You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, you may be asked to provide certain Personal Information (for example, your name and e-mail address).

We receive and store any information you knowingly provide to us when you fill any forms on the Website. When required, this information may include the following:

• Contact information (such as email address, phone number, etc)
• Basic personal information (such as name, country of residence, etc)
• Proof of identity (such as a photocopy of a government ID)

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.

We do not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians

We act as a data controller and a data processor when handling Personal Information, unless we have
entered into a data processing agreement with you in which case you would be the data controller and
we would be the data processor.

Our role may also differ depending on the specific situation involving Personal Information. We act in
the capacity of a data controller when we ask you to submit your Personal Information that is necessary
to ensure your access and use of the Website and Services. In such instances, we are a data controller
because we determine the purposes and means of the processing of Personal Information.

We act in the capacity of a data processor in situations when you submit Personal Information through
the Website and Services. We do not own, control, or make decisions about the submitted Personal
Information, and such Personal Information is processed only in accordance with your instructions. In
such instances, the User providing Personal Information acts as a data controller.

In order to make the Website and Services available to you, or to meet a legal obligation, we may need
to collect and use certain Personal Information. If you do not provide the information that we request,
we may not be able to provide you with the requested products or services. Any of the information we
collect from you may be used for the following purposes:

• Send administrative information
• Run and operate the Website and Services

Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Note that under some legislations we may be allowed to process information until you object to such
processing by opting out, without having to rely on consent or any other of the legal bases. In any case,
we will be happy to clarify the specific legal basis that applies to the processing, and in particular
whether the provision of Personal Information is a statutory or contractual requirement, or a
requirement necessary to enter into a contract.

To maintain the highest level of privacy and to protect your Personal Information to the full extent, we do not share your Personal Information with any third parties.

However, we may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in

In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.

The Website and Services contain links to other resources that are not owned or controlled by us. Please
be aware that we are not responsible for the privacy practices of such other resources or third parties.
We encourage you to be aware when you leave the Website and Services and to read the privacy
statements of each and every resource that may collect Personal Information.

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services

In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website.

We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will send you an email to notify you. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

If you have any questions, concerns, or complaints regarding this Policy, the information we hold about
you, or if you wish to exercise your rights, we encourage you to contact us using the details below:

[email protected]

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

This document was last updated on June 7, 2022