This document was last updated on September 5, 2018
1. General information
1.1 Plasma Alliance OÜ (“Company,” or “we,” or “us,” or “our”) is committed to safeguarding the privacy of our website, plasmapay.com and service users (“users” or “you”).
1.2 This policy applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of that personal data.
1.3 This Policy defines the procedure of processing and protection of information on individuals and legal entities (further – the Customers) which can be obtained by the Company when the Customers use of services and facilities provided by the website https://plasmapay.com(hereinafter – the Website).
1.4 The purpose of this Policy is a provision of appropriate protection of information about client, including personal data from illegal access and disclosure.
1.5 Relations associated with collection, storage, sharing and protection of information provided by the Customers are governed by this Policy, other official documents of the Company and the acting legislation of Estonia.
1.6 Making registration on the Website and using the services, the Customers agree with the terms of this Policy.In the case of the Customers’s disagreement with the terms of this Policy the use of the Site and/or any services and facilities available on the Site should be immediately stopped.
2. Types and Uses of Collected Information
Company collects two types of information about you:
Personally Identifiable Information. Personally Identifiable Information is information that identifies a specific person. When you engage in certain activities via the Services by creating an account for the purpose of using our Services or otherwise participating in the Services (collectively, “Identification Activities”), we may ask you to provide certain information about yourself. If you elect to engage in an Identification Activity we may ask you to provide us with certain personal information about yourself, including, but not limited to:
- Information, you provide – during registration as a Customer, we ask you to inform certain information we need to identify the party in the framework of agreements with the Company.
- Cookies – for collection of information Company can use markers cookies are small pieces of information stored by your browser on the hard drive of your computer at the request of the web site. Our Company cookies do not contain any personal information and are used as follows:
- to monitor temporary information. For example, marker cookies allow us to track what pictures you upload and download;
- to register you in special programs. Cookies allow us to remember you when you log in our Website;
- to remember your preferences concerning country and language;
- to help us understand the scope of your audience and the traffic distribution;
- to collect and record information about what you viewed on our Website and what viewed in our email latter.
- to manage of information of the Website and its presentation and to understand which images can be displayed on your computer; to present information according to your interests.
- Information about visits – when you access the Website https://plasmapay.com (and its subdomains) via a browser, application or others our servers automatically record certain information. These server logs may include information such as a web request, IP address, type and browser language, date and time of the request, and one or more cookie files, which identify your browser or your account.
- The custom message – when you send some messages (email or otherwise), we can save these messages for processing requests, answers the questions and for further development of our services. To contact you regarding our services may use your e-mail address.
Before using the information for other purpose than stated during its in collection, we will ask your permission to such use.
3. How we Obtain Information
Your information is made up of all the financial and personal information we collect and hold about you, which may include, but not be limited to:
- information you give to us;
- information that we receive from third parties, including our Affiliates;
- third parties who provide services to you or us;
- credit reference, fraud prevention or government agencies and other financial institutions (where permitted by law);
- information that we learn about you through our relationship with you and the way you operate your accounts and/or services, such as the payments made to and from your accounts;
- information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for
example pattern recognition); and
g. information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.
4. How we use your personal data
4.1 In this Section 4 we have set out:
- the general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
4.2 We may process data about your use of our website and services (\”usagedata\”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.3 We may process your account data (\”accountdata\”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.4 We may process your information included in your personal profile on our website (\”profiledata\”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.5 We may process information that you post for publication on our website or through our services (\”publicationdata\”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.6 We may process information contained in any inquiry you submit to us regarding the Services (\”inquirydata\”). The inquiry data may be processed for the purposes of offering, marketing and selling
relevant goods and/or services to you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (\”transactiondata\”). The transaction data may include first and last names, an email address to be used as a login, billing contact information, credit card number, banking information and/or cryptocurrency account information, and a password. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions and for determining compliance with Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) regulations, policies and law. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.
4.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (\”notificationdata\”). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.9 We may process information contained in or relating to any communication that you send to us (\”correspondencedata\”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.11 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.12 Please do not supply any other person’s personal data to us unless we prompt you to do so and have that person or person’s authorization to do so.
5. Providing your personal data to others
5.1 We may disclose your personal data to any member of our Affiliates, this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
5.2 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of executing such transactions as you wish to process via the Services and dealing with complaints and queries relating to such payments and refunds.
5.4 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.5 We may use Third Party Service Providers to serve ads when you participate in the Company Service. These companies may use Non-Personally Identifiable Information about your visits and use of the Company Service, and visits to other websites or locations to provide, through the use of network tags, advertisements about goods and services that may be of interest to you.
6. About cookies
6.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
6.2 Cookies may be either \”persistent\” cookies or \”session\” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
6.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
7. Cookies used by our service providers
8. Managing cookies
8.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
- 8.2 Blocking all cookies will have a negative impact upon the usability of many websites.
9. Security of Information
9.1 You can access your Personally Identifiable Information via the Company Service with your password and username. This password is encrypted. We advise against sharing your password with anyone. If you access your account via a third-party site or service, you may have additional or different sign-in protections via that third-party site or service. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-in mechanism appropriately and limiting access to your computer, browser, or mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. If we believe that the security of your information may have been compromised, we may seek to notify you of that development.
9.3 Please be aware that no data transmission over the Internet or via e-mail is completely secure and therefore we cannot guarantee protection of all personal information in all cases. For example, we cannot guarantee protection against interception, misappropriation, misuse, or alteration, or that your information will not be disclosed or accessed by the unauthorized acts of others. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. If you provide us with your credit card number, you should not send it electronically unless the email is encrypted, or your browser indicates that the access to our website is secure. Materials posted to online forums such as bulletin boards or chat rooms are public, not secure, and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other parties.
We continuously improve our websites and our products, and we utilize different third-party web analytics tools to help us do so. We are interested in how visitors use our websites, our desktop tools, our mobile applications, what they like and dislike, and where they have problems. Our products, desktop tools and mobile applications use analytical tools to understand feature usage patterns, to enhance and improve your product experience and offer you specific usage tips and guidance. In connection with normal business operations, as well as to increase functionality and enhance your user experience, this usage information may be linked to personal information that we have about individual users. We maintain ownership of this data and we do not share this type of data about individual users with third parties.
This information is used solely to assist us in maintaining a more effective and useful websites and products for our customers. This data will not be shared with third parties without your prior consent or unless required by law.
11. Your rights
11.1 In this Section we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
11.2 Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
11.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting your profile when logged in.
11.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
11.5 In some circumstances you have the right to the erasure of your personal data without undue delay, and at the latest within one month of receiving your valid request. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully process. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
11.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
11.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
11.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
11.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
11.10 To the extent that the legal basis for our processing of your personal data is:
a. consent; or
b. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
11.12 Under certain limited conditions you may have the right to invoke binding arbitration before the Privacy Shield Panel as created by the U.S. Department of Commerce and the European Commission.
11.13 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
The Company Service are not directed to people under the age of eighteen (18). If you become aware that your child has provided us with personal information without your consent, please contact us at the email address listed below. If we become aware that a child under eighteen (18) has provided us with personal information, we take steps to remove such information and terminate the child’s account.
13. Retaining and deleting personal data
13.1 This Section 13 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
13.2 Personal data that we process for any purpose or purposes shall be kept until such time as we receive a request for deletion from you.
13.3 Notwithstanding the other provisions of this Section 13, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
14. Notice of Privacy Rights to California Residents
California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (“COPPA”) and the California Business and Professions Code. As required by COPPA, we will provide you with the categories of Personally Identifiable Information that we collect through the Company Service and the categories of third party persons or entities with whom such Personally Identifiable Information may be shared for direct marketing purposes at your request. California law requires us to inform you, at your request, (1) the categories of Personally Identifiable Information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. COPPA further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email or physical mail to the address found below. When contacting us, please indicate your name, address, email address, and what Personally Identifiable Information you do not want us to share with our marketing partners. The request should be sent to the attention of our legal department and labeled “California Customer Choice Notice.” Please allow 30 days for a response. Also, please note that there is no charge for controlling the sharing of your Personally Identifiable Information or requesting this notice.
15. Dispute Resolution
15.1 In compliance with the Privacy Shield Principles, if a privacy complaint or dispute cannot be resolved through Company’s internal processes, Company has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure.
15.2 Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: verasafe.com
16. Privacy Shield Compliance
17. Access to personal data
The company provides access to personal information only those employees, contractors and agents of Company to whom this information is necessary to ensure the functioning of the Website, providing services to the Customers and only under the following circumstances:
- We have enough reason to believe that access, use, storage or disclosure of such information is necessary to (a) compliance with any applicable laws, resolutions , requirements of legal process or the a valid request from public authorities, (b) compliance with applicable terms of service, including investigation of potential violations, (c) detection and prevention of fraud actions and decision of the security issues and resolve technical problems or (d) protection from the threat of damage to the rights, property, or safety of the Website https://plasmapay.com (and its subdomains), its Customers or the public as are required or permitted by law.
18. Personal data protection
We take all necessary measures to protect the data against unauthorized access, modify, disclosure or destruction. These measures are internal review processes and conditions of collection, storage and processing of data and security measures, including appropriate encryption and measures to ensure physical data security to prevent unauthorized access to the system in which we store personal data.
We provide access to personal information only to those employees, contractors and agents of Company who need to have this information for action performed on our behalf. These persons must comply with the obligations of privacy and may be subject to disciplinary action, including dismissal and criminal prosecution if they violate these obligations.
19. Working with personal data and their update
Before processing requests, we ask Customers to identify its own identity and the information, which they want to receive, correct or delete. The Customer when using the Website, confirms that:
- has all the necessary rights, allowing him to register (create an account) and use the services of the Website;
- indicates true information about yourself in the volumes necessary to use the services of the Website, mandatory fields for further provision of services of the Website marked special way, all other
information provided by the Customer at his own discretion;
- recognizes that the information on the Website hosted by the Customer about itself maybe available to third parties not marked in this Policy and can be copy and distribute by them;
- familiar with this Policy, agrees with it and assumes the specified rights and obligations. Familiarization with the terms of this Policy is the written consent of the Customer for the collection, storage, processing and transfer to the third parties personal data provided by the Customer;
The company does not verify the authenticity of received (collected) information about Customers, except for cases when such check is necessary to fulfill obligations to the Customer.
20. Compliance of requirements
To this Policy and relations between the Customer and the Company arising about the use of this Privacy
Policy shall be governed by the laws of the country where the Company has registration.
22. Contact Us
Who can I ask if I have additional questions?
For additional inquiries about the privacy of your information, you can contact us as follows.
Compliance Officer: Nikolay I.
Plasma Alliance OÜ (14507139)
EstoniaHarju maakond, Tallinn, Lasnamae linnaosaPeterburi tee 47, 11415