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.
Our Site is operated by Simple Software Limited, a company incorporated under the laws of Malta with registration number C89257 and registered address at Soho Offices, The Strand, Fawwara Building, Triq l-iMsida, Gzira, GZR 1401, Malta.
Our Data Protection Officer can be contacted by email at firstname.lastname@example.org or by post at Soho Offices, The Strand, Fawwara Building, Triq l-iMsida, Gzira, GZR 1401, Malta.
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:
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.
Depending upon Your use of Our Site, We may collect and process some or all of the following personal and non-personal data:
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:
|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.) ;|
|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;|
Your personal data will be primarily stored within the European Union, on servers located in Ireland, Germany and Malta, operated by premiere providers (e.g. Amazon, Hetzner). However, We may share Your personal data with certain third parties, as described below, and it can be accessed or stored by them. Some of these third parties may store Your personal data on their servers located outside the European Economic Area (“EEA”). Your personal data may also be accessed and processed by staff or agents operating outside the EEA who work for Us or for one of Our suppliers. This includes staff engaged in, among other things, the fulfilment of Your order, the processing of Your payment details and the provision of support services. By submitting Your personal data, You agree to this transfer, storing or processing.
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.
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:
You agree to Your personal data being processed by these third parties.
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.
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)||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||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||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.|
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;|