Privacy policy

Valid from 02.05.2019

Welcome to Veriff`s webpage. We are specialized in providing online identification services. We are the new standard in identity verification, and we allow any website or mobile application to verify your driver’s license, passport or ID.

In this Privacy Policy we explain how and on what basis we collect, store and Process Personal Data of Data Subjects i.e. our client’s representatives, Users, Visitors (see definitions below) and (potential) employees. We also explain what Data Subjects’ rights are and our obligations and liability.

Veriff mainly Processes Users’ information as directed by our clients (i.e. Merchants) for the provision of our service.  Our clients are the data controllers who determine the purpose of Processing of Personal Data and, accordingly, Veriff is a  processor of User information with respect to those services. In other cases, Veriff is a controller of User information (e.g. regards to visitors of Veriff’s web page) and may also Process certain Data Subjects’ information in anonymized form for the development and improvement of Veriff’s services and in other forms and purposes set forth in this Privacy Policy.  

In order to fully understand how Personal Data is Processed, Data Subjects should review privacy notices shared with the Users by Veriff and privacy policies of those Merchants’, for whose services, they are getting verified for.

Please review this policy carefully and contact us and our data protection officer at legal@veriff.com if you have any comments, questions or concerns.

What is included in this Privacy Policy?

1. Definitions

2. Our main privacy principles

3. The content of Personal Data we Process

4. The purposes and legal grounds for Processing your Personal Data

5. Data Subject’s rights in relation to Personal Data

6. Disclosure and transfer of Personal Data

7. Security of Personal Data

8. Retention of Personal Data

9. Cookies and other tracking technologies

10. Availability and changes of the Privacy Policy

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1.   Definitions

 

Here you can find the meanings of the most important terms in this Privacy Policy to help you understand who and for what we are Processing your Personal Data.

  • Agreement - service agreement concluded with the Merchant, i.e. our client.
  • Breach - breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed.
  • Cookie(s) - small pieces of information stored by the Visitor’s browser on the hard disk of the computer of any other device of the Visitor.
  • Data Subject / you –natural person about whom we have got information or data enabling to identify the natural person. Data Subjects are our client’s representatives (Merchant’s representatives), Users and Visitors. Veriff does not knowingly collect or maintain personally identifiable information on the web site or through its Services from persons under 16 years of age, except if a guardian of such child has consented to the Processing.
  • Data Providers – these are third party service providers or public authorities who we use to collect additional information for verification. For example, we may check the User provided info against official public registry.
  • DPIA – Data Processing Impact Assessment that is carried out regards to our services that may have significant effect on Data Subjects and especially regards to fully automated processes. DPIAs identify the risks to individuals, show how we are going to deal with them and what measures we have in place to meet GDPR requirements.
  • EEA - European Economic Area (the European Union Member States, Norway, Iceland and Liechtenstein).
  • GDPR - EU General Data Protection Regulation 2016/679.
  • Merchant - the legal entity to whom we provide the Service under the Agreement, i.e. our client.
  • Personal Data - any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • PEP – politically exposed person including their family members and close associates in accordance with the applicable legal acts regards to prevention of money laundering or terrorist financing (such as a natural person who is or who has been entrusted with prominent public functions, e.g member of parliament or of a similar legislative body, a member of a governing body of a political party, a member of a supreme court).
  • Privacy Policy - this privacy policy.
  • Processing - any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing may be done manually or using automated systems.
  • Processor/ our / us / we - Veriff OÜ, registry code 12932944, Niine 11, Tallinn, 10414, e-mail: info@veriff.com and our data protection officer legal@veriff.com.
  • Service - personal identity verification service provided by us.
  • User - the natural person regarding whom we provide the Service at the request of the Merchant and natural person who contacts us as the representative of Merchant prior to conclusion of the Agreement. 
  • Visitor - is any person using the Website of Veriff.
  • Websitewww.veriff.me.

2.    Our main privacy principles

 

We follow what we call “Fundamental-Six”, that is six principles regards to Veriff’s data Processing activities.

These are:

  • First, we Process Personal Data in a reliable and confidential way. We respect each person's right to the protection of their Personal Data and we shall do our best to ensure that Personal Data collected by us is well protected. We regularly evaluate the risks associated with the Processing of Personal Data and shall apply appropriate mitigation strategies to hedge risks.
  • Second, Data protection is an integral part of our Service. All our services are developed and deployed by enshrining the principles of privacy by design and privacy by default that is overseen by our data protection officer. Compliance with Privacy Policy is integrated into our day to day activities, services and processes, and our development efforts.
  • Third, we Process Personal Data lawfully and purposefully. We set clear goals for the Processing of Personal Data and Process Personal Data for these purposes only. We do not collect or Process the data that we do not need.
  • Fourth, we Process Personal Data in a transparent and fair way. We ourselves and our contractual partners are to be careful on Processing of Personal Data, to prevent the unauthorized disclosure or inappropriate use of Personal Data, and to Process Personal Data in an honest and lawful manner.
  • Fifth, we shall store Personal Data only for as long as the retention of data is required by law or contract or is necessary for the provision of our Service. In the end of retention period, we shall permanently erase the Personal Data or anonymize it.
  • Sixth, we have established internal rules for compliance with our Privacy Policy. We understand that compliance with the internal rules takes place through our employees. Therefore, we consider it important and we must ensure that our employees know and comply with the requirements of the internal rules. We expect, instruct and train each of our employees to respect our privacy requirements.

 

3.   The content of Personal Data we Process

 

Whether You are a representative of a Merchant, a User, a Visitor or our potential or actual Employee, in this chapter we provide you with all relevant information regards to what types and categories of data may be processed by Us.

 

3.1  Personal Data we Process about Users

We provide personal identity verification services to Merchants. This means we verify Users and for that you (i.e. the User), have consented to data Processing according to Merchant’s privacy policy and to data Processing by us in accordance with this Privacy Policy.

We may collect and Process, among other, the following Personal Data:

  1. personal information of User, such as name, sex, personal identification code, date of birth, legal capacity, nationality, citizenship, but also historic data of that User that may have been stored with us during previous counteractions within the retention periods;
  2. document details, such as the name of the document, issuing country, number, expiry date, security features;
  3. facial recognition data, such as photos, videos and sound recording, photographs taken from you and your document and video and sound recording of the verification process;
  4. contact details, such as address, e-mail address, telephone numbers, IP address;
  5. technical data (Device Signature)including but not limited to information about, the date and time that you use the Services, your IP address and domain name, your software and hardware attributes, also, your general geographic location (e.g. city, country); 
  6. biometrical data, such as facial identifiers;
  7. publicly available relevant data, e.g. information about being politically exposed person (PEP) and checks in public sanction lists.

We may obtain Personal Data directly from you, as well as from the Merchant. We also collect your Personal Data independently from Data Providers, e.g. to offer our services within the trust-based relationship and to prevent fraud. For example, if we need to verify validity of your identification document, we might inquire for additional information from the appropriate registrar. 

We may share your Personal Data, foremost the biometrical data and facial recognition data with the Merchant through which you used our identity verification service.

3.2  Personal Data we Process about the representative of the Merchant

For entering into Agreement, for providing our Service, for communicating with the representative of our client and for other lawful reasons we need to Process the data of Merchant’s representative.

This means we may Process, among other, following Personal Data of the representative of the Merchant:

1. personal information of the representative of the Merchant, such as name, job title, position, contact information;

2. personal information in connection of provision of the Service, such as data from communication with us;

3. technical data (Device Signature)including but not limited to information about, the date and time that you use the Services, your IP address and domain name, your software and hardware attributes, also, your general geographic location (e.g. city, country); 

4. publicly available relevant data.

We collect this data either from you directly, when you communicate with us directly e.g., sending us an email, providing us with your Personal Data on the phone or through our customer support tools. We may also collect some of your Personal Data in the course of provision of Service to your employer.

Please note that we also check information about Merchant (incl. about relevant representatives of Merchant) from publicly available sources. We only gather relevant and necessary data in order to validate right of representation.

Please note that when we ask you to provide your Personal Data, this provision of Personal Data is voluntary. However, if you do not provide your Personal Data the Merchant may not be able to make use of the full range of our Services.

3.3   Personal Data we Process about the Visitor of our Website

We may collect data regarding the Visitors of the Websites by using Cookies (see below Chapter 9) or other similar technologies (e.g. IP address, equipment information, location information, beacons) and Process the data gathered by them.

This data, among other, may be as follows:

1. personal information of the Visitor, such as IP address, time, location

2. information on usage of the Website and other web log data, such as the pages you visit on the Website, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Website,

3. technical data (Device Signature)including but not limited to information about your IP address and domain name, your software and hardware attributes (including device IDs), your general geographic location (e.g. city, country); We use the collected data to enable the provision of the Service in accordance with the habits of a Visitor; to ensure the best Service quality; to inform the Visitor about the contents and give recommendations; to update advertisements and make marketing efforts more efficient. The collected data shall also be used for counting the Visitors and recording their habits.

 

3.4   Personal Data we Process during recruitment process and employment

As an employee, we fully inform you of the Processing activities taken by Veriff and instruct you and provide you sufficient training on how to Process information related to Data Subjects.

We are constantly hiring new talents and thus encourage as many talents as possible to enter into our recruitment process. During the recruitment process we Process the Personal Data of candidates we contact with possible job offer as well as the candidates who apply themselves.

We may collect and Process, among other, the following Personal Data:

  1. name and contact details;
  2. all information contained in your CV and your motivation letter, e.g. information about your education and trainings, employment history, hobbies, language skills;
  3. interviews, i.e. information disclosed by you during interviews with our recruitment specialists, including within video interview;
  4. your job preferences;
  5. results of your tests, analyses, that are performed in our request;
  6. names and contact details of your recommenders. We consider that you have obtained consent from your recommenders prior to providing us their names and contact details;
  7. publicly available data about you, i.e. information relevant for recruitment process that is publicly available in registries, social media etc. As our service is high-trust service we ask candidates to give us information about or provide us access rights to their criminal records (only valid information, meaning archived criminal registry information is not requested).

We usually obtain Personal Data directly from you when you apply for a position with us or when we contact you with a possible job offer. In addition, we collect your Personal Data independently through different channels (e.g. via social media profiles, online job site). We also may collect your Personal Data from third parties, such as professional recruiting firms, your references, prior employers, employment background check providers, to the extent this is permitted by applicable law. Additionally, we may share your Personal Data with professional recruiting firms that we have entered into agreements with, in order to assist us in the recruitment process (the conditions for such sharing, see Chapter 6). During the recruiting process we may ask submission of different information that enable us to assess your suitability to certain positions. You are not required to provide any of the requested information to us, but kindly note that failing to do so may result in not being able to continue your candidacy for the position.

We do not seek to obtain special categories of Personal Data, such as data concerning your ethnicity, health, philosophical beliefs, sexual orientation etc.  

4.   The purposes and legal grounds for Processing your Personal Data

 

Here you can find out what legal basis and for which purposes we process Personal data. In general, we only process Personal data if you have given us a specific consent; it is strictly necessary for the performance of contract with you or the Merchant; to comply with our legal obligations or if this would be in our legitimate interests.  

 

4.1  The purpose and legal ground of processing for provision of Service

Regards to purpose of Users information we only have one aim – to verify your identity and for this purpose we capture photos and video of the verification session as well as the document provided for verification. We further may mix and match Personal Data collected and decide regards to identification either as “Pass”, “Resubmission” or “Decline”.

Verification process is either semi-automated, meaning that a human is meaningfully involved and may intervene the process at any time; or fully‑automated, meaning our verification algorithm automated verification tool helps us to verify your identity. Nancy is constantly learning to correctly give meaning to information; detect identification fraud or theft and she does her best to make sure you can be you even in the online world. Robot Nancy also makes the decision either “Pass”, “Resubmission” or “Decline”. So, in short Nancy does what our human verification specialists do and we hope that together we can make your identification and verification process as easy and safe as possible. In case we use Robot Nancy, you are invited to read further in published DPIA that considers and addresses the risks regards to automated decision-making by Robot Nancy. In case a fully automated decision-making, where the decision has a significant effect for you, we will be transparent about such processing and either ask for your explicit consent or inform you accordingly regards to legal basis for processing being necessity to entry into a contract directly with us or the Merchant. In case of automated decision-making we will provide you with all relevant information and explanations regards to logics behind Robot Nancy; at any time you will have the right to request human intervention or object to the decision made on grounds relating to your particular situation.

We Process User’s, Merchant’s representative’s and Visitor’s Personal Data for the following purposes:

  • We may ask you to grant us a consent.  Please note that we cannot provide the Service in respect of an anonymous User, and therefore the use of our Service is subject to the disclosure of Personal Data to us and consenting to the Processing of Personal Data by the Merchant and us. However, giving consent is voluntary but failure to do so may mean that we may not be able to provide you Service, for example we will not be able to verify your identity.  In some circumstances, e.g. for purpose of automated decision-making, we may as ask you to provide us with the explicit consent.
  • We mainly Process your Personal Data as a Processor for the benefit of the Merchant in order to fulfil the Agreement concluded with the Merchant for:

1.    performance of the Agreement (including for the provision of the Service);

2.    for performance of the obligations arising from the Agreement (including the realization of rights arising from the provision of the Service).

3.    we also Process your Personal Data if Processing is necessary for compliance with our legal obligation and provision of our Service for realization of rights arising from the Agreement;

4.    for the purpose of realization of rights and fulfilment of obligations deriving from legal acts;

5.    for processing your inquiries and requests;

 

  • we also Process your Personal Data if Processing is necessary in our legitimate interests meaning our interest in the management and direction of our business in order to be able to offer the best possible services on the market. For our legitimate interest, we may Process data for the following purposes:

1.    for analysing the use of our Service, and using research and analysis results, among other, for carrying out satisfaction surveys and developing our products and services including development of autonomous and automated decision-making processes;

2.    for the transmission of information about our Service.

3.    for sending our newsletters, for marketing and developing and promoting our Services, for organisation of campaigns, including personalised and targeted campaigns, and measuring the effectiveness of the performed marketing activities. Please note that for sending out newsletters, we only Process your contact details;

4.    for ensuring a trust-based relationship with a Merchants and Users, for example Personal Data Processing that is strictly necessary to determine the ultimate beneficiaries, being PEP and/or to prevent fraud, e.g. and checks in public sanction lists or our own Service history;

5.    for the administration and analysing the client base to improve the availability, selection and quality of Services and products, and to make the best and more personalised Services;

6.    for the analysis of identifiers and Personal Data collected upon the use of websites, mobile applications and other Services. We shall use the collected data for web analysis or for the analysis of mobile and information society services, for ensuring and improving the functioning, for statistical purposes and for analysing the behaviour and using experience of Visitors and for providing better and more personalised Services;

7.    for monitoring of the service. We may record the messages and instructions given in our premises or by means of communication (e-mail, telephone, etc.), as well as information and other operations carried out by us, and shall use those recordings as needed to evidence instructions or other operations;

8.    for network, information and cyber security considerations, for example for fighting against piracy and for ensuring the security of the Websites, as well as for the measures taken for making and storing backup copies;

9.    for the establishment, exercise or defence of legal claims.

 

Pursuant to our “Fundamental-Six” principles for data Processing, we only Process Personal Data on this legal basis after careful assessment in order to ascertain that the legitimate interest is in compliance with the interests and rights of a Data Subject (after carrying out the so-called three-step test). In case you have granted us a consent to process Personal Data, the details of such processes and purposes thereof would be outlined in the consent itself.

4.2 The purpose and legal ground of processing during recruitment process

  1. determining candidates suitability for the available position;
  2. verifying the data submitted by candidate (including carrying out reference checks and/or conducting background checks (where applicable);
  3. managing the recruitment process and keeping candidate updated about the progress of the process;
  4. in case of successful application, preparing job offer and in employment contract, and for fulfilling onboarding activities;
  5. informing candidate about our vacant positions;
  6. protecting our rights and fulfilling our legal obligations;
  7. business management and administrative purposes, such as record-keeping, improving our recruitment and business practices.

We Process your Personal Data as a controller on the grounds of legitimate interest for recruitment and management purposes (purposes nr (1) up to (3) and (7)), for preparing and performance of the contract (purpose nr (4)), for compliance with our legal obligation (purpose nr(6)), and on the basis of consent (purpose nr (5)).

In case a candidate is not selected, we shall store the Personal Data collected for the entry into an employment contract for two years in order to make a job offer to the candidate in case a suitable position becomes vacant.

 

4.3 Processing for a new purpose

In case Personal Data Processing is carried out for a new purpose, different from those for which the Personal Data were originally collected, or is not based on the consent given by the Data Subject, we shall carefully assess the permissibility of such new Processing. In order to determine whether the Processing for the new purpose follows the purpose for which the Personal Data were originally collected, Veriff shall take into consideration, inter alia, the following:

·      any link between the purposes for which the Personal Data were collected and the intended further purposes Processing;

·      the context of collecting the Personal Data, in particular regarding the relationship between the Data Subject and us;

·      the nature of the Personal Data, in particular whether any special categories of Personal Data are Processed;

·      possible consequences of the intended further Processing for the Data Subjects;

·      existence of appropriate protection measures which may consist in, for example, encryption and pseudonymisation.

 

5.    Data Subject’s rights in relation to Personal Data

 

Here you can find information about your rights regards to your Personal Data.

 

If you wish to exercise any of your rights regarding Personal Data or ask questions about the Privacy Policy, please submit a corresponding request to us at legal@veriff.com. We will respond to your request by e-mail as a rule no later than within one month. Please note that before we can provide you with the requested information regarding your Personal Data, we need to verify your identity. Please also note that if your request concerns data we have Processed as a Processor (i.e. in the course of Service provision) you must submit your request to the Merchant who is the controller of Processing of your Personal Data, we will inform you if this is the case.

You as a Data Subject have the following rights in relation to Personal Data:

  1. Right of access to Personal Data - you have the right to know which of your Personal Data we store and how we Process it, including the right to know the purpose of the Processing, the persons to whom we will disclose your Personal Data, information about automated decision-making and the right to receive copies of Personal Data.
  2. Right to rectification of Personal Data - you have the right to request the rectification of inadequate, incomplete and misleading Personal Data.
  3. Right to withdraw the consent given for the Processing of Personal Data - you have the right at any time to withdraw the consent given to us for the Processing of Personal Data. Please note that withdrawal of your consent shall not affect the legality of the Processing that was made on the basis of consent before the withdrawal.
  4. Right to erasure of Personal Data („right to be forgotten“) - you have the right to request that we erase your Personal Data (for example, if you take back the consent for the Processing of Personal Data, or if Personal Data is no longer needed for the purpose for which it was collected). We have the right to refuse the erasure of Personal Data if the Processing of Personal Data is necessary for the fulfilment of our legal obligation, to exercise the right to freedom of expression and information, for the preparation, presentation and protection of legal claims, or in the public interest.
  5. Right to restriction of Processing - In certain cases, you have the right to prohibit or restrict Processing of your Personal Data for a certain period of time (e.g., if you have filed an objection to Personal Data Processing).
  6. Right to object - you have the right to file an objection to Processing of your Personal Data if your Personal Data Processing takes place on the basis of our legitimate interest or public interest. You shall have the right to object at any time to Processing of Personal Data for direct marketing purposes, and we shall respond immediately.
  7. Right to data portability - In case your Personal Data Processing is based on your consent and Personal Data is processed automatically, you shall be entitled to receive Personal Data about you that you submitted to us as the controller, in a structured, commonly used and machine-readable format, and you shall have the right to transmit this Personal Data to another controller. You also have the right to request that we transfer Personal Data directly to another controller, where technically feasible.
  8. Automated decision-making (including profiling) - provided that we have informed You that we perform automated decision-making (including profiling) that will bring about legal consequences for you or have a significant effect on you, then you may require human intervention in the decision-making process.
  9. Submission of complaint. In case you find that your rights have been breached, you have the right to seek protection and file a complaint to the Data Protection Inspectorate (www.aki.ee).

Please read more about your rights from chapter 3 of the GDPR (General Data Protection Regulation).

 

6.   Disclosure and transfer of Personal Data

 

In this section you will find information about possible disclosure of your Personal Data and / or transfer of Personal Data outside EEA.

 

6.1   Disclosure of personal data to authorities

Please note that due to legal requirements, we may be obliged to disclose your Personal Data or to grant access to your Personal Data to the authorities and the supervisory authority.

6.2   Disclosure to controllers and processors

We may disclose your Personal Data to controllers for whom we are processors (e.g. Merchants) and to our authorized processors (sub-processors), as well as to persons who are legally entitled to receive your Personal Data.

For example, such authorized processors may be our affiliates, our IT partners, our advertising and marketing partners, companies carrying out satisfaction surveys, debt collection agencies, professional recruiting partners, credit registers, authorities and organisations intermediating or providing (electronic) mail, compliance or payment services and alike, provided that:

1.    the respective purpose and the Processing are lawful;

2.    we have diligently assessed that the authorized processor is to comply with the data protection requirements;

3.    the Personal Data Processing is carried out in accordance with the guidelines of us and on the basis of a valid agreement.

If you have questions about our authorized processors, please contact us at legal@veriff.com.

6.3   Transfer of Personal Data

We Process your Personal Data within the EEA.

In the event that we need to transmit your Personal Data outside the EEA, the transmission shall be in accordance with the requirements of the GDPR.

 

7.    Security of Personal Data

 

Security is of utmost importance to us. We do our best to protect Personal Data in our hands.

 

We apply various measures (physical, technical, organizational) to protect your Personal Data from unauthorized or arbitrary rectification, disclosure, acquisition, destruction, loss or unauthorized access.

If you have any information about an actual or suspected data breach, please inform us immediately at legal@veriff.com. We will deal with the issue immediately and inform the Data Protection Inspectorate (if applicable).

 

8.    Retention of Personal Data

 

Here you can find our data retention principles that is the length of period for which we keep Personal Data.

 

We shall store your Personal Data for as long as required by law or in accordance with the law, or for the purposes stated in this Privacy Policy. 

We store the data of Users during the period set forth in the Agreement (currently the term of the Agreement is up to 5 years) or as long as it is necessary for possible establishment, exercise or defence of legal claims of Users, Merchants or Us.

We may store your Personal Data including biometrical data and facial recognition information longer if we have lawful basis do to so, e.g. you have given us consent to use your Personal Data for the development of our Service or we have assessed to have legitimate aim to do so e.g. in pseudomized form or for the purpose of Service history log.

We store the data of job applicants (candidates) during the recruitment process and for two additional year after the recruitment process to  record your recruiting activity with us and be able to inform you of new vacancies within that timeframe.

After the expiration of the Personal Data storage period, we shall anonymize or permanently erase your Personal Data.

 

9.   Cookies and other tracking technologies

 

In this section you can find information about the usage of Cookies and other tracking technologies together with information where you can control your Cookie and add preferences.

 

We use Cookies on our Website, that you can accept if you choose to use our Website. There are other similar technologies for example web beacons. Cookies allow us to recognize whether you have used the Service before and it helps us to store your preferences and other information.

We use Cookies in many ways. Cookies help us to improve the offered services and make use of our services more convenient. For example, we use session Cookies, persistent Cookies and advertising Cookies. A session Cookie is deleted automatically after every visit; persistent Cookies shall remain upon repeated use of the Website, and advertising Cookies and third party Cookies are used by the Websites of the partners of Veriff which are connected with the Website of Veriff. We do not control the generation of those Cookies, therefore information on these Cookies can be obtained from third persons.

Most of the web browsers allow Cookies. Without fully allowing Cookies, not all of the functions of the Website are available to a Visitor. The allowing or prohibiting Cookies and other similar technologies shall be under the control of a Visitor via the settings of the Visitor’s own web browser.

If you prefer that your Personal Data will not be Processed on our website, you can activate the private browsing feature of Your web browser.

You can change and control your Cookie and add preferences for example on the following platforms:

·      Your Online Choices;

·      Network Advertising;

·      About Ads.

 

10. Availability and changes of the Privacy Policy

 

Here you can find info on making changes to the Privacy Policy and informing you about the changes.

 

This Privacy Policy is available on our Website.

Kindly note that we may modify the Privacy Policy from time to time. The modified policy will be uploaded to our webpage and we may notify Merchants and Users whose contact information we have about major changes in the Privacy Policy.

The current version:

Original version from 10.01.2019

New version 02.05. 2019 - We made modifications in all chapters within Privacy Policy to increase transparency, readability and simplicity.