Privacy Notice for Gromus
Last updated: February, 2024
Intro
Gromus (“Company” or “we”) welcomes you. This Privacy Notice (“Privacy Notice”) applies to our website (“Website”).
The Privacy Notice describes which of your personal data Gromus collects, how stores, processes, and uses it, and what happens when you use the Website.
Content
Registered Users’ data
Support requestor’s data
Data received from third parties
Data sharing with third parties
Data transfer outside the European Economic Area
European Economic Area residents
Do not sell my personal information
About us
We are the controller of your personal data processed through the Website. This means that we determine the purposes and means of personal data processing. Pay attention that you can fall into several categories depending on your actions.
Name | Gromus, Inc. | ||
Address | 919 North Market Street, Suite 950 in the City of Wilmington, County of New Castle, DE 19801, USA | ||
[email protected] – for general and privacy inquiries | |||
About you
When you visit the Website, you become our user (“User”). We divide the Users into categories so you can easily find details about the processing of your personal data.
Type of User | Description | ||
Visitor | User who visits the Website | ||
Support Requester | User who messages to the support service | ||
Registered User | User who creates an account on the Website | ||
Please note! We do not knowingly process the personal data of Users under the age of 13. If you are such a User or the legal representative of such a User, please contact us. | |||
Personal data
Sources of data
We receive your data when you visit the Website and interact with it, depending on your actions on the Website.
You can change your personal data by exercising your right to rectification or by the Website functionality. Please note that the same lawful basis and storage terms apply to the changed data.
We may also (although we do not necessarily do so) receive data from third parties. It depends on your settings and the features you use.
Lawful bases for processing
To process your personal data, we rely on the following lawful bases:
- performance of the contract — for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract (mainly, the Terms of Service) with you;
- legitimate interest — for the processing necessary at the development of our services, taking into consideration your interests, rights, and expectations;
- legal obligation — for the processing as required by applicable laws (for example, to comply with tax or KYC/AML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorised public body;
- consent — for additional specific purposes.
Visitors’ data
When you use the Website as the Visitor, we collect some data automatically. We need technical data to operate, support, and improve the Website’s functionality.
Registered User
When you register an account and start to use our service, we collect the data to enable you access and correct work of the Service.
Data | Reasons for processing | Lawful basis |
Name, email address and password | Create an account | Performance of the contract |
Data about the accounts | To provide the smooth operation of the Platform | Performance of the contract |
Data on the device (device name and operating system) | ||
IP address and mobile device identifiers (device ID, MAC address, IMEI); | ||
General location data (country and city) | To understand the regions our users are from | Legitimate interest |
Payment data | To handle subscription and other purchases | Performance of the contract |
Social media accounts | Account identifiers (URL, ID, name, description), publicly available information | Performance of the contract |
Data storage | ||
Data that is processed based on performance of the contract | Stored for 3 years years from the last interaction. | |
Data that is processed based on legitimate interest | Stored for 3 years from the last interaction or until you object to the processing. | |
Support Requestor’s Data
When you address your request to support on the Website, we collect some information to help you.
We may collect your detailed log files to help you with your problem. These log files may contain personal information and are connected to you
Data | Reasons for Processing | Lawful Basis |
To fulfil your support request | Performance of the contract | |
Name | ||
Type of device | ||
Text of the request | ||
Attached files | ||
Logs | ||
Data Storage | ||
We store the data during your use of the service and 3 years after the termination of the agreement between us and you. | ||
Data received from third parties
We may receive some personal data from third parties.
The amount of data collected, the purposes, and the lawful basis for processing is determined by the respective privacy documents of these third parties.
Data sharing with third parties
We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organisational and technical measures to ensure the security of personal data during data transfer to third-party.
Third parties | Description |
Analytics tools | We use analytics tools to understand and promote our business. |
Messengers | We use messengers to communicate with you in ways that are convenient for you. |
Contractors, services providers on Website | We cooperate with service providers and contractors to provide you with their services, operate, develop and improve the features and functionality of the Website, fulfil your support requests, complete payment transactions, etс. |
Providers of the services our team use | We use CRM systems, messengers, and other services in our organisation to provide you with our services. |
State authorities, courts, law enforcement agencies, etc | We may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies:
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To get a detailed list of the third-party recipients of your personal data, contact us. | |
To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.
Data transfer outside the European Economic Area
The personal data we collect is stored on _____ servers.
If there is no adequate decision by the European Commission regarding the country we transfer data to, we use the adopted Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.
If there is an adequate decision by the European Commission regarding the country we transfer data to, we can transfer personal data to that third country without any further safeguard being necessary.
You can read more detailed measures to protect your personal data here.
Data protection
We apply a variety of security measures appropriate to the possible risks.
Organisational measures | |
Staff training | |
Non-disclosure agreements (NDA) | Transfer protection |
Technical measures | |
Two-factor authentication | Backups |
Firewalls | Encryption technologies |
Data subjects rights
You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.
European Economic Area residents
You, as a data subject, have the right to interact with its data directly or through a request to us. This section describes these rights and how you can exercise them:
Right | Description |
Right to access | You can request an explanation of the processing of your personal data. |
Right to rectification | You can change the data if it is inaccurate or incomplete. |
Right to erasure | You can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law. |
Right to restrict the processing | You may partially or completely prohibit us from processing your personal data. |
Right to data portability | You can request all the data you provided to us and request to transfer data to another controller. |
Right to object | You may object to the processing of your personal data. |
Right to withdraw consent | You can withdraw your consent at any time. |
Right to file a complaint | If your request was not satisfied, you could file a complaint to the regulatory body. |
To exercise your rights, contact us. If your request was not satisfied, you can submit a complaint to your local Data Protection Authority. You may find it here. UK residents enjoy the same rights but may lodge a complaint at the other Authority in the UK – Information Commissioner’s Office. You can contact them at 0303 123 1113 or go online at www.ico.org.uk/concerns. | |
United States residents
You, as data subjects, have some special privacy rights. To use them, please contact us.
Please note! Depending on the state and legislative requirements, we have from 30 to 60 days to exercise your request, with the right to postpone it for 30 days more. |
If your complaint is not satisfied, you can file a complaint with the Federal Trade Commission.
Your rights vary depending on the laws that apply to you but may include:
Right | Description | Area | |
Right to access | You can request an explanation of the processing of your personal data. |
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Right to correct | You can change the data if it is inaccurate or incomplete. |
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Right to delete | You can send us a request to delete your personal data from our systems. |
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Right to portability | You can request all the data you provided to us and request to transfer data to another controller. |
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Right to opt out of sales | The right to opt out of the sale of personal data to third parties. |
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Right to opt out of certain purposes | The right to opt-out of processing for profiling/targeted advertising purposes. |
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Right to opt out of processing of sensitive data | The right to opt-out of processing of sensitive data. |
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Right to opt in for sensitive data processing | The right to opt in before processing of sensitive data. |
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Right against automated decision-making | A prohibition against a business making decisions about a consumer based solely on an automated process without human input |
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Private right of action | The right to seek civil damages from a controller for violations of a statute. |
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Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is not on the list, please contact us. | |||
Do not sell my personal information
California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by CCPA.
We do not sell your personal information to anyone nor use your data as a business model.
However, we support CCPA by allowing California residents to opt out of any future sale of their personal information. If you would like to record your preference that we will not sell your data in the future, please contact us via [email protected].
Do-not-track requests
California residents visiting the Website may request that we do not automatically gather and track information about their online browsing movements across the Internet.
Such requests are typically made through web browser settings that control signals or other mechanisms that allow consumers to exercise choice regarding collecting personal data about an individual consumer’s online activities over time and across third-party websites or online services.
We currently do not have the ability to honour these requests. We may modify this Privacy Notice as our abilities change.
Canada residents
You, as a data subject (individuals), under The Personal Information Protection and Electronic Documents Act, Personal Information Protection Act of British Columbia, Personal Information Protection Act of Alberta, and Act respecting the protection of personal information in the private sector of Quebec have the right to interact with its data directly or through a request to us regarding privacy issues.
This section describes the privacy rights of Canadian residents and how they can exercise them:
Right | Description |
Right to access | You can request an explanation of the processing of your personal data. |
Right to rectification | You can change the data if it is inaccurate or incomplete via request or profile settings on the Website. |
Right to delete | You can send us a request to delete your personal data from our systems or delete your account via Website settings. We will remove all data unless some of them we have to store in compliance with the law requirements. |
Right to data portability | You can request all the data you provided to us and request to transfer data to another controller. |
Right to object opt-out | You may object to the processing of your personal data. |
Right to withdraw consent | You can withdraw your consent at any time. |
Right not to be subject to automated decision-making | You can object to being subject to automated-based processing to know if there are consequences concerning them due to such processing. |
Right to lodge a complaint | If your request is not satisfied, you can file a complaint to the regulatory body. |
To exercise your rights, contact us. We have 30 days to exercise your request from the moment it is received on our contact email. If your complaint is not satisfied, you can file a complaint to the Office of the Privacy Commissioner of Canada. | |
Cookies
We use cookies that are needed for the Website’s operation. By using cookies, we receive automatically collected data. You can read more in the Cookie Policy.
If you want to turn off cookies, you can find instructions for managing your browser settings at these links:
Privacy Notice updates
This Privacy Notice is developed according to the General Data Protection Regulation, other applicable privacy laws, and best privacy practices.
Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on the Website.
If there are material changes to the Privacy Notice or the Website that affect your data privacy rights, we will notify you by displaying information on the Website and, if necessary, ask for your consent.