Privacy Policy

Background

We understand that Your privacy is important to You and that You care about how Your personal data is used and
shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use
personal data in ways that are described here, and in a manner that is consistent with Our obligations and Your
rights under the law.

Under the EU Regulation 2016/679 – the General Data Protection Regulation and other applicable legislation We are
required to comply with personal data protection and processing procedures to ensure that Your data is at all
times stored and processed securely and that Your rights as a data subject are observed and protected. We take
these obligations very seriously and have implemented adequate technical and organizational measures to ensure the
protection of Your privacy.

Please read this Privacy Policy carefully and ensure that You understand it. You will be required to read and
accept this Privacy Policy when You first provide Your personal data to Us.

Information About Us

Our Site is operated by Simple Software Technology, a limited liability company incorporated and registered under
the laws of Romania with registration number J40/594/2020and its registered address at George Enescu Street, No.
36-42, commercial space No.2, office 15, 1st floor, 1st District, Bucharest, Romania.

Our Data Protection Officer can be contacted by email at dpo@thunderspin.com or by post at George Enescu Street,
No. 36-42, commercial space No.2, office 15, 1st floor, 1st District, Bucharest, Romania.

What Does This Policy Cover?

This Privacy Policy applies to Your use of Our Site. Our Site may contain links to other websites. Please note
that We have no control over how Your data is collected, stored, or used by other websites and We advise You to
check the privacy policies of any such websites before providing any data to them.

Your Rights

As a data subject, You have the following rights under the GDPR, which this Policy and Our use of personal data
have been designed to uphold:

You have the right to be informed about Our collection and use of personal data and to access to the personal
data We hold about You. Please contact Us at dpo@thunderspin.com for
more details;
You have the right to rectification if any personal data We hold about You is inaccurate or incomplete. Please
contact Us at dpo@thunderspin.com for more details;
You have the right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about You.
There may other legal obligations which may prohibit Us from deleting all or any information held about You
(such as Anti-Money Laundering legislation) immediately, however, We will process Your request at the earliest
opportunity whenever any applicable data retention period expires. You can exercise this right by contacting Us
at dpo@thunderspin.com;
You have the right to restrict (i.e. prevent) the processing of Your personal data, and the right to object to
Us using Your personal data for particular purposes, e.g. for marketing purposes. You can exercise this right
by contacting Us at dpo@thunderspin.com or by unsubscribing from Our
e-mail, by following the instructions in
those e-mails;
You have the right to data portability (obtaining a copy of Your personal data to re-use with another service
or organization). We will provide such a copy free of charge unless the request is manifestly unfounded or
excessive, wherein such case a reasonable fee for administration costs may be charged. Please contact Us at
dpo@thunderspin.com for more details;
You have certain rights with respect to automated decision making and profiling. You have the right to obtain
human intervention in the process of automated decision making, to express You point of view and to contest the
decision. You can exercise this right by contacting Us at dpo@thunderspin.com.

Please note that if You withdraw Your consent for Us processing Your personal data, restrict such processing or
request that Your personal data be deleted, We may be no longer able to provide Our services to You.

Information We Collect About You

Depending upon Your use of Our Site, We may collect and process some or all of the following personal and
non-personal data:

Information You give us. This is information about You that You give Us by filling in forms on Our Site, using
live chat on Our Site, or communicating with Us via e-mail, post or other methods. The information You give Us
may include Your first name, last name, title, e-mail address, nickname / username (alias) and other
information provided by You or contained in the documents provided by You;
Information We collect about You. When You visit Our Site, use Our services, use live chat on Our Site, or
communicate with Us via e-mail, post or other methods, We may collect information about You, which may include:
Your location, IP address, locale, referrer, source of your traffic to Our Site or chat room, domain, chat ID,
chat history, contact details, pages You visit and links You follow, and technical parameters of Your device
and software You use to access Our Site.

How We Use Information About You

Our use of Your personal data will always have a lawful basis, either because it is necessary for Our performance
of a contract with You, because You have consented to Our use of Your personal data, or because it is required by
applicable law. Specifically, We may use Your data for the following purposes:

Purpose	Comments
Our Site functionality and management	In order for Us to manage Our relationship with You and provide You information You requested;
Marketing purposes	In order to provide You with information on Our offers, industry events, and other news and products that may interest You;
Content customization	In order to deliver information and other content in the form most convenient to You (this may include specific languages, optimized view for specific device types, etc.) ;
Official notifications	To notify You about changes in Our Privacy Policy and other applicable terms and notices;
Profilin	We may use Your personal data for profiling of You and Your activity on Our Site to get to know Our customers better and to provide better user experience to You, as well as to personalize, measure, and improve Our marketing and to send You more relevant marketing communications;
Affiliate management	In order to run and manage Our affiliate program;

Where We Store Information About You

Your personal data will be primarily stored within the European Union.

If We transfer Your Personal Data outside of the EEA, within the group or to Our
business partners, We will take all reasonable steps to ensure that adequate measures are in place to keep Your
personal data as secure as it is within the EEA and in accordance with this Privacy Policy, by relying on the use
of standard contractual clauses or binding corporate rules or any other acceptable method that ensures protection
of Your data to the standard required within the EEA. You can always contact Us to receive more details on which
service providers outside of the EEA process Your data.

Data security is very important to Us, and to protect Your personal data We have
taken suitable measures to safeguard and secure data collected through Our Site. All information You provide to Us
is stored on secure servers. Your payment details data will be encrypted. Unfortunately, the transmission of
information via the internet is not completely secure. Although We will do Our best to protect Your personal data,
We cannot guarantee the security of Your data transmitted to Our Site; any transmission is at Your own risk. Once
We have received Your information, We will use strict procedures and security features to prevent unauthorised
access.

We do not keep Your personal data for any longer than is necessary in light of
the reasons for which it was first collected. Your personal data will be retained for as long as You have a
relationship with Us, and for a period of up to five years after that unless a longer period is required by the
applicable law.

With Whom We Share Information About You

In certain circumstances, We may be legally required to share certain data held by Us, which may include Your
personal data, for example, where We are involved in legal proceedings, where We are complying with legal
obligations, a court order, or a governmental authority, or in order to enforce or apply Our agreements with You,
or to protect Our rights, property, or safety, including combating terrorism financing, money laundering, and
fraud.

We may share Your personal data with other companies in Our group. This includes Our subsidiaries and Our holding
company and its subsidiaries.

We may share Your personal data with other selected third parties, some of which may be located outside the EEA or
further sub-process Your data to entities outside the EEA, including:

Our suppliers and their sub-processors engaged in operating Our Site and supporting Our clients. These persons
would require Your personal data in order to provide targeted advertising to You, run promotional campaigns,
run behavioural advertising, verify accurateness of the data You provide to Us, and contact You in relation to
the products and services on Our Site and other products and services that We believe may be of interest to
You. These entities also have access to Your personal information in order to provide You with first-line
support or to answer initial queries and complaints from You. For example, Your information regarding the use
of the live chat on Our Site may be shared with the live chat service provider – LiveChat, Inc., located in the
USA;
IT and related service providers and their sub-processors, engaged in operating Our Site. These providers
include cloud service providers contracted to store Your personal data (Amazon and Hetzner);
advertisers and advertising networks, affiliates, and their sub-processors, which require Your personal data
to select and serve relevant adverts to You and others. The example list of these entities can be found in “Our
Use of Cookies” section below;
analytics, business intelligence partners and search engine providers and their sub-processors, which assist
Us in the improvement and optimisation of Our Site. The example list of these entities can be found in “Our Use
of Cookies” section below;
Our lawyers, advisors, auditors, consultants who We may engage from time to time to advise on any matter which
requires them to gain access to personal information;
Potential sources of funding, investment, new business owners, who require such information to evaluate
potential investment, merger or acquisition.

You agree to Your personal data being processed by these third parties.

Our Use of Cookies

Our Site may place and access certain Cookies on Your computer or device. A Cookie is a piece of information in
the form of a very small text file that is placed on an internet user’s hard drive. It is generated by a web page
server, which is basically the computer that operates a web site. The information the Cookie contains is set by
the server and it can be used by that server whenever the user visits the site.

By using Our Site, You agree to the use and storage of Cookies on Your computer or device. If You do not wish Our
Website to use Cookies on Your computer or device, You can at any time deactivate and delete Cookies through Your
browser settings. More information on Cookies and how to disable and delete them may be found at www.aboutCookies.org/Cookie-faq or www.allaboutcookies.org. Please note, however, that if You refuse
or delete Cookies, certain parts of Our Site may not function properly, and we may not be able to offer You
certain services.

We use both first party and third party Cookies. First party Cookies are those placed directly by Us and are used
only by Us. We use Cookies to facilitate and improve Your experience of Our Site and to provide and improve Our
products and services. By using Our Site, You may also receive certain third-party Cookies on Your computer or
device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. In addition, Our
Site uses analytics services, which also use Cookies. Website analytics refers to a set of tools used to collect
and analyse usage statistics, enabling Us to better understand how people use Our Site.

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses
Cookies to help the website analyse how users use the site. The information generated by the Cookie about Your use
of Our Site (including Your IP-address) will be transmitted to and stored by Google on servers in the United
States. Google will use this information to analyse Your use of Our Site, compile reports on Our Site activity for
Us, and perform further services associated with Our Site use and Internet use. Google may also transmit this
information to third parties where required by law or to the extent third parties process these data on behalf of
Google. You can opt-out from being tracked by Google Analytics with effect for the future by downloading and
installing Google Analytics Opt-out Browser Add-on for Your current web browser: tools.google.com/dlpage/gaoptout.

Most common Cookies used on Our Site are:

Name of cookie or similar technology	Cookie or similar technology provider	Purpose
_csrf	We	This Cookie is used to identify You when You visit Our Site
Google Tag Manager (_gid, _ga)	Google	This Cookie is placed by Google. It enables Our Site to learn information about Our users’ use of Our Site, such as the time of visit, the pages viewed, whether the user has visited before and the websites visited prior to visiting ours, using Google and other thirds party services.
Google Analytics	Google	This Cookie is placed by Google. It enables Our Site to learn information about Our users’ use of Our Site, such as the time of visit, the pages viewed, whether the user has visited before and the websites visited prior to visiting ours.
Yandex.Metrica (_ym_uid, _ym_isad)	Yandex	This Cookie is placed by Google. It enables Our Site to learn information about Our users’ use of Our Site, such as the time of visit, the pages viewed, whether the user has visited before and the websites visited prior to visiting ours.
Facebook Pixel	Facebook	This Cookie is placed by Facebook. It enables Our Site to measure, optimize and build audiences for advertising campaigns served on Facebook.
One Signal	One Signal	This Cookie is placed by One Signal. It enables Our Site to remember that You subscribed to receive push notifications. It also helps Us deliver personalized notifications.
VWO>	VWO	This Cookie is placed by VWO. VWO places Сookies in end user’s and customer’s browser to identify the user. Cookies do not contain any of Your personal data. They may also collect and store information locally on Your device, using mechanisms such as browser web storage.
Hotjar	Hotjar	This Cookie is placed by Hotjar. It collects non-personal information, with the overall aim of providing You with a better website experience, diagnose technical problems and analyse trends.
Unbounce	Catena Media	Unbounce is a tool that helps Us build better landing pages. Unbounce Сookies will be used to collect non-personal data that will be used to improve the landing pages and provide a better experience.
dWords	dWords	AdWords is used to enable Google PPC (pay per click) campaigns.
Double Click	Double Click	Double Click is used for advertisers and to advertise on multiple ad servers.
LiveChat (__lc.visitor_id., lc_sso)	LiveChat, Inc.	This Cookie allows Us to communicate with You through a live chat when You select this option on Our Site.

Contacting Us

If You have any questions about Our Site or this Privacy Policy, please contact Our Data Protection Officer, by
email at dpo@thunderspin.com or by post at George Enescu
Street, No. 36-42, commercial space No.2, office 15, 1st floor, 1st District, Bucharest, Romania.

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be
immediately posted on Our Site and You will be deemed to have accepted the terms of the Privacy Policy on Your first
use of Our Site following the alterations. We recommend that You check this page regularly to keep up-to-date. Where
appropriate, We will also notify You by e-mail. In the event that You do not agree with any changes, You must stop
using Our Site.

Definitions

In this Policy, the following terms shall have the following meanings:

“Cookie”	means a small text file placed on Your computer or device by Our Site when You visit certain parts of Our Site and/or when You use certain features of Our Site;
“GDPR”	means EU Regulation 2016/679 – the General Data Protection Regulation;
“personal data”	means any and all data that relates to You as an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that You give to Us via Our Site or that We collect via Our Site. This definition shall, where applicable, incorporate the definitions provided in the GDPR;
“controller”, “data subject”, and “processing”	shall have the same meaning as in the GDPR;
“We/Us/Our”	means the company described in the “Information About Us” section above;
“Our Site”	means this site: https://thunderspin.com/;
“You/Your”	means You, the individual using Our Site;