Privacy Policy

We, at Born To Earn Ltd. ("Company" or "we") are deeply about privacy, security, and online safety, and we have implemented applicable measures and procedures to protect users of our products and services from the risks of theft, disruption, and unauthorized access to their online information and activities.

This privacy policy ("Policy") which is a part of the Company's Installer & Software Terms of Service ("TERMS"), sets out in detail the processing and transfer of data collected with respect to downloading and using Installer & Software, all in accordance with the relevant data protection and privacy regulations, including, as relevant to the User's jurisdiction, the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act ("CCPA").

Before downloading, accessing or making use of the Installer or Software, we recommended the User   to review this Policy with much diligence.  In addition, if a User is a California resident, we recommend to review the Company's specific CCPA Privacy Notice.

 This Policy does not cover the User's interaction with third-party content provided as part of the Software or otherwise included as a link therein. The Company privacy practices detailed herein may be different from third parties’ privacy practices. The Company does not control the privacy and security practices of third parties and shall not be liable or responsible to their omissions or acts.

DATA COLLECTION

The Company may collect and process certain types of data regarding the User, when the User is accessing or interacting with the Installer or Software.

The collected data includes both Personal and Non-Personal Data. Personal Data, is information that can identify or may with reasonable effort identify an individual. Non-Personal Data, is information which is unidentifiable or aggregated (for example, technical data), such information is not used to identify individuals.

All collection of the Personal Data, will be in accordance with the following lawful principle (under the GDPR): (1) The Company will process online identifiers for operation and functionality purposes; (2) The Company will process the User's contact details If the User make contact with the Company of his own wish, as well as any information provided to the Company for the purpose of carrying out our agreement with the User; and (3) When consent is necessary by the relevant laws, we will process certain Personal Data subject to obtaining the User's consent.

please see below a list of the specific types of data that will be collected, as well as THE purpose of Such collection:

  1. We will collect the User Internet Protocol ("IP") addresses and/or MAC addresses (Machine ID) address when the User uses the Installer and/or Software. This data might be collected by the Company or by its service providers.

This data it is necessary for operating and providing the Installer and Software, and therefore it processed under our legitimate interest.

Additionally, we will use this data in order to examine and track installations, to make sure that any installed Software is suitable for the User's device; by deciding which Software and what version will be proposed to the User and installed on the User's device; by correlating errors with certain information for debugging purposes; and by creating and analyzing statistics , to further advance, develop and customize the Installer and Software, as well as to conduct research, and preform statistical activities, detect fraud, and security issues. This data may further be used in order to make a calculation of our business partners’ payments.

Please note, that the IP address will be stored in a manner that is non identifiable, and once it collected, it will immediately be made anonymous (we will use industry common practices in this regard).

  1. Various technical data can be passed on to us when Installer and the Software are being used. The technical data collected will include: date and time stamp; the type of device and operating system; approximate location; traffic source which lead to the Installer; language; apps installed on device.

This technical data shall be used for operation purposes, and also in order to strengthen and upgrade the Installer and the Software, and to administer internal statistics.

  1. If the User choose voluntarily to contact the Company through any means of communication (for example, by sending an email), the User will be required to provide the Company with contact details such as name, organization name or email address

We will use the User's contact details in order to respond and provide the User with the assistance, or any other service the User requested.

The correspondence may be stored if the Company find is required, for instance, for any future claim, or to provide the User with assistance or to improve the Installer or the software

  1. In the event the Software installed by the User is an add an browser extension or a search related product, the User's search related data may be collected, which include data related to the URLs of websites that the User visited. This type of data will be collected as an aggregated Non-Personal Data. However, in some of the cases web browsing data contains data that could be deemed to be Personal Data. This type of data will be deleted short time after collection. The Company shall use this data in order to provide certain features of the Software, such as display relevant advertising based on searches.

SHARING DATA WITH THIRD PARTIES

The Company may share Personal Data solely for following limited purposes:

  1. The Company will share the Personal Data of the User, solely to the extent needed, in order to comply with applicable law or regulation (including the Company policies and agreements);

  2. The Company may share the User's Personal Data with its service providers only to the extent required to fulfill the purposes of providing the Installer’s and Software’s features.

  3. The Company may share the User's data, in compliance with applicable laws requirements, in the event of a corporate transaction (for instance, sale of a substantial part of our business, merger, consolidation or asset sale). In such case, the Company's affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.

  4. The Company may share the User's Personal Data with third parties, subject to the User's consent. If the Company does so, the Personal Data shared shall be subject to such third party’s privacy policies.

  5. The Company may share the User's data with its affiliated companies such as: subsidiaries, parent company or controlled companies only if and when applicable or necessary.

  6. The Company may share online identifiers collected by it with its business partners, in order to calculate payments or detect fraud, in connection with the Installer’s and Software’s services.

DATA TRANSFER

The Company may process or store Personal Data within the European Economic Area ("EEA"), US, and internationally. The Company will take appropriate safeguards to ensure that the User's Personal Data receives an adequate level of data protection as required under applicable data protection laws.

SECURITY AND RETENTION

Since the privacy of the User is important to the Company, the Company is committed to protecting his/her Personal Data from unauthorized access, use or disclosure. The Company has implemented physical, technical and administrative security measures that comply with applicable laws and industry standards.

However, the Company cannot guarantee that the Personal Data of the User is fully secured and cannot be responsible for such acts of those who achieve unauthorized access or abuse the Installer’s or Software’s services. The Company makes no warranty, express or implied, that it can prevent such access.

If the User feels that his privacy was violated by individual attempt to the Installer’s or Software’s services, the User may contact the Company at: [add email address].

Information the Company collects will be retained for as long as needed to provide the Installer’s or Software’s services, to comply with our legal commitments, resolve disputes and enforce the Company's agreements if applicable, in accordance and compliance with applicable laws, and subject to the instructions which the Company may receive from the User.

The User shall not interpret this Policy as a commitment to save his/her information, and the Company may, at its own discretion, delete or avoid from keeping any or all information.

USER’S RIGHTS

Applicable data protection and privacy laws may provide the User with the ability to exercise some rights regarding his Personal Data collected by the Company (which might be different in each jurisdiction). 

If the User is a resident of the EEA or California State, the provisions of the GDPR and the CCPA, respectively, may provide the User with some of the following rights:

  1. The right to access his Personal Data;

  2. The right to amend and update his Personal Data;

  3. The right to request deletion of his Personal Data (if there is no new lawful basis for continued processing);

  4. The right to object to the processing of his Personal Data;

  5. The right to limit the processing of his Personal Data;

  6. The right to have his Personal Data "port" to a third-party;

  7. The right to withdraw consent when consent is the legal basis for the processing of his Personal Data; and

  8. The right to file a complaint to a supervisory authority in his jurisdiction.

CHILDREN’S’ PRIVACY

The Installer and Software are not intended for individuals under the age of 16. Accordingly, the Company does not knowingly solicit, collect or save Personal Data of children as defined under applicable law. If we later obtain actual knowledge that a user is considered as child under applicable law, we will take steps to immediately delete its Personal Data.

DO NOT TRACK SIGNAL

Please note that the Installer and Software do not respond to Do Not Track signals. Please click the following link to receive more information: www.allaboutdnt.com.

UPDATES TO THE POLICY

The Company may update or amend this Policy at its sole discretion or if it required under the laws. The most recent and updated version of this Policy referred in the "Updated" heading in the preamble. We encourage the User to periodically review this Policy for the latest information about our privacy practices. In case it required under relevant law, the Company will send an applicable notice. 

CONTACT INFORMATION OF THE COMPANY

If you have any question or query about this Privacy Notice you can contact us at:

Born To Earn Ltd.

lyashenko.sptk@gmail.com