Privacy Policy

This privacy policy (the “Policy”) explains how the KayaStudio OÜ, reg.number 16620779, registered under the law of Estonian Republic (“Service Provider”, “we” or “us”) collects and uses information when you use any of the services located on our website at https://www.manuelamitevova.com/ (the “Website”) or if you use any other services (the “Services”) that we provide to you. The present Policy is an integral part of Service Provider's Terms of Service and is integrated therein. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Service.

You have many rights that you can use to control your privacy. Service Provider respects those rights.

By using or interacting with the Website and/or our Services, you, as a user of our website, (“User”, “Client” or “you”) agree to the provisions of this Policy and confirm that you have read and understood all of the provisions stated in the Policy.

KayaStudio OÜ is the processor a controller of your personal data. Your KayaStudio OÜ data protection officer can be contacted at e-mail support@manuelamitevova.com.

Please take your time to read this policy and contact Service Provider if you have any questions or feedback regarding our privacy policy.

The Personal Information We Collect About Customers:

  • By using our Services and registering on our Website, you, as the Client, hereby acknowledge and give your explicit consent for the collection, processing, and use of your personal data. When you register for any Service, when you use the Services, when you visit Service Provider's pages, and when you enter Service Provider's promotions and offers, we may collect your Name and email address.

  • E-mail: If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. We may also retain any messages you send through the Services. You consent to our use of your email address to send Service-related notices, including any notices required by law. You also agree that we may send you notifications to the email address you provided about new programs, or changes to existing programs.

  • Social Media: Service Provider may be accessible through social media applications like Facebook, Instagram or YouTube, or use features associated with social media, such as the Facebook Like button and “share this” button. Your interactions with any social media platform are governed by the privacy policies of the companies providing them.

The Automatic Information We Collect:

  • Website browsing statistics

Service Provider is constantly improving its website and aims to make using it as easy as possible. For this purpose, Service Provider needs to know what information is most relevant to website visitors, how often they connect, what browser and device they use, what content is mostly read, what region visitors come from, and similar demographics and statistics.

Service Provider collects this information by using an automated tool called Google Analytics. This allows Service Provider to record and analyse how visitors use the website.

You can learn more about how Google Analytics works and the information it allows us to collect and analyse here - https://support.google.com/analytics/answer/1012034?hl=lten&ref_topic=6157800

Service Provider uses this data on the basis of our legitimate interest as a business in improving our understanding of client needs and preferences in order to constantly enhance our services and improve client access to information that Service Provider publishes.

You may at any time disable collection of your data by Google Analytics, as described here - https://tools.google.com/dlpage/gaoptout/.

  • Cookies

What are cookies?

Cookies are files with a small amount of data that a website saves on your computer or mobile device when you visit the site, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. A cookie enables the website to remember your actions and preferences ‒ such as login, language, font size and other display preferences ‒ over a period, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

How does a Service Provider use cookies?

The Service Provider website uses cookies to collect your IP address and browsing information, such as the websites you have visited or the time you have spent on each page, and allows the Website to remember your system and preferences.

Other cookies allow Service Provider  to track website traffic and users’ interaction with the website – Service Provider  uses this data to analyse visitors’ behavior and to improve visitors’ experience. These cookies are placed and used by the Google Analytics tool.

Cookies are placed on your device only if you consent, unless cookies are required for strictly technical functioning of the website. However, note that if you do not consent to the use of cookies, certain functions of the website may not function properly or may not function at all.

The legal basis for the use of cookies is Service Provider’s legitimate interest in ensuring the technical functionality of the website. When cookies are used to remember your choices or for statistical purposes, the legal basis is your consent.

How to control cookies?

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. However, if you do this you may have to manually adjust some preferences every time you visit a site, while some services and functionalities may not work.

  • Logs

The server that hosts the Service Provider website may also record requests you make to the server, such as the web address you open, the device and browser you use, your IP address, date and time of access. This data is used only for technical purposes – that is, to ensure the proper functioning and security of the website and to investigate possible security incidents.

The basis for collecting and using such data is Service Provider ’s legitimate interest in ensuring the technical availability and security of the Service Provider  website.

How We Use or Store Your Information:

The personal data collected will be used solely for the purposes described in these documents, which may include, but are not limited to, providing and improving our Services, communicating with you, and fulfilling any legal or regulatory requirements. The Service Provider undertakes to process this Data in strict compliance with laws regulating Data protection and exclusively for the provision of services as outlined herein. The Service Provider uses your data only:

● to provide our Services, to create and manage your user accounts and to allow you to provide feedback. If you wish to stop receiving information from us and to terminate the registration process, you could contact us by phone, chat or email or to press the “unsubscribe” button in case of e-mail legal ground: legitimate interest);

● To provide you with access to the relevant parts of the Website (legal ground: legitimate interest);

● To provide you with the services you have requested, that is, provide the offer for the order (legal ground: legitimate interest);

● to allow payment for ordered services

● to create, maintain and administer the account to use the Website;

● to provide technical and operational application support to facilitate the use of the Website;

● to forward information relating to complaints, in particular compensation claims, in

connection with a Services;

● improve the efficiency and quality of service that our customers can expect from us in the future;

● enable our customer support team to assist you as efficiently as possible if you have questions or complaints;

● customize the content that we, our catering or advertising partners offer. For example, to offer restaurants in your area or to make sure that you see the most relevant advertising for you, based on the characteristics we have defined;

● to contact you to know your opinions and comments on our services and to inform you in case of important changes or developments of our Website or our services (inform you that our services are proposed in a new zone, if you asked to be informed);

● to enforce the contract binding us and any other agreement, to be able to exercise or defend us from complaints and protect the rights of Service Provider, partners or others (including the prevention of fraud).

Who may access your data

  • Statistical data about Service Provider visitors may be accessed by employees in our marketing and IT departments or our business partners who are responsible for analysing that data and for improving our website.

Service Provider partners who provide us with website content management tools or who host the Service Provider  website may have access to technical log files.

The Google Analytics tool provided by Google Inc. (a US company) has access to statistical data collected by that tool. Google Inc has subscribed to the EU-US Privacy Shield principles EU – US Privacy Shield list, which confirms that what we have provided complies with mandatory EU privacy standards. Contractual obligations to ensure privacy are also applied to this provider, which you may read here: https://www.google.com/analytics/terms/dpa/dataprocessingamendment_20160909.html

  • Promotions and Advertisements: Service Provider displays targeted advertisements based on personal information. Advertisers (including advertisement serving companies) may assume that people who interact with, view, or click targeted ads meet the targeting criteria. Service Provider does not provide any personal information to the advertiser when you interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will make the assumption that you meet the targeting criteria used to display the ad. Please consult the respective privacy policies of such advertisers.

  • E-mail and ActiveCampaign: ActiveCampaign may view your information when helping Service Provider with technical support regarding e-mail Services, which includes your name and e-mail. ActiveCampaign does not have access to any private e-mails sent between you, and Service Provider. ActiveCampaign will never contact you about Services, promotions or technical support issues. Please consult the ActiveCampaign privacy policy for more information on their practices.

  • Your Consent: Any personal information or content that you voluntarily disclose for posting to the Service becomes available to the public, as controlled by any applicable privacy settings. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other users have copied or saved that information.

  • Business Partners: We may use information about you in partnership with outside companies in the course of providing you with additional services related to Service Provider. When you choose to participate in rewards programs, contests, discount offers, or other programs that involve third parties, you authorize Service Provider to share your personal information with those parties. By sharing this information, you agree that Service Provider is not liable or responsible for the actions or inactions of third parties.

  • Legally Required: Except as otherwise described in this Privacy Policy, Service Provider will not disclose personal information to any third party unless required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Service, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations; (c) to assist government enforcement agencies, or to protect the security or integrity of our site; and (d) to exercise or protect the rights, property, or personal safety of Service Provider, our users or others.

Children’s Online Privacy Protection Act Notices:

  • Prohibition of Disclosure of Information: Children under 13 are not permitted to disclose any personally identifying information in relation to any Service. This means that children may not register for any of The Website product or service.

  • Filtering Notices: There are commercially available services and software that limit access to objectionable information.

The transfer of your Personal Data to third parties

The information we collect about you will be transferred and stored on our servers located in the EU. We may transfer your data to the other service provider only in case of providing Services described and/or ordered on Website. We are very cautious and transparent about who your information is shared with.

We will share your Data with third parties in these cases:

● Outsourced accounting and payment service providers (online payment service providers and fraud detection service providers): to provide us with their services.

For example, when they process information such as credit card payments for us, when they provide you with support services or when they carry out anti-fraud checks on our behalf;

● IT & software service providers (cloud service providers, CRM software): for data storage, backups and analysis purposes;

● Customer Support Partners, who will help us resolve any issues you may have regarding our services, and

● marketing and advertising partners: they will make sure you see ads that are more tailored to your needs and send you marketing emails on our behalf.

Service Provider could share the Data internally within our company and its offices when it is necessary for the provision of services.

Service Provider will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy when it is disclosed to third parties.

We can also share your information:

● if we are required to disclose or share your information in order to comply (and / or if we believe that is the case) with such regulatory requirements or requirements. This includes exchanging information with other companies and organizations for fraud protection and detection purposes;

● to enforce our contractual terms with you and any other policies or agreements;

● to protect the rights of the undertaking with which Service Provider is tied with contractual relations, or Service Provider itself to prevent criminal or any other activity against the laws, and

● with third parties whose participation we believe is necessary to detect or prevent crime, for example with the police.

We have ensured that all third-party service providers to whom we transfer your Personal Data will follow our instructions with respect to how they process your Personal Data. The transfer of your Personal Data is regulated by the data processing agreements or data processing terms that exist between us and third-party service providers. Any third-party service providers – as the data processors, must ensure that they process your Personal Data with the same level of care and diligence as we do and are legally liable to you and to us if the data processors act contrary to those warranties. Furthermore, these third-party service providers are required to implement technical and organizational measures to ensure an equal level of data protection to the one that we bring to our data processing efforts.

How long does Service Provider store data?

The personal data provided to the Service Provider and indicated in the Section 1 above of this Policy will be kept for as long as you maintain an account with our Website or use our Services. When you delete your account or upon your request, we will remove your personal information from our system within 3 months. After this period, we will retain only anonymous information for statistical and analytical purposes.

The Data will be anonymised in order to make it impossible to "re-identify" the personality of the owner of the data, such that the data are no longer personal within the meaning of the laws regulating personal data protection.

As an exception, the Data may be retained for longer durations in intermediate archiving

to the extent, in particular, that:

● there is a legal or regulatory obligation to retain the Data for a fixed duration;

● The Data is of interest, particularly in the event of litigation, justifying it’s retention for the periods set forth by applicable rules relating to limitation periods/lapse of rights (for example, in civil, commercial, criminal, accounting and tax matters) or until the end of the proceedings initiated

Service Proider uses collected statistical data for analysis for up to three years.

Cookies are usually valid for a short term (a day, a week or a month), though in some cases they may remain valid for up to a year.

We primarily store and process Personal Data within the European Union. Nevertheless, it may at times be necessary that your Personal Data is transferred to and stored at a destination outside the European Union. It may also be processed by data processors operating outside the EU. By submitting your Personal Data to us or by consenting to the processing of your Personal Data you agree to the processing of your data, including both data storage and data transfer, outside the EU for the purposes set out in this Policy.

Your rights and how you may exercise them

By contacting Service Provider via e-mail at support@manuelamitevova.com, you may exercise your right:

  • to require access to your personal data:

You have the right to request access to any data that can be considered your Personal Data. This includes e.g. the right to be informed on whether we process your Personal data, what Personal Data categories are being processed by us, and the purpose of our data processing.

  • to require rectification of your personal data:

You have the right to request that we correct any of your Personal Data if you believe that it is inaccurate or incomplete.

  • to require erasure of your personal data:

You may also request that your Personal Data be erased if the Personal Data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that the Personal Data has to be erased to enable us to comply with a legal requirement.

  • to data portability: 

If your Personal Data have is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you that Personal Data in a structured, commonly used and machine-readable format. Moreover, you may also request that the Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible.

  • to withdraw consent to processing of your personal data, where applicable:

In cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time.

In some cases, you may have a right to request a restriction on processing your personal data or to object to processing of your personal data.

You may exercise your rights in line with the requirements of applicable EU and local laws.

If personal data is erased at your request, Service Provider will only retain such copies of the information as are necessary to protect our or third party legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with Service Provider .

You may disable cookies by your browser settings, or by visiting here:

https://tools.google.com/dlpage/gaoptout/

How To Unsubscribe or Modify Your Information:

At any given moment, you can edit your account information or unsubscribe from future e-mails or any correspondences whatsoever by emailing us at support@manuelamitevova.com

  • Right to lodge a complaint

If you think your privacy rights have been breached, you may lodge a complaint with an authority of the EU country of your habitual residence. Contact information for these authorities can be accessed at  http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Links To Other Sites

Our Website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Miscellaneous

  • Notification Procedures: It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on the Services, as determined by The Website in its sole discretion. We reserve the right to determine the form and means of providing notifications to you.

  • Changes to Our Privacy Policy: Service Provider may update this policy at any time. We will notify you about significant changes in the way we treat personal information by placing a prominent notice on our website. Changes to this Privacy Policy are effective when they are posted on this page.

  • This Privacy is governed by “GDPR” (Regulation 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, and repealing Directive 95/46/EC) and legislation of the Estonian Republic.

  • Questions or Comments: If you have any questions or comments about this policy, please contact us at the information below:

Service Provider

support@manuelamitevova.com

Last update of this privacy policy: 10.11.2023