Privacy Policy

EFFECTIVE DATE18 May, 2022

RESPONSIBLE

Responsible for the collection, processing and use of your personal data within the meaning Canadian and US data protection laws (as well as GDPR) is – Kull Jet OU (Address: Ehitajate tee 114-11, 13517, Tallinn, Estonia), hereinafter – “Company”.

If you wish to object to the collection, processing or use of your data by us in accordance with these data protection regulations as a whole or for individual measures, you can address us your objection.

Also, you can save and print out this Privacy Policy at any time.

GENERAL CONDITIONS

Our Company (“We,” “Us,” and “Our”) profoundly cares about the safety of its Users (“Clients”, “Visitors”, “You,” and “Your”), as well as about the security of their private information. The Privacy Policy section here is destined to give You an overview of the information we need from you and about how it is protected from illegal use. We urge Our Clients to study the following Privacy Policy section before they pass to the cooperation with Us.

You accept the following information about the Privacy Policy, as well as the Terms and Conditions. If You need additional information about the Privacy Policy issues, find Our Company’s contact information on the Website and get in touch with one of Our online specialists.

All personal data is collected and processed in compliance with the applicable data protection regulations of Canada, the United States of America, as well as the General Data Protection Regulation (GDPR).

AGE LIMITATIONS

We have no official right to collect any private information from persons who are not 18 yet. It is strictly prohibited to the Users under 18 to use Our Website and any of the Services offered by Our Company. As soon as We find out that the information presented by the User is not eligible because of the age limits, it will promptly be erased. We bear no responsibility in case if You’re not old enough to use the Website. You must be of legal age to be in line with Our Privacy Policy, as well as with Our Terms and Conditions.

Alert Us in case one of Your children under 18 is using Our Website trying to get access to our services. We’ll take measures to block access to Our Website from Your IP address. All affiliate websites cooperating with Our Company will be blocked for your child as well.

INFORMATION WE COLLECT

We collect some personal information to enable you to use our Services. Depending on how you use our Services and which Services you use, different personal information may be collected. There are several ways in which we may collect personal information from you: you may provide it, or we will get it automatically through our Services and from third parties.

INFORMATION YOU PROVIDE

We collect and process the personal information You provide on the submission or contact forms.

Contact information: your Full name, email address and telephone number.

Information about yourself: age, gender, citizenship.

Preferences: e.g., language preference or interests.

The User is responsible for the legitimacy of the content.

INFORMATION WE COLLECT AUTOMATICALLY

We also collect and use personal data that You provide when using Our Services (including data collected by Cookies).

Browser information: browser type, language settings, country, and time zone.

Identity information: unique identifiers such as IDFA (for iOS), MAC address or UserID.

Network information: IP addresses and mobile network information.

Location data: data about your geographic location based on your IP address.

Cookie or web beacon information: Cookie IDs and settings and other personal data collected through cookies, web beacons, or pixel tags.

Device information: your device type, hardware model, and operating system.

Service usage: information about how you interact with our Services, websites.

PAYMENT DETAILS

We reserve the right to keep the billing information, but We don’t have complete access to the numbers of Your credit cards. Our Privacy Policy implies that we can store the following information about our Clients’ payment details:

• Billing address;
• IP address.

These are basic payment details necessary for the cooperation with most online shops and services. Accept that Our Website can partially collect Your payment details and technical data. Our Clients provide most of the information intentionally.

Our Website may also collect information and statistics about the way You use our payment system and other technical aspects. This information is only collected in the impersonated form and used for further analysis to enhance Your experience and make it more beneficial for You.

PERSONAL INFORMATION USE AND DISCLOSURE

We do not use Your personal information for any other purposes except for the ones mentioned in this Privacy Policy section. We also never share Your data with third-party companies or people. This is considered illegal, and We have no rights to enforce the rules that do not correspond with the legislation of the state.

All Users of Our Website will have access to Your personal information posted by You in Your account. No one will be able to make changes in it except for You. Our Support Team can also access your personal information to verify your age, as well as the legacy of Your activity on Our Website.

We rely on Your personal information to provide you with the marketing information and special offers depending on your preferences.

We partially scan your data with the analytics tools and advertising services to find out about the effectiveness of Our work and the functionality of Our Website. We do this to improve our Customer Service and not to identify Our Clients personally.

We can use Your geographical location to help Our marketing and advertising partners post relevant advertisements on Our Website that will correspond with Your place of residence and Your needs.

We use Your contact information only for communication with Our Support Team. We will never share Your contact information with anyone who can use it for marketing or promotion purposes.

PERSONAL INFORMATION PROTECTION

We use HTTPS/TLS encryption to protect the personal information of Our Users. This technology guarantees 100% protection of Your data so that it will never be stolen or transferred anywhere without your permission.
All payments and transactions performed through Our Website are secure because of the additional encryption and enhanced gateway. Remember that We are not responsible for the breaches of security caused by Your irresponsible actions or Our service suppliers.

STORAGE TIME

We only store personal data for as long as is necessary to fulfil the purposes pursued. In some cases, the legislator provides for the storage of personal data, for example in tax or commercial law. In these cases, the data will only be stored by Us for these legal purposes but will not be processed in any other way and deleted after expiry of the legal retention period.

COOKIES

You can block, disable or delete cookies at any time by changing the settings in your browser. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages of our site or other sites.  You can find more information about cookies and other options you may have for restricting them at www.cookiesandyou.com/ and www.aboutads.info/choices.

Your browser may offer a Do Not Track (DNT) setting.  If you turn that setting on, your browser sends a signal to websites indicating that you don’t want to be tracked over time or across third party sites.  We don’t currently respond to these signals because there is not yet a common understanding of how to process them or a consensus on what “tracking” means.

GOOGLE-ANALYTICS

We use Google Analytics, a web analysis service of Google Inc. “(“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about the use of this website by page visitors is usually transferred to a Google server in the USA and stored there.

The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, note that if you do this you may not be able to use the full functionality of this website.

You can also prevent the transmission to Google of data generated by the cookie and relating to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing the browser plug-in.

VISITORS BEHAVIOR PATTERNS

We study the behavior patterns of Our Users and track the number of people in different parts of the Website. We do not identify the Users in any way, and this process is performed to analyze Our work and the work of the Website elements.

PRIVACY POLICY POSSIBLE CHANGES

We reserve the right to change the Privacy Policy section and add more information to it. We are not obliged to notify the Users about the changes applied to the current Privacy Policy. It means that the Users are to check this section for themselves to find out more about the way their personal information is protected.

YOUR RIGHTS AS A DATA SUBJECT

According to the applicable laws, you have various rights regarding your personal data. If you wish to assert these rights, please send your request by e-mail or by post to the address specified in the section on the bottom of this Policy, clearly identifying yourself.

Right to acknowledgement and access

You have the right to receive confirmation from Us at any time as to whether personal data relating to you will be processed. If this is the case, you have the right to request from us free of charge information about the personal data stored about you together with a copy of this data.

If personal data are transferred to a third country or an international organization, you have the right to be informed of the appropriate guarantees in accordance with GDPR and US data protection laws in connection with the transfer.

Right to correction

You have the right to request Us to correct any inaccurate personal data concerning you without delay.

Right for cancellation (“Right for oblivion”)

As a pursuant under GDPR and US data protection laws, you have the right to demand that we delete personal data concerning you without delay, and we are obliged to delete personal data without delay if one of the following reasons applies:

1. personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
2. you file an objection to the processing pursuant to GDPR and US data protection laws, and there are no overriding legitimate grounds for the processing, or you file an objection to the processing pursuant under conditions of GDPR and US data protection laws.
3. you withdraw your consent, on which the processing was based pursuant according to GDPR and US data protection laws, and there is no other legal basis for the processing.
4. the deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which we are subject.

Right to limitation of processing

You have the right to request Us to restrict processing if one of the following conditions is met:

1. you dispute the accuracy of your personal data for a period of time that enables us to verify the accuracy of your personal data;
2. the processing is unlawful, and you have refused to delete the personal data and have instead requested the restriction of the use of the personal data;
3. We no longer need the personal data for the purposes of processing, but you do need the data to assert, exercise or defend legal claims, or
4. you have filed an objection against the processing pursuant according to GDPR and US data protection laws, as long as it is not yet clear whether the justified reasons of our company outweigh yours.

Right to Transferability of Data

You have the right to receive the personal data concerning you that you have provided to us in a structured, current and machine-readable format, and you have the right to transmit this data to another person in charge without our interference, provided that

1. processing is based on consent or on a contract pursuant according to conditions of GDPR and US data protection laws and
2. processing is carried out using automated methods. When exercising your right to data transferability in accordance with paragraph 1, you have the right to request that the personal data be transferred directly by us to another person responsible, insofar as this is technically feasible.

Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you on the basis of GDPR and US data protection laws; this also applies to profiling based on these provisions. We no longer process personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If We process personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising.

You have the right to object to the processing of personal data concerning you, for scientific or historical research purposes or for statistical purposes in accordance with GDPR and US data protection laws, for reasons arising from your particular situation, unless the processing is necessary to fulfill a task in the public interest.

Automated decisions including profiling

You have the right not to be subject to a decision based exclusively on automated processing – including profiling – that has legal effect against you or significantly impairs you in a similar manner. An automated decision making based on the collected personal data does not take place.

Right to revoke consent under data protection law

You have the right to revoke your consent to the processing of personal data at any time.

Right of appeal to a supervisory authority

You have the right of appeal to a supervisory authority.

In particular, if you have US residentship, in the Member State where you are staying, working or suspected of having infringed the law, if you believe that the processing is unlawful.

Or, if you have EU/EEA residentship, and have a concern about our practices concerning the processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside or in which you work, or in which the alleged infringement occurred, each as applicable, or by contacting the authority for such issues, at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

NOTICE TO INDIVIDUALS IN THE STATE OF CALIFORNIA (USA)

Your Rights to Your Personal Information

California residents have the right to request that We (i) provide you with access to the Personal Information that we hold about you, (ii) correct your Personal Information, (iii) delete your Personal Information, and (iv) cease or restrict disclosures or sales of your Personal Information to third parties. You also have a right against discrimination for exercising any of these rights, which We are committed to upholding and honoring at all times.

Categories of Data that We Hold about You

As mentioned above, We maintain data about you in only pseudonymized form, which means that we do not know your identity because we do not process your name, email address, or other identifiable information. Instead, we only process digital identifiers such as cookie IDs, IP addresses, mobile advertising IDs on your device, network browsing history and associated preferences, and in some limited circumstances, your hashed email address.

Why We Collect Your Personal Information.

We process your Personal Information in order to provide Services and personalized advertisements to You.

Where do We Collect Your Personal Information

We automatically collect User Information when Users interact with our Services that appear on our Customers’ websites and digital properties. Like most other web-based services, we collect this User Information through cookies and other technologies. We may also obtain Information about you from our data partners.

We collect Information either directly from you during your use of our Sites and Services or from third parties that independently collect this Information from you, and we may combine the Information that we collect from these various sources. For more information about these collection methods, please see Sections above.

How do We Share Your Personal Information

We may disclose or make available your pseudonymous Personal Information to our trusted partners. In most cases when we do so, we have contractually restricted their uses of this data for only Our business purposes. Under the CCPA, such disclosures of Personal Information to service providers are not deemed to be a “sale” and thus are not prohibited after you exercise your right to cease or restrict disclosures or sales of your Personal Information to third parties. In any instances where we have not entered into a service provider relationship with such third parties, we will stop sharing your Personal Information when you instruct us not to “sell” your Personal Information.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

According to CalOPPA we agree to the following:

• Users can visit our site anonymously;
• Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website;
• Our Privacy Policy link includes the word ‘Privacy’, and can be easily found on the page specified above.

Users will be notified of any privacy policy changes on our Privacy Policy Page.

Users are able to change their personal information by emailing us.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.We do not specifically market to children under 13.

Fair Information Practices

• The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
• In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur
• We will notify the users via in site notification
• Within 7 business days

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions;
• Process orders and to send information and updates pertaining to orders;
• We may also send you additional information related to your product and/or service.

To be in accordance with CAN SPAM ACT we agree to the following:

• NOT use false, or misleading subjects or email addresses;
• Identify the message as an advertisement in some reasonable way;
• Include the physical address of our business or site headquarters;
• Monitor third party email marketing services for compliance, if one is used;
• Honor opt-out/unsubscribe requests quickly;
• Allow users to unsubscribe by using the link at the bottom of each email.

NOTICE TO THE CITIZENS OF CANADA

Data subjects with a residentship in Canada  have the following rights under the Privacy Act:

The right to access information – the right to both:

confirmation as to whether (or not) an agency holds information about that person; and access to such personal information, where such personal information may be readily retrieved.

The right to correction of information – the right to request correction of information. The agency must, on request or of its own initiative, take steps that are reasonable in the circumstances to ensure (having regard to the purposes for which the information may lawfully be used), the information is accurate, up to date, and not misleading.

In addition to the access and correction rights you may be entitled to exercise the right to:

object to the processing of your personal data (for instance, where we base the processing on our legitimate interests and we will stop processing your data. Except for processing related to direct marketing, we may resume processing if we can show legitimate grounds that override your rights;

request the restriction of processing of your personal data (for instance, if the data is not accurate and needs to be updated). This can also be done for data where the purposes of processing no longer apply, but you still need the data and do not want us to erase it;

request erasure of your personal data (for instance, if it’s no longer necessary for the purposes for which it was collected, if you have withdrawn consent or there is no other legal basis for processing, or if you have objected to the processing and our legitimate interests do not override your rights). Certain data may not be erased if we have a requirement to retain it for legal purposes;

request portability of your own personal data (the transfer of information you have provided to us, to another controller, in a structured, commonly used and machine-readable format), if such a request is technically possible to complete.

Also, according to Canadian legislation and specifically under both the Privacy Act (R.S.C., 1985, c. P-21) and the Personal Information Protection and Electronic Documents Act (PIPEDA) (S.C. 2000, c. 5, Assented to 2000-04-13), We collect personal information as defined by section 3 of the Privacy Act.

CONTACT US

Click here to contact us regarding this Privacy Notice or other related Privacy issues. You can also write to us as follows:

In the Estonia by registered mail:

Kull Jet OU

Address: Ehitajate tee 114-11,

13517, Tallinn, Estonia

or send us an email on: [email protected].