PRIVACY POLICY 

Updated: June 06, 2024

This Privacy Policy (hereinafter – the Policy) stipulates the processes of your personal data collection, use, disclosure, transfer, storage, retention while you are using our website karavan.partners (hereinafter – the Site) or otherwise participate in our affiliate program (collectively – the Services). By “you” we mean any person, who being a natural person is acting as a sole proprietor or on behalf of a business entity, voluntarily sharing with us his\her personal data.

We may change this Policy from time to time. Your further use of the Site constitutes your consent with the changes to this Policy. In case of significant changes, we will notify you via email. If you disagree with the Policy, you should immediately cease your using the Services.

Personal data we process

• Registration data: first and last name, company name, email address, phone number, address, preferred payment method;
•  Communication data: data related with history of email communication, phone calls; 
• Payment data: payment methods, bank name, IBAN, SWIFT code, currency, transaction amounts, payment frequency, auto-payment status; 
• KYC\AML required data: ID card, passport, driver’s license, or your company’s incorporation and good standing certificates; 
• Traffic and performance data: data where the traffic comes from, how much there is, and details about your websites, apps, platforms, end-users’ IDs, their activities on our websites, deposit history, or other actions which allows us to calculate your remuneration; 
• Device data: IP address, location of internet access, browser, operating system and other usage details pertaining to the Site.

We also reserve the right to get any other additional information about you from third parties or public sources, like our business partners or online search engines, provided it is necessary for your effective use of the Services.

Purpose and basis of processing

We use personal data for the following purposes:

• to enable your access to the Site and Services; 
• to meet our obligations stipulated by applicable law; 
• to ensure safety and security;
•  to communicate with you regarding our Services;
•  to manage marketing activities

Depending the purposes above, we process your personal data on the following lawful bases: fulfillment of contract, compliance with our legal obligation, legitimate interest, consent and\or public interest.

Your rights as a data subject

The processing of personal data collected through the Site is carried out in accordance with the principle of equality. All our users enjoy equal rights prescribed the standards we adhere in the field of personal data protection, namely:

• right to access: you may send us inquiries concerning kind, purpose and duration of their personal data processing and receive relevant information within 30-day-period; 
• right to correct: you may contact us to supplement or change your personal data; 
• right to delete: you may ask us to delete your personal information fully or partially; 
• right to restrict processing: you may ask us to stop, in whole or in part, the processing of your personal data; 
• right to data transfer: you have the right to receive a copy of your personal data and transfer such data to other administrators; 
• right to object to the processing of personal data and to withdraw consent to their collection and processing; 
• right to data portability: you can request a copy of your personal data in a structured, machine-readable format; 
• right to appeal: you may file a complaint to the authorities regarding the protection of personal data if you believe that we have violated any of your rights.

To exercise any of your right, please reach us at: [email protected]

Automated Decision-Making

We understand the importance of transparency in automated decision-making processes. Automated decision-making entails the use of computer algorithms and automated systems without direct human involvement. We do not engage in automated decision-making, including profiling, regarding our Site users. In the event that we consider implementing such processes in the future, we commit to notifying you in advance.

Personal Data Sharing

For the purposes outlined above, we may share your personal data within the group of companies and internal service providers to which belong the following ones: hosting, marketing, IT and security service providers, customer support and payment service and analytic providers. We enter into a contractual agreement with each provider to ensure they handle your personal data responsibly and high security measures are applied respectively. 

Additionally, we may share your personal data with the respective parties or authorities for the purpose of complying the law, dealing with legal disputes and fulfilling business changes, such as an actual or potential sale, transfer, disposal, merger, or restructure of a part of our business or as part of an acquisition or merger with another business.

Marketing communications

Provided that we receive your consent to get marketing newsletters, we might contact you with promotions, products, or services you are interested in from time to time. With no influence on Services, you can unsubscribe from marketing newsletters whenever you want simply by managing your preferences in “My Account” or clicking the button “unsubscribe” at the end of each marketing newsletter. If you opt out, any marketing messages will appear to you until you consent to them again.

International Transfer

We may transfer your personal data to third countries or international organizations outside the European Economic Area (“EEA”) or have it processed by data processors operating outside the EEA when necessary for the purposes described in this Privacy Notice. These transfers are conducted in accordance with legal mechanisms, to which belong Adequacy Decision, Standard data protection clauses and other mechanisms.

Personal Data Security

We have put in place appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Data retention 

We will retain your personal data as long as it is necessary for the purposes collected. This may include our need to satisfy a legal, regulatory, accounting, or reporting requirement. Considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and applicable legal requirements, we determine the retention period of your personal data. 

Links to Third-Party Websites 

Our Site may contain links that direct you to other websites or services with privacy practices that differ from ours. If you choose to share personal data on any of these third-party sites, their privacy policies/notices, rather than ours, will dictate how your data is handled. We advise you thoroughly examine the privacy policy or notice of any external website you choose to visit.