Effective Date: 09.09.2022
Current version is available at: https://sotaplus.me/legal/privacy/
Please note that your using any of the Sites and/or Services may be subject to additional terms and conditions, which may amend and/or supplement this Policy and (or) include specific privacy terms in relevant parts of legal documents for such Sites and/or Services.
2. Who processes your personal information
To provide you with access to the Sites and Services, your Personal information is collected and used by SOTA PLUS LLC or its affiliates for particular Services or in specific jurisdictions.
3. What is the purpose of this Policy
Privacy and security of your Personal information are extremely important to us. When you use the Sites and/or Services, SOTA+ processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.
As part of our commitment to protecting your Personal information, we use this Policy to transparently inform you about the following:
- why and how your Personal information is collected and used (also, “processed”) by SOTA+ when you access the Sites or Services;
- SOTA+’s role and responsibilities in this context as the legal entity deciding why and how your Personal information is processed;
- what instruments you may use to limit the amount of Personal information collected by SOTA+;
- what your rights are in relation to the above processing.
4. What type of Personal information is collected by SOTA+
Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your SOTA+ user account or without logging in. When you are logged in to your SOTA+ user account as you are using the Sites or Services, Personal information collected by SOTA+ may be collated and combined with other Personal information (such as your identity, contact details, age and gender, if you shared this information with us) collected by SOTA+ in your user account. SOTA+ does not verify Personal information provided by you unless otherwise provided in the Terms of Service, and does not decide the its credibility or whether you have the legal capacity required. However, SOTA+ assumes that the information you provide is true, sufficiently complete and up-to-date.
Personal information collected by SOTA+ when you access, interact with or operate the Sites and/or Services includes:
- information provided by you when you register (create) a user account, such as your name, mobile phone number, address and age;
- electronic data (http headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software, wi-fi network data);
- date and time of accessing the Sites or Services;
- information related to your activity while using the Sites or Services (e.g. your search history, data on purchases in the Services, data on visited organizations, likes and preferences, email addresses of your mailing contacts, phonebook data, information about interaction with other users, as well as files and content stored in SOTA+ systems);
- (geo)location information;
- other information about you that needs to be processed according to the terms and conditions SOTA+ Site or Service;
- information about you that we may receive from our Partners in accordance with an agreement you made with this Partner and an agreement between SOTA+ and this Partner;
- your payment cards information, and other payment information, provided by you, as well as provided by Partners or other entities engaged into processing of the payment operations conducted within the SOTA+ Sites or Services or in connection with providing commercial services by SOTA+.
SOTA+ does not actively collect any sensitive personal data (such as racial origins, political opinions, health or biometric data). However, you may voluntarily provide us with such data and we may process it as part of providing you with our Services (e.g. if you perform search queries related to your health). As we do not know in advance the potentially sensitive nature of the personal data you may provide to us, you must be aware that we may not be able to request your consent with such processing.
SOTA+ does not perform any form of profiling, which has the potential to significantly impact your rights and freedoms in accordance with applicable laws.
5. What are the legal basis for processing your Personal information and the purposes of it
SOTA+ is not allowed to process your Personal information if it does not have a valid legal ground. SOTA+ will therefore only process your Personal information if:
- the processing is necessary to perform contractual obligations between you and SOTA+ such as Terms of Service for SOTA+ Services: https://sotaplus.me/legal/terms/;
- the processing is necessary to comply with our legal or regulatory obligations;
- in case it is provided by applicable law, the processing is necessary for the legitimate interests of SOTA+ and does not unduly affect your interests or fundamental rights and freedoms. Please note that when we process your Personal information on this basis, we will always seek to maintain a balance between our legitimate interest and the protection of your privacy;
- for specific purposes or if consent is required under the applicable laws and regulations, we may ask your consent for processing of your Personal information. In those jurisdictions in which consent is the legal basis, you provide such consent by agreeing to use our Sites and/or Services. We hereby inform you, and you hereby acknowledge, that you have no legal obligation to provide us with any Personal Information when you use the Sites or Services, and such provision is solely based on your free will. However, you are aware that without the provision of Personal Information, we will not be able to provide you with Services and your use of the Sites will be limited.
Examples of such ‘legitimate interests’ referred in (iii) above are:
- to better understand how you interact with our Sites and/or Services;
- to enhance, maintaining accessibility, modify, personalize or otherwise improve the Sites and Services for the benefit of all users;
- to offer you other products and services from SOTA+ or other companies which we think can be of interest to you (i.e. personally-targeted advertising).
SOTA+ always processes your Personal information for a specific purpose and only processes Personal information, which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes:
- to provide you with the Sites and/or Services;
- to provide you with access to your user account;
- to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application;
- to personalize advertisements and/or commercial offers based on your preferences, search history and other Personal information available to SOTA+;
- to improve user experience, including more personalised Sites and/or Services, as well as improving other SOTA+ products, applications and services;
- to develop new products, applications and services;
- to protect your rights and the rights of SOTA+;
- to collect, process and present statistical data or big data, or perform other research and/or analysis of Personal information;
- (ix) discovering of the security risks to the Sites and Services, users, SOTA+ and/or third parties, which also includes your integrity check in course of entering into agreements while using the Sites or Services;
- arrangement of the acceptance of your payments, processing of the payment for goods and services by you in course of using the Sites and Services.
6. How SOTA+ protects your Personal information
In most cases, Personal information is processed automatically without access to it by our staff. However, if such access is necessary, your Personal information can be accessed only by those SOTA+ employees whose professional tasks require using this information. To protect your Personal information and ensure its confidentiality, these employees must comply with internal rules and follow protocols for processing Personal information. They are also required to follow all technical and organisational security measures protecting your Personal information.
SOTA+ has also implemented adequate technical and organisational measures to protect Personal information against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information.
7. Who else has access to your Personal information and who is it shared with
SOTA+ may also transfer Personal information to third parties outside the SOTA+ to complete the purposes listed in Section 5 above. Please note that the level of protection of Personal Information in some countries may not be identical to the level in your jurisdiction and by using the Services you consent to such transfer.
Such third parties may include:
- Partners, such as media publishers, advertising networks and other partners providing SOTA+ with services related to the placement and display of advertisement on the websites, programs, products and/or services owned or operated by such Partners;
- Advertisers or other Partners serving targeted advertisement on the SOTA+ Sites or Services; and third parties who process Personal information, such as our (IT) systems providers and/or consultants;
- Entities, providing information for discovering security risks to the Sites and Services, users, SOTA+ and/or third parties, including your integrity check in course of entering into agreements while using the Sites or Services;
- Entities, involved in the arrangement of the acceptance of your payments, processing of the payment for goods and services by you in course of using the Sites and Services (international payment systems, payment products vendors, banks and other financial organizations, etc.).
SOTA+ may also transfer Personal information to the following third parties outside:
- any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
- any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;
- third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you;
- any third party to ensure legal protection for SOTA+ and/or the third parties if you violate the Terms of Service (https://sotaplus.me/legal/terms/), this Policy or if there is a threat of such violation.
8. Where your Personal information is stored and processed
SOTA+ stores Personal information in the EEA.
SOTA+ has taken appropriate measures to ensure Personal information is handled according to applicable EU data protection rules.
If you are located in a jurisdiction where transfer of your Personal Information to another jurisdiction requires your consent, then by using the Sites or Services you provide SOTA+ with your express and unambiguous consent to such transfer, storage, and/or processing of the information in other jurisdictions.
9. How long we store your Personal information
SOTA+ will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.
Unless otherwise legally required or agreed, the emails and documents, which are stored by you on our systems as part of the Service, will remain stored as long as you have an account with us, but you can delete them at any time.
10. Your rights
10.1 What are your rights
If it is provided by applicable law, you have a right of access to your Personal information as processed by SOTA+ under this Policy.
If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.
If it is provided by applicable law, you also have the right to:
- request erasure of your Personal information or certain parts of it, as well as withdraw consent to the processing of the Personal information;
- request the restriction of the processing of your Personal information;
- object to the processing of your Personal information if it is provided by applicable law.
SOTA+ will honor any such requests or objections as required under applicable law.
To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.
In case where you use the Services, the transfer of Personal Information is carried out with your consent expressing your free will and your interest, (in particular, on the ground of an agreement with you) and it is not an obligation by law.
10.2 How can you exercise your rights
To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact SOTA+ (see Section 13 hereof).
If you are not satisfied with how SOTA+ processes your Personal information, please let us know and we will investigate your concern. If you are not satisfied with SOTA+’s response, you have the right to make a complaint to the competent data protection authority.
11.1 What cookies SOTA+ uses and why
The following types of cookies are used on the Sites:
- strictly necessary cookies / technical cookies: these cookies are required to run the Sites and provide you with the Services and may, among other, allow SOTA+ to identify your hardware and software, including your browser type;
- statistical / analytic cookies: these cookies enable us to recognise users, count the number of users and collect information such as your actions on the Sites and the Services, including the web pages you visit and the content you retrieve;
- performance cookies: these cookies collect information about how users interact with our Sites and Services, enabling us to identify errors and test new functionalities to improve the performance of the Sites and the Services;
- functionality cookies: these cookies enable us to provide specific functionalities in order to improve your experience on the Sites, for example by storing your preferences (e.g. language and location);
- (third party) tracking / advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable us to display advertising which may be of interest to you based on collected Personal information. These cookies are also used for statistical and research purposes.
11.2 How long are those cookies stored on your device
SOTA+ only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.
11.3 Who else has access to the information contained in the cookies
Personal information collected through cookies placed on your device may be transmitted to and accessed by SOTA+ or the third parties referred to in Section 7 hereof. The use of Personal information outside of the Sites for advertising purposes, if any, may be subject to separate policies available on the above third parties’ websites. SOTA+ or those third parties might also provide you with a possibility to opt out of personalized advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings.
SOTA+ may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes:
- to track your actions on the Sites and when using the Services, by accessing and interacting with the cookies stored on your computer;
- to collect statistical information related to operating the Sites, the Services or products, utilities, advertisements or other SOTA+ offerings.
12. Updates to this Policy
This Policy may be subject to amendments. SOTA+ shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services.
SOTA+ undertakes not to introduce significant changes, imposing additional obligations or reducing your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the Site or Services (e.g. via a pop-up or web banner) prior to such changes taking effect, and you may also be notified via other channels (e.g. by email) if you have provided us with your contact details.
13. Questions and Suggestions
We welcome your questions or suggestions concerning implementation of or amendments to this Policy.
You can also use email firstname.lastname@example.org to exercise your rights or report any inaccuracies in your Personal information or protest its processing.