Privacy Policy

PRIVACY POLICY

 

Lalafo takes care of all its Users’ privacy. For this purpose, Lalafo collects and uses personal information only to the extent necessary to provide its Users with the services, websites, and mobile applications (collectively, “the Service”).

This Privacy Policy shall establish the procedure of receipt, storage, processing, usage, disclosure and protection of User’s personal data.

This Privacy Policy shall constitute an integral part of the Service User agreement http://lalafo.pl/.

Personal data Controller shall be Private limited company Yalla Classifieds (YALLA CLASSIFIEDS OÜ), address: Pärnu Road 22, 10141 Tallinn, Estonia.

By using the Service, the User fully accepts this Privacy Policy.

 

1.         Data collection

1.1.      Personal data means information, which can be used to identify a natural person directly or indirectly. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.

1.2.      The User shall provide information and personal data when filling out the form to publish Advertisement, or during registration to the Service, or when subscribing to receive messages, as well as in other cases of using the Service. Information may also be collected during surveys of the Service Users.

1.3.      The Service will collect the following information about Users:

1.3.1.   Personal information, which represents input by the User, shown or revealed in any other way by him/her to the Service when using the Service. Such information can include:

- the User’s name and surname (company name),

- email address and password,

- phone number,

- location, as well as

- address.

The User needs to provide this information to enable the Service to provide User with the services and to provide access to the Service and the means for Users.

The Administration may also verify Users with the help of personal data.

In this case, the Administration may request all data relating to the User necessary to verify and eliminate fraud, including, for example, the name, surname and email address assigned by the Account, residential address, PESEL number, data of the User's personal documents.

1.3.2.   Technical information, which is automatically collected by the Service when the Service is visited. The Service collects information from the device and from the application that Users use to access the services. Typically, this is information about:

- User’s IP address,

- operating system version,

- device type,

- system and performance,

- and the type of browser.

If the User accesses the Service from a mobile device, the Service also gets a universal unique identifier (UUID) for such device. The Service may combine this information obtained from the User’s browser or mobile device with other information about the User that the Service or its partners collect, including information collected from several devices.

1.3.3.   When the User logs in using another service profile (for example, Facebook, Google+etc.), the Service may also collect information located in the relevant profile of such service that the User has agreed to make available, including the User’s name, email address, and profile-related information. The User agrees to share this data with the Service during the registration process. This permission can be revoked at any time by sending an appropriate request to the Service.

1.3.4.   The Service may collect information regarding the physical location of the User’s device. The individual User’s location may be determined through the IP or Geo-location information obtained from the User’s device. The Service can use and store the User’s location information to provide functions and improve and customize services, for example, for internal analytics and performance monitoring or for showing content or provide offers relevant to the User’s location.

1.3.5.   The Service uses “cookies” and similar technologies on its websites. More information about cookies is provided in the “Cookies, Web Beacons, and Similar Technologies” section https://lalafo.pl/en/page/cookie-policy.

1.3.6.   Communication via chat on our Service

When you use chat to communicate with other users, we may collect the content of the message and the information you provide through this feature.

1.3.7.   Telephone communication and correspondence

When you contact us by phone or email, we collect all the information that you choose to provide in the course of a conversation or during correspondence with our employees or representatives. Please note that in the case of telephone contacts, all conversations are recorded. If you object to the recording of telephone conversations, the conversation will not continue and you will be able to use other available forms of communication.

1.3.8.   Establishing contact with us, including when you are a guest

If you use our website and provide us with data to contact you, or you contact us yourself, we collect the data that you provide to us through all types of contact forms, requesting an offer or contacting us.

1.3.9.   The data provided by the User in connection with his/her participation in contests and surveys conducted by the Service or by other third parties at the request of the Service.

1.3.10. The Service receives information about Users and their activities from marketers, partners, researchers, and other sources (including publicly available databases). The Service may combine information that is collected from the User with information obtained from other Users and third parties.

1.4.      The Service will not collect or process any “Special categories of data”, for example, the data about racial or ethnic origin, political, religious and ideological beliefs, membership in political parties and professional unions, criminal history, as well as data concerning health, sex life, biometrical or genetic data.

1.5.      The Service does not collect, store, or in any other way process data on the User's bank accounts, data on his/her bank (payment) cards and other financial information under the jurisdiction of the User, banks and payment systems. Collection and processing of such personal data of the User (including data on the User's bank accounts, his/her bank (payment) cards) shall be governed by the privacy policies of the payment service providers, but not by this User Agreement.

1.6.      Service is not intended for children under the age of 16, and we do not knowingly collect information about them. If we discover that a person under the age of 16 has provided us with personal data, we will delete it immediately.

1.7.      Please note that any information posted by the User on the Service (e.g.  User’s name and publicly available photos, etc.) could become public and may be available to other Users and the general public. The Service urges Users to be very careful when deciding what information to disclose through the Service. Personal information posted by Users or disclosed by them to other Users may be collected by other Users and may result in unsolicited messages. The Service is not responsible for protecting the information that the User may disclose to third parties through the Service.

1.8.      In order to facilitate interaction between the Users, the services shall imply restricted access to the contact information of other Users. The User Agreement shall restrict the right to use information provided by other Users.

1.9.      Identification (Authentication) of the User

  Since, according to the terms of the User Agreement, the Recipient of the goods can be a citizen of Ukraine, who was forced to leave their place of residence in Ukraine (refugee, etc.), due to the results of an open military attack committed by the Russian Federation and is currently located in Poland, as well as an individual who has the sufficient legal capacity to accept the Terms of the User Agreement and fulfil all obligations emanating herefrom. The Administration took it upon itself to verify the identity of the Recipient of goods for the compliance of data entered by the individual, within the possibilities determined by the Administration.

            In addition, the identification of the User is necessary for appropriate effectuation of the agreement between the Administration and the User, in particular to avoid duplication of User accounts, and to assure the fulfilment of the terms of the Agreement  regarding the limits on the goods available to a User, as determined by the rules of the Service.

            The verification of the User identity can be carried out, in particular, using the electronic authentication of the User in the electronic authentication service of the integrated electronic identification system (Bank ID, https://diia.gov.ua/ etc).

            In the process of identification, the User may be asked by to provide the following information:

            -  Identification number of Ukrainian citizen

            -  Full Name (First, Last and Middle name)

            -  Age of the User

            -  Other information, in accordance with the requirements of the authentication system or/and conditions, purposes and needs of the Administration to fulfil its obligations under the Agreement.

            When requesting personal data, any of the authentication systems warns the User about the requested data, in accordance with the rules of such system, and requests the User’s consent for data collection. 

            The Administration may store the User’s  identification number for some time (during the period of fulfilment of the agreement and obligations), in which case the identification number will be stored as encoded file and will not be shared with any Third Party. This information is required for aforementioned purposes.

            Any other information will not be stored by the Administration.

            In this regard, the Administration holds a right to request personal information, and the User agrees to provide their personal information in the way and for the purposes described in this clause.

 

2.         Processing purposes

2.1.      The Service will only use your personal information as required by law.

2.2.      Processing of the personal data is any action or combination of actions, such as collection, registration, accumulation, storage, adaptation, alteration, use, distribution (sale, transfer, including transfer abroad), and deletion of the personal data, including application of informational (automated) systems.

2.3.      The Service uses the personal information collected from Users for a range of different business purposes and according to different lawful bases of processing.

The Service may use the information collected from the Users as follows:

2.3.1. To conclude and perform the agreement, as well as to provide and improve its services. The collection of certain data is necessary for the Service to fulfil its contractual obligations under the User Agreement (the provision of services by the Administration under the User Agreement), ensure the implementation of the User Agreement, this Privacy Policy or other policies.

For example, the Service uses the names and phone numbers that its Users provide in their accounts for other Users to identify them and communicate with each other.

If the User logs in with his/her mobile phone number or email ID, the Service will use User`s name, mobile phone number or email address to identify him/her as a User and provide him/her with access to the Service.

If the User logs in with his/her Facebook or Google account, the Service will use his/her name and email address from Facebook profile or Google account, as well as the URL of profile picture, to identify the User and provide the User with the Service access.

In case of verifying the User with personal data, the Administration may request all data relating to the User necessary to verify and eliminate fraud, including, for example, the name, surname and email address assigned by the Account, residential address, PESEL number, data of the User's personal documents. User verification is required, in particular, but not exclusively, for the purposes to fulfil Administration`s contractual obligations in accordance with the User agreement, for example, to verify that the Recipient of the goods (the User) is the person as it described in the section “General terms and conditions” of the User Agreement.

The Service also may use the User’s information to improve, fix, and customize its services and to pursue the Service’s legitimate interests of improving the services for the Users. The Service is always looking for ways to make the services smarter, faster, secure, integrated, and useful for the Users;

For example, the Administration may use User`s activity data to offer him/her better search results when her/he uses the Service.

Or by determining the User`s duration of navigation on the Service and in order to learn about User`s interests and to improve the services the Service may offer the User other interesting content.

Or with the help of location and for a better experience, the Service may display listings of advertisements from User`s area.Or based on User`s information the Service can recognize the various devices (e.g. desktop, mobile phone, tablet) that used by the User to access the Service. This allows Administration to match the User`s activity on the Service across all devices and also helps to improve the services so that the services can be provided equally conveniently regardless of which device the User uses.

The Service may use the photos, descriptions and other information to train machine learning models, for example, to personalize search results in relation to User interests, and improve search function. This will help to improve the Service and provide a better User experience.

The Service accesses and analyzes User`s chat messages with other Users using the chat feature in the Services in order to improve the product and provide a better User experience. But in these cases, the access provides only to a few machine learning experts who parse chat content. During the analysis process, all identification data in chat is removed. However, there may be instances beyond our control where chat content may contain certain personally identifiable information that the User chooses to provide.

2.3.2    To manage the Users’ accounts and provide them with user support. The Service may use Users’ information to resolve technical issues, to respond to Users’ requests for assistance, to analyse technical failure information, and to repair it.

This is necessary in order to fulfill the agreement by the Administration and provide access to a safe and efficient Service, as well as for the purposes of the legitimate interests of the Administration, in particular, to improve the services of the Service.

2.3.3.   To develop, display, send, and track content and advertising adapted to the interests of Users in relation to the Service. The Service uses contact information and information about how Users use the Service to send notifications that may be of specific interest to the Users. These notifications are aimed at driving engagement and maximizing the benefits derived by the Users from the Service, including information about new features, newsletters, and events that may potentially be of interest to the Users. The Service also communicates with the Users about new product offers, promotions, and contests. The Service may communicate with the Users by e-mail, post, phone and/or mobile devices. The User can control these notifications and have the right to withdraw his/her consent at any time.

The Service uses the User`s email address and mobile phone number to send offers and recommendations regarding Service that may be of interest to the User. The aforementioned information is processed for the proper performance of the contract you have entered into with us and on the basis of a legitimate interest in the event that we carry out marketing activities to offer you Services.

The Service may use browsing data to monitor campaign performance and provide reports to our business partners, as well as for internal business analysis.

Location data may be used to measure and track the User`s interactions with third-party banner ads that placed on the Service.

The Service processes the above information on the basis of legitimate interest in conducting marketing activities in order to offer the User services that may be of interest to him/her.

Every User could ask the Administration to stop sending marketing messages at any time by clicking on the unsubscribe link in an email or by changing account settings.

2.3.4.   To comply with legal, regulatory and law enforcement requests and protect the Service’s legitimate interests and rights. The Service cooperates with government and law enforcement officials and private parties to enforce the law. The Service shall disclose any information about the Users according to legal requirements where it is necessary to protect the Service’s legal rights and interests and/or legal rights and interests of third parties or to prevent or stop illegal activity.

The Service also uses information to restrict or prevent various forms of abuse of the services, such as fraud, spamming, and other unauthorized actions that violate the User agreement.

Where required by the law, the Service may use the information in connection with legal and audit activities, for example, for the purpose of acquisition, merger or sale of its business.

To the legally permitted extent, the Service will take reasonable steps to notify the Users about provision of personal information to third parties.

2.3.5.   Website analytics. The Service uses multiple web analytic tools (or tracking-tools) provided by third-party service providers such as Google Analytics to collect information about how Users interact with the Service. The Service conducts research and analysis of the User’s use of the Service or the interests of the User in products, services, and content. The Service uses the information provided by these tools to improve services and to detect and analyze errors. Such service providers’ tools place cookies in Users’ browsers. Cookies cannot be used by anyone other than third-party service providers. The information collected using cookies may be transmitted to and stored on servers in a country other than the User’s country. Information collected is used and shared by these service providers in accordance with their individual privacy policies. Users are free to opt-in to collection and processing of the data generated by the cookies in connection with the use of the Service.

2.3.6.   To conduct contests or surveys. The Service uses the information collected through these methods, for example, to improve the services.

The Administration may provide you with User surveys to measure your overall satisfaction with the Service. Moreover, the User can voluntarily provide the Administration with her/his contact details, such as email address and mobile phone number, so that the Administration can contact the User and invite him/her for UX test or for interview with the Service’s experts. Information the User provide to Administration when answering the questionnaire may include personal data that User provides voluntarily.

2.3.7. To fulfil obligations under tax legislation. When required by a law and/or provided that the Users pay for the Administration's services, the Administration may collect Users' data in order to fulfil obligations under a tax law or civil law - according to Article 6(1)(c) of GDPR (processing is necessary for the Controller to comply with a legal obligation);

 

3.         Sharing and disclosure of information

3.1.      The Service may share and disclose the User’s information to third-party service providers that provide services to the Service, namely, website hosting, data analysis, information technology and related infrastructure provision, email and messages (notifications) delivery, auditing, services that assist the Service in providing customised advertising and service providers for the management of service desk, support data and CRM systems. These Services help the Service to provide services (for example, they can assist the Service in providing customised advertising or they can assist the Service with the prevention, detection, mitigation, and investigation of potentially illegal acts). These service providers will only have access to the information necessary to perform the relevant functions. These third parties are obligated not to disclose or use User’s information for other purposes. In some cases, these service providers are not strictly required to provide the services for the Service, but they help to make the Service better. Cooperation with third-party service providers with the aim to make the services better is the Service’s legitimate interest (to ensure the adequate performance of the contract with the User).

For example, the Service uses Google Analytics to monitor and analyze the use of the Service. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. The User can opt-out of having made his/her activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

The Service also uses the online advertisement services to display advertisement Google Adsense and DoubleClick for Publishers. The User can find more information on the privacy practices of Google here: https://policies.google.com/privacy?hl=en and here: https://business.safety.google/privacy/.

3.2.      The Service may transfer portions of the Users’ information outside of the User`s country of residence. For example, personal data stores on servers located in Germany. The Service has established legal mechanisms to ensure that Users’ rights are protected irrespective of such transfers.

If personal data is transferred to a third country (i.e. a country outside the Europe Union or the European Economic Area), the transmission of data will be governed by the principles of the Privacy Shield (https://www.privacyshield.gov/welcome) or will be performed on the basis of the standard contractual clauses established by the European Commission (http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm and https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).

3.3.      The Service may share the Users’ information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside the User’s country of residence, to comply with legal, regulatory, and law enforcement requests and protect the Service’s legitimate interests and rights.

For example, the Service may disclose the User`s personal data in the good faith belief that such action is necessary to:

3.3.1.   To comply with a legal obligation

3.3.2.   To protect and defend the rights or property of The Service

3.3.3.   To prevent or investigate possible wrongdoing in connection with the Service

3.3.4.   To protect the personal safety of users of the Service or the public

3.3.5.   To protect against legal liability

3.4.      The User`s consent to this Privacy Policy followed by his/her submission of such information represents the User`s agreement to that transfers.

Nevertheless, if necessary, the Service may ask for User`s consent to share/disclose his/her information. In any such case, the Service will provide a full explanation why and what information the Service needs to share/disclose.

3.5.       In some cases, when it is determined by a law and/or agreement, Suppliers may collect Users' personal data. In certain cases, the Service may act as an intermediary in the transfer of such data, but the Administration does not use or store such User data in any way. The User, as a payer who orders a payment transaction, confirms that he/she authorizes the Administration to transfer the User's (payer's) data to the Supplier, which accompany such transaction.

          The Supplier may process personal data for the purpose of:

3.5.1. signing a contract between the User and the Administrator and its performance - in accordance with Article 6(1)(b) of GDPR (processing is necessary for signing and performing the contract);

3.5.2. complying with obligations under a tax law or civil law - in accordance with Article 6(1)(c) of GDPR (processing is necessary for the Controller to comply with a legal obligation);

3.5.3. establishing claims, pursuing them or defending in accordance with Article 6(1)(f) of GDPR (processing is necessary for purposes arising from the legitimate interests of the Supplier as controller, which in this case is the ability to effectively establish, consider claims or defend against them);

3.5.4. in other cases, provided for by the Privacy Policy of the corresponding Supplier.

          Recipients of the User's personal data may also be third parties cooperating with the Supplier including:

          а) a company that provides accounting services to the Supplier-Controller;

          b) a company that provides data hosting services to the Supplier-Controller;

          c) other third parties that the Supplier Controller has a legal obligation to provide data to.

          The Supplier undertakes to post the Privacy Policy on the Service page or provide access to them to Users.         

For all issues related to the processing of personal data by the Supplier-Controller, you should refer to the Supplier using the contact details specified in the Privacy Policy of such Supplier.

 

4.         Data protection

The Controller shall take all reasonable technical and organisational measures to protect personal data of the User from unauthorised access by third parties.

The Service conducts review of candidates at the time of hire or before entering into a contract with independent contractors (to the extent permitted or facilitated by applicable laws and countries). Also, signed non-disclosure agreements. The Service provides ongoing privacy and security training.

All personal data collected and processed by the Service shall be stored on one of the several protected servers. There shall be no access to such servers outside the corporate network or contractors that signed the Non-disclose agreement.

Nevertheless, while the Service implements safeguards designed to protect the Users’ information, no security system is impenetrable and the Service cannot guarantee that data, during transmission through the Internet or while stored on servers or systems owned by the Service, will be absolutely safe from intrusion by third parties.

 

5.         Legal rights

5.1.      The Service will honour any statutory right the User might have to access, modify or erase his/her personal information.

5.2.      Every User has account settings that help him/her access, rectify or delete information that the User provides to the Service. User can change his/her settings on their devices to either consent or oppose the collection of the personal information or display of the corresponding notifications.

5.3.      Mobile applications have permission systems for specific types of device data and notifications such as location as well as push notifications. Please note that certain services may lose full functionality because of deactivation of certain functions.

5.4.      User can contact the support of the Service ([email protected]) with any questions regarding these settings.

5.5.      According to applicable laws, the Users have the following rights (inter alia):

5.5.1.   to request access to the User`s personal data. This enables the User to receive a copy of the User`s personal data stores by the Service and to check that the Service is lawfully processing it.

5.5.2.   to request correction of the User`s personal data. This means the User can correct any incomplete or inaccurate data. Please note that the Service may need to verify the accuracy of the new data.

5.5.3.   to request erasure of the User`s personal data. The User can ask the Service to delete or remove personal data where there is no good reason for the Service continuing to process it. The User also have the right to ask the Service to delete or remove the User`s personal data, where the Service may have processed personal data unlawfully or where the Service is required to erase personal data to comply with local law.

5.5.4.   to object to the processing of the User`s personal data (for example, when the personal data is processing for direct marketing purposes). In some cases, the Service may demonstrate that the Service has compelling legitimate grounds to process information which override the User`s rights and freedoms.

5.5.5.   to request restriction of processing of the User`s personal data. The User have the right to obtain from the Service restriction of processing where one of the following applies:

(a) the accuracy of the personal data is contested by the User, for a period enabling the Service to verify the accuracy of the personal data;

(b) the processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead;

(c) the Service no longer needs the personal data for the purposes of the processing, but they are required by the User for the establishment, exercise or defence of legal claims;

(d) the User has objected to processing pending the verification whether the legitimate grounds of the Service override those of the User.

5.5.6.   to request the transfer of the User`s personal data to the User or to a third party. The Service will provide to the User, or to a third party the User`s personal data in a commonly used machine-readable format.

5.5.7.   to withdraw consent at any time where the Service is relying on consent to process the User`s personal data. However, this will not affect the lawfulness of any processing carried out before the User withdraw his/her consent. If the User withdraws his/her consent, the Service may not be able to provide certain products or services to the User.

5.6.      Please note that the Service may reject requests for certain reasons, including if the request is unlawful or if it may violate the rights of another User or a third party.

5.7.      In certain countries, the Users have the right to lodge complaints with the appropriate data protection authorities if they have concerns about how their personal data are processed.

Chairman of the Office for the Protection of Personal Data in Poland (address: Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193, Warszawa).

Estonian Data Protection Inspectorate, address 39 Tatari St., 10134 Tallinn, Estonia, e-mail [email protected], website https://www.aki.ee/.

 

6.         Messages and Notifications

Occasionally, the Service may need to contact the User. These messages can be delivered by email, by push notifications or by telephone for the purposes of provision of the Users with support or for other purposes (for example, provide the Users with information regarding products and features that Users may find interesting). These notifications could be sent with prior consent of the User or in response to the Users’ requests. The User may control marketing emails and/or messages through his/her account settings as well as through the opt-out link included in the marketing emails or messages.

If the User give his/her consent to receive notifications, he/her confirms that the Service shall have the right to provide User`s email addresses and phone numbers to third parties in order to deliver notifications and messages to the User.

In this case, the User understands, accepts and agrees that such letters and messages may be, but are not limited to: proposals to enter into an agreement with other Users, proposals and communications of other informational and / or advertising nature and other communications. The User understands, accepts and agrees that such messages and / or parts thereof may be of an advertising nature and may contain advertising, information and other advertisements.

Some messages may be published on the Service (for example, messages from other Users with propositions to buy/sell or certain Service’s messages). Advertisements published on the Service shall be deemed delivered to the User once they are published.

Some messages are service-related and necessary to provide services by the Service and/or performance of the User agreement (non-marketing messages, for example, emails related to the Users’ accounts, security-related notifications, etc.). The User agrees that such messages can be sent to him/her.

The Service shall bear no liability for the use of the message sending form placed on the Service by other Users and/or automated systems (robots).

The Service shall bear no liability for the use of the phone numbers and electronic addresses placed by the User on the Service pages by other Users and/or robots.

 

7.         Access to and deletion of the User`s information

The User can exercise his/her rights to access, change or delete his/her personal information at any time.

In order to easily access, view or update personal data (where available) or to update subscription preferences, the User should enter his/her account and visit the “Account Settings” section.

The User is entitled to request the deletion of his/her account without providing any reasons therefor. If the User wishes to erase his/her account or data or if the User decides to revoke his/her consent to this Privacy Policy, the User may send a request to the following e-mail address: [email protected] (https://lalafo.pl/en/page/user-data-deletion).

Please note that the Service will not be able to provide access to the services if the User revokes his/her consent. Also, the Service will not be able to provide certain services if the User deletes his/her account/data.

In order to ensure the Users’ protection, support managers of the Service may only respond to requests for personal information sent from the email addresses the Users use to send requests, and the Service may need to verify the relevant User`s identity before implementing his/her request. The Service will try to comply with the User`s request as soon as possible, but it may require some time.

 

8.         Data retention

The Service keeps the Users’ information only as long as needed for legitimate business purposes and as permitted by applicable legal requirements.

If the User closes his/her account, the Service will retain certain data for analytical purposes and recordkeeping as well as to prevent fraud, enforce User agreement, or if there is an outstanding issue, claim or dispute requiring the Service to keep the relevant information until it is resolved or if the Service must keep it to evidence the Service`s compliance with applicable law (for example, records of consents to Privacy Policy).

Personal data is deleted or anonymized on a regular basis when it is no longer relevant for the purposes, for which it has been collected.

Retention of personal data that is provided to third parties as described in this Privacy Policy will be subject to those third parties’ privacy policies.

 

9.         Final provisions

9.1.      The User shall bear liability for the accuracy and reliability of any information and data provided by him/her.

9.2.     The services are not designed for individuals under the age of eighteen (18). The Service will not knowingly collect personal information from children under 18 if they use the Service.

9.3.      The Controller may introduce amendments, delete or renew the rules of the Privacy Policy. The Service will announce any material changes to this Privacy Policy by sending a message and/or via email.

9.4.      If the User has any questions or complaints, he/she may contact the support by email:

            [email protected]

            or by sending a letter to the following address:

            Pärnu Road 22, 10141 Tallinn, Estonia.

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