complaint about a breach of the Australian Privacy Principles to the
Office of the Australian Information Commissioner.
In Short: You may have additional rights based on the country you reside in.
Australia
We collect and process your personal information under the obligations and
conditions set by Australia's Privacy Act 1988 (Privacy Act).
This privacy notice satisfies the notice requirements defined in the Privacy Act, in
particular: what personal information we collect from you, from which sources, for
which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their
applicable purpose, it may affect our ability to provide our services, in particular:
offer you the products or services that you want
respond to or help with your requests
At any time, you have the right to request access to or correction of your personal
information. You can make such a request by contacting us by using the contact
details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE
THE DATA WE COLLECT FROM YOU?"
If you believe we are unlawfully processing your personal information, you have the
right to submit a complaint about a breach of the Australian Privacy Principles to the
Office of the Australian Information Commissioner.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from time to time. The updated version will be
indicated by an updated "Revised" date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice frequently
to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
avasiliukha@gmail.com or contact us by post at:
WHERE tech Oy
Kalevalantie 8C 43
Espoo, Uusima 02100
Finland
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request
access to the personal information we collect from you, change that information, or
delete it. To request to review, update, or delete your personal information, please fill
out and submit a data subject access request.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from time to time. The updated version will be
indicated by an updated "Revised" date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice frequently
to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
avasiliukha@gmail.com or contact us by post at:
WHERE tech Oy
Kalevalantie 8C 43
Espoo, Uusima 02100
Finland
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request
access to the personal information we collect from you, change that information, or
delete it. To request to review, update, or delete your personal information, please fill
out and submit a data subject access request.