This Privacy & Cookie Policy outlines how EDINET  and its affiliated entities (referred to as “EDINET,” “we,” “us,” or “our” as applicable) manage personal information collected through our digital platforms connected to this Privacy & Cookie Policy. These platforms encompass our websites collectively referred to as the “Service.” Additionally, it covers the collection of personal information through social media, our marketing efforts, and other activities detailed within this Privacy and Cookie Policy.

Gathering and Maintenance of Personal Information

Data You Share with Us: Personal information you may share with us via the Service or by other means can consist of:

Contact Information
This includes your contact details such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.

User Profile Data
Within this category, you’ll find information like the username and password used for your Service account, biographical details, date of birth, photographs, links to your social media profiles, interests, preferences, your involvement in our contests, promotions, or surveys, and any additional data you include in your account profile.

Correspondence Record
This encompasses all communication exchanged between us, whether it occurs when you contact us through the Service, social media platforms, or any other means.

Demographic Details
This entails information related to your demographics, such as your city, state/county, country of residence, postal code, gender, and age.

Marketing Preferences
This section encompasses information related to your marketing preferences, including your choices regarding how you wish to receive our marketing communications and insights into your interactions with these communications.

Transaction Records
This category pertains to data relevant to your transactions, including but not limited to order numbers, transaction history, and any information required to process your orders on or through the Service.

Government-Issued Identification Data
This pertains to government-issued identification numbers, including but not limited to national identification numbers (such as tax identification, social security number, file number, and passport number), as well as state or local identification numbers (like driver’s license or state ID number). It also includes images of the corresponding identification card.

User-Generated Content
This category encompasses content that you create, transmit, or make accessible on the Service, which includes photos, images, videos, audio recordings, comments, questions, messages, profile pictures, and other content. Additionally, it includes associated data, which involves details on when, where, and by whom the content was collected, as well as any formatting or editing applied to the content. This data also encompasses information that users can append to their content, like keywords, geographical or location data, and similar details.

Payment Details
This encompasses the information required to facilitate transactions, which may include payment card details or bank account numbers.

Participation in Promotions
This pertains to the information you provide when entering competitions, promotions, or surveys. It’s essential to note that when participating in sweepstakes, contests, or giveaways through the Service, we may request your Contact Data for notification purposes, identity verification, and prize distribution. Occasionally, additional information, such as prize selection preferences, may be necessary during the entry process. Participation in these sweepstakes and contests is entirely voluntary, and we advise you to review the rules and pertinent details for each event you enter.

Additional Information
Data that has not been explicitly detailed herein will be employed as outlined in this Privacy and Cookie Policy or as disclosed during the data collection process.

Data from External Sources: We may gather the categories of personal information detailed earlier from the subsequent third-party sources and blend this data with the personal information you furnish to us:

External Data Providers
This incorporates data suppliers like information service providers and data licensors who furnish demographic and other details. Additionally, it includes credit bureaus, which aid in fraud detection and the provision of specific credit-related services. This data may encompass information pertaining to your credit history.

Information from Publicly Accessible Sources
This covers data obtained from publicly accessible sources, including government agencies, public records, social media platforms, and other openly accessible sources.

Collaborative Marketing Associates
This includes marketing collaborators, such as partners engaged in joint marketing efforts and co-sponsors of events.

Affiliate Collaborators
This refers to our affiliate associates, encompassing our affiliate network provider and individuals such as publishers, influencers, and promoters involved in our compensated affiliate programs.

External Service Providers
This refers to services provided by third parties, including:

• Social media services that you utilize to log in to, or connect with, your Service account. This information may encompass your username, profile picture, and other data related to your account on that third-party service, which is accessible to us based on your account preferences on that platform. The specific information received will be contingent on your privacy settings on the respective platform.
• Logistics service providers who aid us in optimizing our delivery services. This data may consist of details related to your delivery address information.
  
  

Automated Data Gathering: We, along with our service providers and business associates, may automatically record data pertaining to you, your computer or mobile device, and your ongoing interaction with the Service, our communications, and other online services. This may encompass:

Geographical Information
This covers location-related information, including your general location data, such as your IP address, and, subject to your consent, the precise location data from your mobile device. Please be aware that, for the majority of mobile devices, you can control or deactivate the utilization of precise location services for all applications via your mobile device’s settings menu.

Internet Activity Information
This encompasses data related to your online activity, which includes the pages or screens you perused, the duration of time spent on a page or screen, the website you visited before arriving at the Service, the routes taken between pages or screens, details about your actions on a page or screen, the times when you accessed the Service and how long you accessed it, as well as whether you opened our emails or interacted with the links within them.

Device Information
This encompasses details related to your device, including the operating system type and version, manufacturer, and model of your computer or mobile device. It also includes browser type, screen resolution, RAM and disk size, CPU usage, device category (e.g., phone or tablet), IP address, distinctive identifiers (inclusive of those utilized for advertising purposes), language configurations, mobile device carrier, radio/network specifics (e.g., Wi-Fi, LTE, 3G), and general location data, such as city, state, or geographic area. We also gather service-related, diagnostic, and performance information, which includes crash reports and performance logs.

Cookies and Comparable Technologies: Certain aspects of the automatic data collection mentioned earlier are facilitated through the utilization of the following technologies:

Local Storage Technologies
We employ local storage technologies, such as HTML5, which offer functionality akin to cookies but can store more extensive data on your device independently of your browser, in association with specific applications.

Cookies and Their Functions
Cookies, which are compact text files stored by websites on user devices, enable web servers to track users’ online browsing actions and retain their inputs, preferences, and login status while they navigate a website or application. The cookies employed on our sites encompass various types:

“Session cookies” are removed once a session concludes.
“Persistent cookies” have a more extended duration.
“First-party cookies” are set by us.
“Third-party cookies” are set by our third-party business associates and service providers.

Pixel Tags
These pixel tags serve the purpose of indicating that a webpage or email was accessed or opened, or that specific content within them was viewed or interacted with.

Utilization and Disclosure of Your Personal Data

We will solely employ and divulge your personal information in compliance with applicable legal provisions and the objectives for which it was initially collected, except if we reasonably determine that there is a necessity to utilize it for a purpose that is connected to the original intent. In cases where we must utilize or reveal your personal data for an unrelated purpose, we will notify you and provide an explanation of the legal basis that permits us to do so. We retain the right to utilize or disclose your personal data in the following manners:

1. With Your Consent: When you have provided your consent for us to do so.
2. Contractual Obligations: When it is necessary to fulfill our obligations under a contract with you.
3. Legal and Regulatory Compliance: To comply with legal or regulatory requirements.
4. Legal Rights and Proceedings: To establish, exercise, or defend our legal rights or for the purpose of legal proceedings.
5. Legitimate Business Interests: When it is essential for our legitimate business interests (or those of our affiliate), which may include:
   • Providing our website or services to you.
   • Furnishing information about new products or services.
   • Pursuing any of the purposes detailed below.
   •  

We may gather, retain, utilize, and disclose your personal information for the subsequent objectives:

• Delivery of Services: We may acquire, retain, employ, and reveal your personal data to:
  • We may collect, store, utilize, and reveal your personal information to assist in sending invitations to friends whom you wish to invite to join the Service.
  • We may gather, maintain, employ, and reveal your personal information to activate security features of the Service, including tasks such as sending security codes through email or SMS and recalling devices from which you have previously logged in.
  • We may collect, retain, utilize, and disclose your personal information to create and sustain your user profile on the Service.
  • We may acquire, retain, employ, and reveal your personal data to offer, manage, and enhance the Service and our overall business operations.
  • We may collect, hold, utilize, and disclose your personal information to engage in communication with you regarding the Service. This includes sending notifications, updates, security notifications, and providing support and administrative messages.
  • We may gather, retain, utilize, and disclose your personal information to offer support for the Service and address your requests, inquiries, and feedback.
  • We may acquire, retain, employ, and disclose your personal information to prevent, identify, investigate, and respond to instances of fraud, unauthorized access or usage of the Service, violations of terms and policies, or any other inappropriate or unlawful activities.
  • We may collect, maintain, utilize, and reveal your personal information to administer sweepstakes, contests, and other promotional activities. Additionally, we may utilize your user profile picture and name information to identify you in these promotions and activities.
  • We may gather, hold, utilize, and disclose your personal information to comprehend your requirements and interests. This helps us personalize your interactions with the Service and our communications. This personalization may include the identification and suggestion of products that may appeal to you or the presentation of features that are accessible in your specific location.

• Marketing and Advertising: We, in collaboration with our service providers and third-party advertising associates, may acquire, maintain, utilize, and reveal your personal information for marketing and advertising objectives, including:
  
  • Interest-Driven Advertising
    Our third-party advertising affiliates may employ cookies and comparable technologies to gather data about your engagement with the Service, our communications, and other online services over time. They utilize this information to deliver online advertisements that align with your preferences, a practice known as interest-based advertising. Furthermore, we may collaborate with these firms by sharing information about our users, which helps in executing interest-based advertising campaigns targeting those users or individuals with comparable interests on alternative online platforms. For further information on how you can restrict interest-based advertising, please refer to the “Your choices” section below.
  • Direct Marketing
    We may forward direct marketing communications to you. If you wish to cease receiving our marketing communications, you can choose to opt-out, as outlined in the “Opt-out of Marketing Communications” section below.
• Compliance and protection: We may collect, hold, use and disclose your personal information to:
  
  • We may collect, hold, utilize, and disclose your personal information to adhere to relevant laws, lawful requests, and legal proceedings, including responding to subpoenas or requests from government authorities.
  • We may acquire, retain, utilize, and disclose your personal information to carry out audits of our internal procedures to ensure compliance with legal and contractual obligations or our internal policies.
  • We may gather, maintain, utilize, and disclose your personal information to safeguard the rights, privacy, safety, or property of ourselves, you, or others. This includes actions such as initiating and defending legal claims.
  • We may collect, retain, employ, and reveal your personal information to prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activities, including incidents such as cyberattacks and identity theft.
  • We may gather, hold, utilize, and disclose your personal information to enforce the terms and conditions that oversee the Service.

• With Your Agreement: In specific situations, we may explicitly seek your consent to gather, retain, utilize, or reveal your personal information, especially when mandated by law.
• Cookies and Comparable Technologies: In addition to the other purposes outlined in this section, we may employ cookies and similar technologies, as previously described, for the subsequent objectives:
  
  • Analytics and Marketing Cookies: We utilize cookies and comparable technologies to facilitate the promotion of our services on various platforms and websites and to gauge the efficacy of our own marketing initiatives. Our advertising associates may gather your personal data to construct a profile of your interests, allowing them to display pertinent advertisements on other websites.
  • Preference Cookies: These cookies are designed to recollect your preferences, such as your language or location, to enhance your shopping experience and tailor it to your needs, making it as smooth and personalized as possible.
  • Essential Cookies: These cookies are essential for the proper functioning of our site and the provision of our services and features. They also enable us to evaluate and analyze how our customers utilize the site, enhancing both its functionality and your shopping experience.
    
    

Sharing Your Personal Data

We do not exchange your personal information for monetary compensation, and we solely disclose your personal information to the subsequent parties, as outlined in this Privacy & Cookie Policy or as indicated during the data collection process.

• Service Providers
  We may share your personal information with third-party service providers who assist us in delivering services, operating the Service, or managing our business. These services encompass hosting, information technology, customer support, email delivery, order fulfillment and delivery, marketing, consumer research, and website analytics.
  
  
• Affiliate Entities
  We may disclose your personal information to our corporate parent, subsidiaries, and affiliated companies for purposes consistent with this Privacy & Cookie Policy
  
  
• Third Parties at Your Direction
  We may reveal your personal data to third parties when you have explicitly directed us or given your consent for such sharing. For instance, we may share your personal information with third-party advertisers with whom we have partnerships to provide you with additional services like sweepstakes, raffles, and promotions. We will only disclose the personal information necessary for these other companies to furnish the services you have requested.
  
  
• Advertising Associates
  We may share your personal information with third-party advertising firms for the interest-based advertising aims as previously described.
  
  
• Payment Processors
  Your payment card information used for purchases on the Service is collected and processed directly by our payment processors.
  
  
• Linked Third-Party Services
  If you log into the Service using or connect your Service account to a social media or other third-party service, we may distribute your personal information to that third-party service. The manner in which the shared information is employed by the third party will be subject to its privacy policy and the configurations linked to your account with the third-party service.
  
  
• Business and Marketing Collaborators
  We may share your personal information with third parties with whom we co-sponsor events or promotions, with whom we jointly provide products or services, or whose products or services may be of interest to you.
  
  
• Authorities and Other Entities
  We may disclose your personal information to law enforcement, government authorities, and private entities when we believe, in good faith, that it is necessary or suitable for compliance and protection purposes as described earlier.
  
  
• Professional Advisers
  We may share your personal information with professional advisors, including lawyers, auditors, bankers, and insurers, as required in the provision of professional services they offer to us.
  
  
• Business Transfers
  We may disclose your personal information to acquirers and other relevant parties involved in business transactions or negotiations concerning corporate divestitures, mergers, consolidations, acquisitions, reorganizations, sales, or other dispositions of all or part of the business or assets of EDINET or our affiliates. This includes situations related to bankruptcy or similar proceedings.
  
  
• Sellers, Other Users, and the General Public
  
  We may distribute your personal information to sellers to facilitate your transactions conducted on or through the Service. For instance, when you make a purchase on or through the Service, we typically share necessary personal information, such as your shipping address and phone number, with the seller or their service providers.
  
  We may also reveal your personal information to other users and sellers to facilitate your interactions with them on or through the Service. For example, information about a seller’s store is typically made accessible to users.
  
  Your profile and other user-generated content (excluding messages) may be visible to other Service users and the general public. This encompasses details like your name, photograph, location, reviews you’ve composed (including any photos or videos uploaded with those reviews), and the list of individuals you follow or those who follow you, as well as your username when you send messages, comment, or upload images or videos through the Service. This information can be accessed, collected, and employed by others, including caching, copying, screen capturing, or storing by other parties (e.g., search engines). Please exercise caution and sound judgment before sharing personal information in public areas of the Service.
  
  

Your Rights and Options

Data Subject Rights:
You possess rights concerning the personal information we retain about you. Depending on your place of residence or location, these rights may encompass:

• The right to obtain information about the processing of your personal data and access to the personal data we hold about you.
• The right to request that we rectify your personal data if it is inaccurate or incomplete.
• The right to withdraw your consent to our processing of your personal data at any time (please note, however, that we may still be entitled to process your personal data if we have another legitimate reason other than consent for doing so).
• The right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. However, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data, but we are legally entitled to continue processing your personal data and/or to refuse that request.
• The right to request that we erase your personal data in certain circumstances (though please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it).
• The right to request that we provide you with some personal data in a structured, commonly used, and machine-readable format, and/or request that we transmit those data to a third party where this is technically feasible (though please note that this right only applies to personal data which you have provided to us).
• The right to lodge a complaint with your data protection authority or with us in writing if you believe that we have breached any of our obligations or infringed your rights under applicable privacy law.

To exercise your rights, please reach out to us through the contact information provided in the “How to contact us” section below. We will promptly address your complaints in writing. Upon request, we will furnish information about your relevant data protection authority.

Accessing and Updating Your Information:
If you have registered for an account via the Service, you have the option to review, update, or delete specific account details by logging into your account. Specifically, you can modify your:

Name
Address
Phone number
Email address
Password
Payment methods
Profile information
Purchase history
You can do this within the “my account” section of the website.

Opting Out of Marketing Communications
To manage your preferences or opt-out of marketing communications, you can utilize any of the following methods:

• Email Promotional Offers: If you wish to stop receiving emails from us regarding special promotions or offers, you can simply click on the unsubscribe options located at the bottom of each email.

• Mobile Promotional Offers: When you provide us with your mobile number, we may send you marketing alerts via text message. Standard data and message rates will apply. If you no longer wish to receive mobile marketing alerts, you can follow the instructions provided in those messages or reply STOP to any alert we send.

• Push Notifications: If you use the mobile app and would rather not receive push notifications, you have the option to adjust your settings on your mobile device to control whether you want to receive these alerts.

Cookies and Similar Technologies

• Managing Cookies: You can typically remove or decline cookies through your browser settings. Refer to your browser’s instructions on how to do this. Keep in mind that many browsers accept cookies by default until you modify your settings. Please be aware that if you disable cookies in your browser, the Service may not function correctly.

• Additional Information on Cookies: For further insights into cookies, including instructions on how to view the cookies set in your browser and how to manage or delete them, you can visit www.allaboutcookies.org.

• Preventing Web Beacons: You also have the option to configure your device to prevent images from loading, which can help prevent web beacons from functioning.

Mobile location data.
You can disable our access to your device’s precise geolocation in your mobile device settings.

Limiting Interest-Based Advertising

You can restrict the use of your information for interest-based advertising through the following methods:

• Browser Settings: You can block third-party cookies within your browser settings.

• Privacy Browsers/Plug-ins: Utilize privacy browsers or ad-blocking browser plug-ins that enable you to block tracking technologies.

• Mobile Device Settings: You can also control interest-based advertising by adjusting your mobile device settings to limit the use of the advertising ID linked to your mobile device for such purposes.

• Platform Settings: Explore the settings available on the platform you are using to further manage interest-based advertising preferences.

Please note that you must apply these opt-out settings individually on each device from which you wish to opt out.

• “Do Not Track” Signals: Certain internet browsers may be set up to send “Do Not Track” signals to the online services you access. However, it’s important to note that we presently do not respond to “Do Not Track” or similar signals.

Declining to Provide Information

To offer specific services, we may need to gather personal information. If you opt not to provide the information we identify as necessary or mandatory, we may be unable to furnish those services.

Linked Third-Party Platforms

If you decide to link to the Service using your social media account or another third-party platform, you might have the option to control the information we receive from it by adjusting your settings within your account on that platform. It’s important to note that if you revoke our access to information from a third-party platform, this decision will not affect the information we have already obtained from that third party.

Deleting Content or Closing Your Account

You have the right to delete specific content through your account, and you can also have the right to ask for account closure by contacting us via email message.

Retention

We retain personal information only for as long as it is necessary to fulfill the purposes for which we initially collected it. This includes meeting any legal, accounting, or reporting obligations, as well as establishing or defending legal claims and preventing fraud. The specific duration of retention varies depending on the type of personal information, the reasons for processing it, and any legal obligations we must adhere to.

In determining the appropriate retention period for personal information, we take into account factors such as the quantity, nature, and sensitivity of the personal information, the potential risks associated with unauthorized use or disclosure, the purposes for processing the information and whether those purposes can be achieved by other means, and relevant legal requirements.

Once we no longer need the personal information we’ve collected from you, we may choose to delete it, anonymize it, or, if technical constraints make deletion or anonymization impractical, we will isolate it to prevent further processing or render it “beyond use.”

Other Websites and Services

The Service might include links to websites, mobile applications, and other online services that are operated by third parties. Additionally, our content may be incorporated into web pages or other online services that are not under our control. These links and integrations should not be interpreted as an endorsement or indication of our affiliation with any third party. We have no authority over websites, mobile applications, or online services operated by third parties, and we do not assume responsibility for their activities. We urge you to review the privacy policies of any other websites, mobile applications, or online services that you utilize.

Security

We have implemented various technical, organizational, and physical measures to safeguard the personal information we gather. Nevertheless, it’s important to acknowledge that security risks are inherent in all internet and information technologies. Therefore, while we take steps to protect your personal information, we cannot provide an absolute guarantee of its security.

International Data Transfers

The personal information we collect from you may be transferred, disclosed, stored, and processed in locations outside your country, which may include regions where EDINET and its affiliates operate. When we transfer your personal data outside of your country, we will take measures to ensure that it is protected in a manner consistent with the level of protection your personal data would receive if processed within your country. This can be accomplished through various means, such as:

• The destination country may have received approval from the relevant data protection authority.
• We may employ appropriate data transfer mechanisms, such as adhering to contracts based on “model contractual clauses” sanctioned by regulatory bodies like the Information Commissioner’s Office or European Commission. These contracts obligate recipients to safeguard your personal data.
• In some instances, the law may authorize us to transfer your personal data outside your country using alternative methods. Regardless of the approach, we will guarantee that any transfer of your personal data complies with the applicable privacy and data protection regulations. For more details regarding the protection of your personal data when transferred outside your country, please contact us as outlined in the “How to contact us” section below.
  
  

Children

The Service is not designed for individuals under the age of 18. If you are a parent or guardian and believe that we have collected personal information from a child in violation of applicable laws, please reach out to us. In the event that we discover that we have collected personal information from a child through the Service without the necessary consent of the child’s parent or guardian, as mandated by law, we will take the appropriate steps to adhere to legal requirements, including deleting the information.

Changes to this Privacy & Cookie Policy

We retain the right to amend this Privacy & Cookie Policy whenever necessary. In the event of significant changes to this Privacy & Cookie Policy, we will inform you by updating the date of this Privacy & Cookie Policy and posting it on the Service or employing other suitable methods. The alterations to this Privacy & Cookie Policy will come into effect once we publish the revised version (or as otherwise stated at the time of publication). Regardless, your use of the Service following the effective date of any revised Privacy & Cookie Policy demonstrates your acceptance of the updated Privacy & Cookie Policy.

How to contact us

EDINET RESEARCH AND DEVELOPMENT
4 Michail Georgalla, Engomi 2409, Nicosia, Cyprus
info@edinetcy.com | +357 22270122