IMPORTANT PRIVACY INFORMATION
When you access our website we automatically collect from your device cookies, IP address and technical information about your device, such as language settings, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID. We need this data to provide our services, analyze how our customers use the website and to measure ads.
If you decide to register a personal account on the Website, we will ask you to provide an email, name, payment details, date of birth, photo, country, exact location, phone number, social media identifiers (Google account, Instagram, Facebook), identifiers in instant messaging platforms (Skype, Viber, WhatsApp), company name, your position, copies of identity documents. We will use this data to render you a service. For improving the website, we use third party solutions. Therefore, some of the data is stored and processed on the servers of third parties. Such third parties include Digital Ocean, Facebook, Google, Mailchimp, Mobizon. This enables us to analyze different interactions.
You have the right to revoke your consent to the collection, use and storage of your personal data at any time by clicking on the link https://security.google.com/settings/security/permissions.
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states to the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
TABLE OF CONTENTS
- PERSONAL DATA CONTROLLER
- CATEGORIES OF PERSONAL DATA WE COLLECT
- FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
- UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
- WITH WHOM WE SHARE YOUR PERSONAL DATA
- HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
- AGE LIMITATION
- INTERNATIONAL DATA TRANSFERS
- CALIFORNIA PRIVACY RIGHTS
- DATA RETENTION
- HOW “DO NOT TRACK” REQUESTS ARE HANDLED
- CONTACT US
1. PERSONAL DATA CONTROLLER
Oklamon Limited, a company registered under the laws of the Republic of Cyprus, having its registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus, will be the controller of your personal data.
2. CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, email address, payment details, contact details, such as phone number, social media identifiers, identifiers in instant messaging platforms, photo, country, exact location, company name, and your position, copies of identity documents). We also may receive data about you from third parties (for example, when you sign in via Facebook or Google). We also collect data automatically (for example, your IP address, cookies, and information about your device).
2.1. Data you give us
If you decide to register your personal account on the Website, conclude agreement on the Website, register online to participate in our events, withdraw funds from your YouTube channels, get a consultation or use other services, we will ask you to provide an email address that will be used for signing in to your personal account and informing you about our services. We will also ask you to provide your payment details to enable you to create payment orders via your personal account and withdraw funds from your YouTube channels.
We may also ask your approximate age to understand if you are eligible to use the Website, your contact details (phone number, social media identifiers, identifiers in instant messaging platforms) to resolve support cases and inform you about our services, your photo, country, exact location, company name, and your position to create your personal account and make it possible for you to use it, copies of identity documents to enable you to create payment orders via your personal account and withdraw funds from your YouTube channels.
2.2. Data provided by third parties
When you decide to log in using Facebook, we get personal data from your Facebook account. This includes your profile image, name, and Facebook ID. Unless you opt out on the Facebook Login screen, we will also collect other data, such as email address.
For more information, please refer to the Facebook Permissions Reference (describes the categories of information, which Facebook may share with third parties and the set of requirements) and to the Facebook Data policy. In addition, Facebook lets you control the choices you made when connecting your Facebook profile to the Website on their Apps and Websites page.
2.3. Data we collect automatically:
2.3.1. Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad).
2.3.2. Device and Location data
We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
2.3.3. Usage data
We record how you interact with our Service. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Website, how long you are on the Website, your purchases.
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.
Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information, which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.
3. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
We process your personal data:
3.1. To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. As a result of such processing, we will use your email, your photo, country, exact location, company name, and your position to create your personal account on the Website and make it possible for you to use it, conclude agreement on the Website, register online to participate in our events and provide access to such events, use or browse the Website, grant access to your channels, to send you reports.
We will also use your payment details and copies of your identity documents to enable you to create payment orders via your personal account and withdraw funds from your YouTube channels.
To host personal data and enable our Service to operate and be distributed, we use Digital Ocean, which is a hosting and backend service.
To protect your personal data by enabling two-factor authentication, we use Mailchimp, which is a transactional email service. Here its privacy statement.
3.2. To customize your experience
We process your personal data, such as your Google Account, to adjust the Service. As a result of such processing, for instance, you get access to information on your YouTube income through your personal account on the Website.
3.3. To provide you with customer support
3.4. To communicate with you regarding your use of our Service
We communicate with you, for example, by emails. These may include for example, emails with information about the Service and special offers on our products and Services that, in our opinion, may be of interest to you. To opt out of receiving emails, you need to follow the instructions in the footer of the emails.
The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service’s users, as well as when they interacted with it, such as by tapping/clicking on links included in the message.
3.5. To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.
3.6. To send you marketing communications
We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Website.
3.7. To personalize our ads
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website, you might see ads of our products in your Facebook’s feed.
How to opt out or influence personalized advertising iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.
Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.
macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads.
Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have other Windows version, please follow the steps here.
To learn even more about how to affect advertising choices on various devices, please look at the information available here.
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
- Network Advertising Initiative – https://optout.networkadvertising.org/
- Digital Advertising Alliance – https://optout.aboutads.info/
- Digital Advertising Alliance (Canada) – https://youradchoices.ca/choices
- Digital Advertising Alliance (EU) – https://www.youronlinechoices.com/
- DAA AppChoices page – https://www.aboutads.info/appchoices
Browsers: It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Chrome
- Cookie settings in Safari web and iOS
Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.
We use Facebook pixel on the Website. Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Website.
We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, choose users that have completed certain actions in the Service (for example, visited certain sections of the Website). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.
Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our Website (for example, show our ads to users who have made a purchase). Some other examples of events that may be used for tailoring ads include, in particular, visiting our Website. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
3.8. To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
3.9. To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.
We process your personal data under the following legal bases:
4.1. to perform our contract with you
Under this legal basis we:
- Provide our Service (in accordance with our Terms and Conditions of Use)
- Customize your experience
- Provide you with customer support
- Communicate with you regarding your use of our Service
4.2. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
- to communicate with you regarding your use of our Service
This includes, for example, sending you email to notify you that we have released a new product. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.
- to research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable, or to introduce and test new features).
- to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.
- to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
- to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
4.3. to comply with legal obligations.
5. WITH WHOM WE SHARE YOUR PERSONAL DATA
5.1. Service providers.
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
- cloud storage providers (Digital Ocean)
- communication service providers (Mailchimp, Mobizon)
- marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google)
5.2. Law enforcement agencies and other public authorities.
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
5.3. Third parties as part of a merger or acquisition.
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website.
Deleting your personal data. You can request erasure of your personal data as permitted by law.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.
Additional information for EEA-based users:
If you are based in the EEA, you have the following rights in addition to the above:
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request to us as described below.
To exercise any of your privacy rights, please send a request to firstname.lastname@example.org.
7. AGE LIMITATION
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.
8. INTERNATIONAL DATA TRANSFERS
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).
10. CALIFORNIA PRIVACY RIGHTS
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to email@example.com which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
11. DATA RETENTION
12. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user's DNT preference. You can usually access your browser's DNT option in your browser's preferences.
We currently do not support “Do Not Track” requests because no DNT standard has been adopted.
Our third-party services may collect information about you and your online activities over time and across our Services and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. To determine whether any of the third-party services honor the “Do Not Track” requests, please read their privacy policies.
13. CONTACT US
Effective as of: 20 June 2022.