Privacy Policy

Last updated: Jun 11, 2018

Thanks for visiting Ivaja.com! Ivaja is a brand of Ivaja Ltd., hereinafter referred to as “Ivaja” or “we”. Note that any capitalized terms not defined in this Privacy Policy have the meanings set forth in our Terms of Service. If you don’t agree to the terms of this Privacy Policy, you may not access or use the Services. If you have any comments or questions about this Privacy Policy, feel free to contact us at contact@ivaja.io

 

OUR COMMITMENT TO PRIVACY

We are committed to safeguarding the privacy of our website visitors and service users. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in the other words, where we determine the purposes and means of the processing of that personal data.

Consent to use of cookies: We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website. 

Website privacy controls: Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via your website account.

Data controller name: In this policy, “we”, “us” and “our” refer to www.ivaja.io

 

HOW WE USE YOUR PERSONAL DATA

In this section we describe categories, purposes and legal bases of our data processing, namely:

  • The general categories of personal data that we may process;
  • In case of personal data that we did not obtain directly from you, the source and specific categories of that data;
  • The purposes for which we may process personal data; and
  • The legal bases of the processing.

Processing of usage data: We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of our service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of account data: We may process your account data (“account data”). The account data may include your name and email address. The source of the account is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of profile data: We may process your account data (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of operating our website, providing our services, and ensuring the security of our website and services. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of service data: We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include IP address, location, device type, session data, and if provided by you, name, email address, phone number, address, birth date, amongst other data. The source of the service data is you and your device. The service data may be processed for the purposes of operating our website, providing our services, and ensuring the security of our website and services. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of publication data: We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of enquiry data: We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of customer relationship data: We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of transaction data: We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”).The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of notification data: We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of correspondence data: We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record- keeping.The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing of other data: We may process personal data and data related to web analytics. This data may include name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of this data is your device, browser and what you voluntary provide. This data may be processed for business and performance and Hansen performances. The legal basis for this processing is your consent to our legitimate interests, namely the proper administration of our website and business.

Processing for legal claims: We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

Processing for risk management: We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

General purposes of processing personal data: In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interest of another natural person.

Disclosure of third party personal data: Please do not supply any other person`s personal data to us, unless we prompt you to do so.

 

PROVIDING YOUR PERSONAL DATA

Intra-group disclosures of personal data: We may disclose your personal data to any member of our group of companies (this means our subsidiaries, or ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at www.Ivaja.com.

Disclosure of personal data to insures etc: We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, maintaining risks, obtaining professional advice, or the establishment, exercise or defence of legal claims whether in court proceedings or in an administrative or out-of-court procedure.

Disclosures of personal data to subcontractors: We may disclose relevant personal data to our suppliers or subcontractors. Identified at www.Ivaja.io insofar as reasonably necessary for business purposes.

Disclosures of personal data to payment services providers: Financial transactions relating to our website and services are/may be Handled by our payment services providers, PayPal and Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers` privacy policies and practices at https://stripe.com/us/privacy/ and https://www.paypal.com/webapps/mpp/ua/privacy-full.

Disclosure of personal data to third party suppliers: We may disclose your enquiry data to one or more of those selected third party supplies of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy. Which will govern that third party’s use of your personal data.

Disclosure of personal data necessary for legal compliance etc: In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interest of another natural person . We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

PROVIDING YOUR PERSONAL DATA TO OTHERS

Intra-group disclosures of personal data: Intra-group disclosures of personal data: We may disclose your personal data to any member of our group of companies (this means our subsidiaries or ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at www.Ivaja.com.

Disclosure of personal data to insurers, etc.: We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, maintaining risks, obtaining professional advice, or the establishment, exercise or defense of legal claims whether in court proceedings or in an administrative or out-of-court procedure.

Disclosures of personal data to subcontractors: We may disclose relevant personal data to our suppliers or subcontractors. Identified at www.Ivaja.io insofar as reasonably necessary for business purposes.

Disclosures of personal data to payment services providers: Financial transactions relating to our website and services are/may be Handled by our payment services providers Stripe and Stunning. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers` privacy policies and practices at https://stripe.com/, https://www.paypal.com/.

Disclosure of personal data to third-party suppliers: We may disclose your enquiry data to one or more of those selected third-party supplies of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy. Which will govern that third party’s use of your personal data.

Disclosure of personal data necessary for legal compliance, etc.: In addition to the specific disclosures of personal data set out in this privacy policy, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interest of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

International transfers within the business: We and our other group companies have offices and facilities in Malta. The European Commision has made an “adequacy decision” with respect to the data protection laws of this country.

International transfers to hosting services provider: The hosting facilities for our website is situated in the United Kingdom. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country.

Publication of personal data on the internet: You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

 

RETAINING AND DELETING PERSONAL DATA

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation and deletion of personal data.

Personal data retention default rule: Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or purposes.

Personal data retention specific rules: We will retain your personal data only as long as necessary.

Personal data retention criteria: In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained.

Personal data deletion exception: Notwithstanding the other provisions of this privacy policy, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interest or the vital interests of another natural person.

 

AMENDMENTS

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may/will notify you of changes/significant changes to this policy by email or through the private messaging system on our website.