1. 1. Introduction:

SileskaSeo Agency together with its Affiliates (“SileskaSeo”, “we”, “us”, or “our”), recognizes the importance of your privacy. This policy governs only SileskaSeo to use and disclosure of information we collect when users elect to use the SileskaSeo widget, visit a publisher web site that includes the SileskaSeo widget or uses SileskaSeo Services, or view advertisements we serve. This policy does not otherwise apply to the practices of other web sites, third-party advertisers or advertising networks, or other services or companies that we do not own, manage or control. We do not control the privacy practices of such third parties, and you are subject to the privacy policies of those third parties when you use their services.

We may collect information about you through the following means:

1. • when you complete a SILESKASEO registration,
   • when you visit our web site,
   • when you use our widget,
   • when you visit a web site using SILESKASEO services, or
   • when you view or respond to advertisements served by us or on our behalf.

If you elect to register with us, you will be providing us with certain information, some of which identifies you personally, such as your email address, IP address and other registration information. From time to time, you may also provide us with additional information about yourself if you engage in any other transactions with us, for example, when you give us your phone number to seek customer support. We call this information you provide to us directly “Registration Information“.

1. 1. Information Collection on the Site

Our Service allows for an interactive experience by integrating a commenting platform. By using our Service you understand and agree that we are providing a public comment sharing platform and that we or other Users may search for, see, use, re-post any of your User Content that you make publicly available through the Service.

When you visit the Sites, or use or interact with any of our Services, we will collect information from or about you or your device, which may include personal information or personal data as defined by applicable privacy laws (“Personal Information” or “Personal Data“) (collectively, the “Information”), and this Information will be handled as described in this Privacy Policy.

We may use Information collected through the Sites and Services in various ways, depending on whether you are(i) a User; (ii) a Customer; or (iii) a Visitor to the Sites. Therefore, this Privacy Policy outlines specific provisions for each of these categories and outlines provisions that apply to all three categories.

2.1. Personally Identifiable Information about Users:

We use and disclosure of information we collect when users elect to use the SILESKASEO‘s widget, visit a publisher web site that includes the SILESKASEO‘s widget or uses SILESKASEO services, or view advertisements we serve.

User Information that we collect includes, but is not limited to, Information about a User’s device and operating system, IP address, the web pages accessed by Users, event information (e.g., system crashes), general location information (e.g., city and state).

We ask for Personally Identifiable Information such as: (i) your name and e-mail address when you register for a SILESKASEO account with the Service, or if you correspond with us (in which case we will also retain our responses), IP address, location. If you purchase services or sign up for a paid subscription, then we will also ask for additional information, such as your full name, credit card number and billing address. We may also retain any messages you send through the Service, and may collect information you provide in User Content you post to the Service. We may receive Personally Identifiable Information about you from third parties, including, for example, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications.

2.2. Personally Identifiable Information about Visitors:

We collect information when you visit our web site, use or interact with SILESKASEO services, when you visit our partner publishers’ web sites that use our widget or SILESKASEO services, and when you view or click advertisements that we serve or are served on our behalf. This information could include general click stream behavior such as web pages viewed (including the URL addresses of such pages), search queries from which users are directed to a page, navigation from page to page through the SILESKASEO services, time spent on each page, and items that you click or select (“Usage Information“). This Usage Information also may include IP address, information about your geographic location derived from your IP address and the domain name of your Internet Service Provider. We also collect and use information about your interactions with the Service in a manner and format that does not identify you as an individual (“Non-Personally Identifiable Information“). We may collect, use, and disclose Non-Personally Identifiable Information as set forth below.

2.3. Personally Identifiable Information about Customers:

We collect Customer Information directly from our Customers. For example, we will collect a Customer’s contact details when a Customer enters a contractual relationship with SILESKASEO (Customer Information from Agreement, IO), when Customers accepted SILESKASEO TOS. When a Customer sends us an email asking a question, or signs up to receive our email newsletters, we will collect the Information that the Customer submits to us. We will also collect other Information that Customers choose to provide to us, such as the contents of a message or form that a Customer submits through our Sites or via email. We may also collect Information from prospective customers through publicly-available sources.

When a Customer signs up to use our Services, we collect and store only Information such as the Customer’s name, email address, telephone number, payment card information (card number, wallet number), billing information, and any other Information the Customer may choose to provide to us on the platform. We do not store payment systems Client ID, billing information, payment information (such as pin, expiration date, cvv code etc). We may also work with third party vendors to process payments to or from our Customers on our behalf. We do not have access to the Information that you provide to these third parties, and we encourage you to visit their privacy policies to understand their practices.

1. 1. Use of the Information

3.1. How we use Personal Information of Users and for what purposes

Use: We use Personally Identifiable Information of Users for the following purposes:

1. • internally for purposes such as analyzing how the Service is used, diagnosing service or technical problems or maintaining security,
   • to operate, maintain, and provide to you the features and functionality of the Service,
   • to fulfill requests you may make to us,
   • to personalize your experience and
   • to provide you with information and offers from us or third parties that we believe you may find useful or interesting, including newsletters, marketing or promotional materials and other information on services and products offered by us or third parties.

Following termination or deactivation of your SILESKASEO account, SILESKASEO may retain your pseudonymized profile information and User Content for a commercially reasonable time for backup, archival, or audit purposes. Furthermore, SILESKASEO may retain and continue to use indefinitely all information (including User Content) contained in your communications to other Users or posted to public or semi-public areas of the Service after termination or deactivation of your SILESKASEO account. SILESKASEO reserves the right, but has no obligation, to monitor the User Content you post on the Service. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Service, or to protect or defend our rights or property or those of any third party. SILESKASEO also reserves the right to remove information upon the request of any third party.

3.2. How we use Personal Information of Visitors and for what purposes

We will use your Non-Personally Identifiable Information:

1. • to fulfill requests for our services;
   • to communicate with you and respond to your inquiries;
   • to conduct research about the use of the SILESKASEO services;
   • to enable you to create an account, store log-in credentials, and customize your SILESKASEO services;
   • to contact you from time to time about SILESKASEO services; and
   • for SILESKASEO to provide offers for products and services of SILESKASEO.

We use the Usage Information we collect and information collected from our third-party partners to assemble non-personal, demographic and behavioral information to group users that share a common interest into “Audience Segments.” These Audience Segments do not contain Personally Identifiable Information; for example, these segments may disclose that a user located in a geographic area may be interested in cars, but this information does not identify or include the name, e-mail address, phone number, mailing address, or user name of any specific individual. We will use these Audience Segments (a) to match advertisements that may be of interest to our users that fall within that segment and (b) to assist our advertisers, ad networks, and publisher web sites to deliver advertisements and offers that may be of interest to users within a given segment.

3.3. How we use Personal Information of Customers and for what purposes

Use: We use Personally Identifiable Information of Customers for the following purposes:

1. • internally for purposes such as analyzing how the Service is used, diagnosing service or technical problems or maintaining security, for financial, accounting, statistics matters of SILESKASEO;
   • to provide our Sites and Services and for other customer service purposes in relation to Customer accounts;
   • to communicate, via email or otherwise, about Customers’ accounts;
   • to operate, maintain, and provide to you the features and functionality of the Service,
   • to fulfill requests you may make to us,
   • to personalize your experience and
   • to provide you with information and offers from us or third parties that we believe you may find useful or interesting, including newsletters, marketing or promotional materials and other information on services and products offered by us or third parties.

Following termination or deactivation of your SILESKASEO account, SILESKASEO may retain your pseudonymized profile information and User Content for a commercially reasonable time for backup, archival, or audit purposes. Furthermore, SILESKASEO may retain and continue to use indefinitely all information (including User Content) contained in your communications to other Users or posted to public or semi-public areas of the Service after termination or deactivation of your SILESKASEO account. SILESKASEO reserves the right, but has no obligation, to monitor the User Content you post on the Service. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Service, or to protect or defend our rights or property or those of any third party. SILESKASEO also reserves the right to remove information upon the request of any third party.

1. 1. Transfer (Sharing of Personal Information)

4.1. Sharing of Personal Information within SileskaSeo Agency.

We may disclose User, Visitor and Customer Information to any current or future Affiliates, parent companies, or subsidiaries to process data for the purposes described in this Privacy Policy in accordance with Agreements between the companies within the SileskaSeo Agency.

4.2. Sharing of Personal Information with Third Party.

We may disclose Visitor, Customer, Users Information to vendors, service providers, agents, contractors, or others third parties who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, card processing, data hosting, fraud detection) on our behalf.

We will not rent or sell your Personally Identifiable Information to third parties outside SILESKASEO and its controlled subsidiaries and affiliates without your consent, except as noted below:

1. • Who we may share your Personally Identifiable Information with: We may share your Personally Identifiable Information with third-party business partners for the purpose of providing the Service to you. Those business partners will be given limited access to the Personally Identifiable Information that is reasonably necessary to deliver the Service, and we will require that such third parties comply with this Privacy Policy.
   • Who you may choose to share your User Content with: Any Personally Identifiable Information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. To change your privacy settings on the Service, please change your profile setting. 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.

1. • What happens in the event of a change of control: We may buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personally Identifiable Information such as customer names and email addresses, User Content and other user information related to the Service will likely be among the items transferred in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
   • Instances where we are required to share your Personally Identifiable Information: SILESKASEO will disclose Personally Identifiable Information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of our Service; and/or (c) to prevent/ investigate fraudulent activity, to exercise or protect the rights, property, or personal safety of SILESKASEO, our Users or others.

We may share Non-Personally Identifiable Information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.):

1. • in any manner permitted for Personally Identifiable Information; and
   • with our third-party business partners for the purposes described in the section above.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

We may share non-aggregate, non-personally identifiable Usage Information, including audience segments, with third party advertisers and publishers to assist us and them in delivering relevant, targeted advertising that is aligned with user interests. For example, these companies may use such information (e.g., click stream information, time and date, subject of advertisements clicked or scrolled over) in order to provide advertisements about goods and services likely to be of greater interest to you. Your preferences collected through this process may be used to influence which types of marketing messages you receive across sites that we work with.

We may also share aggregate statistical information about our services with advertisers and publishers. We do not provide any personally identifiable information to these third parties.

We may use User Information to improve a unique User’s experience across multiple browsers and devices (such as smartphones, tablets, or other viewing devices) by providing better targeted ad campaigns to that User. For instance, should we recognize a User on a web browser, we may want to provide that User similar or personalized content on mobile apps, as well. To do this, we identify unique Users across devices, or we may sync cookies and identifiers with our Customers that do this, to help our Customers enhance their own data and data segments, or to help them target the right audience.

4.3 International Data Transfers

We may transfer your Information outside the country in which it is collected, including to a country that may not offer the same level of protection for Information as the country in which you reside. Rest assured however, that SILESKASEO has arranged all contractual safeguards to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among SILESKASEO Affiliates, subsidiaries, and/or parent companies. More over SILESKASEO transfers Data according to the relevant provisions of GDPR regarding “Transfers of personal data to third countries or international organisations” and according to Standart Contractual Clauses for particular cases.

SILESKASEO currently stores Customer, User, and Visitor Information in our data centers located in the United States, The Netherlands and Singapore.

1. 1. Reginal transfer of Data

5.1. Data transfer within the European Economic Area (“EEA”)

5.1.1. Data Controller and Representative

If you reside in the EEA or UK, SILESKASEO in EEA will be the controller of your Personal Data provided to, collected by or for, or processed by SILESKASEO in connection with our Services.

5.1.2. Legal Basis for Processing Personal Data

If you are a Customer, Site Visitor, or User from the EEA or UK, our legal basis for collecting and using the Personal Data described above and will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only

1. • where we have your consent to do so,
   • where we need the Personal Data to perform a contract with you, or
   • where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms

In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirements or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, please contact us at [email protected]

5.1.3 Your Rights to Your Information

You have the right to request that SILESKASEO

1. • provide you with access to the Personal Data we hold about you,
   • correct your Personal Data,
   • Export your Personal Data,
   • delete your Personal Data, and
   • cease or restrict processing of your Personal Data

If you are a User and would like to understand what Personal Data and behavioural information SILESKASEO holds about you, specifically, and how you can exercise any of your rights with respect to your Personal Data, please submit a data subject access request by emailing us at [email protected] so that SILESKASEO may either respond with the relevant information or, if applicable.

You have the right to complain to a data protection authority about our collection and use of your Personal Data. To learn more, please contact your local data protection authority, via the contact methods available here. However, if you have any questions about our collection and use of your Personal Data, please first contact us at [email protected]

5.1.4 EEA/UK Data Transfers

As part of SILESKASEO’s global operations, our data flows between the EEA, the UK and other country.

When SILESKASEO transfers any personal data from the EEA within the SileskaSeo Agency in the United Kingdom, it relies on the European Commission’s decision that the UK provides a level of data protection that is adequate for personal data from the EEA.

Beyond that, when SILESKASEO transfers EEA/UK Data to other countries then, if those countries do not have a European Commission adequacy finding and are not the subject of UK adequacy regulations (as applicable), SILESKASEO implements Standard Contractual Clauses approved by the European Commission and/or competent UK authorities (as applicable) to protect the transferred data.

In particular, non-EEA/UK SILESKASEO Affiliates, like our Company in the United States, have accordingly adopted Standard Contractual Clauses to ensure the legality, privacy, and security of the data flows necessary to provide, maintain, and develop our services.

5.2. Data transfer in the State of California

5.2.1. Your Rights to Your Personal Information

California residents have the right to request that SILESKASEO

1. • provide you with access to the Personal Information that we hold about you,
   • correct your Personal Information,
   • delete your Personal Information, and
   • cease or restrict disclosures or sales of your Personal Information to third parties.

You also have a right against discrimination for exercising any of these rights, which SILESKASEO is committed to upholding and honouring at all times. If you would like to opt out of SILESKASEO‘s disclosures and sales of your Personal Information, you may do so by emailing us at [email protected].

5.2.2. Categories of Data that SILESKASEO Holds about You

If you are a Customer, Site Visitor, or User our legal basis for collecting and using the Personal Data described above and will depend on the Personal Data concerned and the specific context in which we collect it.

At the same time SILESKASEO may maintains unidentifiable information about you in only pseudonymized form, which means that we do not know your identity because we do not process your name, email address, or other identifiable information. Instead, we only process digital identifiers such as cookie IDs, IP addresses, dUser Agent on your device, network browsing history and associated preferences.

5.2.3. Why SILESKASEO Collects your Personal Information

SILESKASEO processes your Personal Information in order to provide personalized content and advertisements to you, as well as for fraud-analysis to fraud-prevention with in-house product and Our Services.

5.2.4 Where SILESKASEO Collects Your Personal Information

We automatically collect User Information when Users interact with our Services that appear on our Customers’ websites and digital properties. Like most other web-based services, we collect this User Information through cookies and other technologies. We may also obtain Information about you from our data partners.

SILESKASEO collects Information either directly from you during your use of our Sites and Services or from third parties that independently collect this Information from you, and we may combine the Information that we collect from these various sources.

5.2.5 How SILESKASEO Shares Your Personal Information

SILESKASEO may disclose or make available your pseudonymous Personal Information to our trusted partners and other persons/companies as descrived above. In most cases when we do so, we have contractually restricted their uses of this data for only SILESKASEO‘s business purposes. Under the CCPA, such disclosures of Personal Information to service providers are not deemed to be a “sale” and thus are not prohibited after you exercise your right to cease or restrict disclosures or sales of your Personal Information to third parties. In any instances where we have not entered into a service provider relationship with such third parties, we will stop sharing your Personal Information when you instruct us not to “sell” your Personal Information.

5.3. Data transfer in Thailand

5.3.1 Data Controller/Processor

If you reside in Thailand, Affiliate/Subcidiary of SileskaSeo Agency will be the controller of your Personal Data provided to, collected by or for, or processed by SILESKASEO in connection with our Services.

5.3.2 Legal Basis for Processing Personal Data

If you are a Customer, Visitor, or User from Thailand, our legal basis for collecting and using the Personal Data described above and will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only

1. • where we have your consent to do so,
   • where we need the Personal Data to perform a contract with you, or
   • where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms

In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

5.3.3 Your Rights to Your Information

You have the right to request that SILESKASEO

1. • provide you with access to the Personal Data we hold about you,
   • export your Personal Data,
   • delete your Personal Data, and
   • cease or restrict processing of your Personal Data.

If you are a User and would like to understand what Personal Data and behavioural information SILESKASEO holds about you, specifically, and how you can exercise any of your rights with respect to your Personal Data, please submit a data subject access request by emailing us at [email protected] so that SILESKASEO may either respond with the relevant information or, if applicable, direct this request to, and cooperate with, your employer to respond.

If you have any questions about our collection and use of your Personal Data, please first contact us at [email protected].

5.3.4 Thailand Data Transfers

SILESKASEO transfers data outside of Thailand. SILESKASEO has in place an Inter Group Data Transfer Agreement across its international entities and ensures a high level of security of transferred data.

As part of SILESKASEO’s global operations, our data flows between Thailand, the EEA, the United States and other countries. To ensure that Thailand Data is adequately protected when transferred outside of Thailand, the Personal Data Protection Act, B.E. 2562 mandates that such transfers take place using certain legal mechanisms.

When transferring Thailand data elsewhere, SILESKASEO relies on Standard Contractual Clauses, set forth by the European Commission, that outline contractual privacy and security commitments between companies that transfer personal data (for example, between companies within SileskaSeo Agency). SILESKASEO and its Affiliates have accordingly adopted Standard Contractual Clauses to ensure the legality, privacy, and security of the data flows necessary to provide, maintain, and develop our services.

5.4. Data transfer in Brazil

5.4.1 Data Controller

If you reside in the Federative Republic of Brazil (“Brazil”), Affiliate/Subcidiary of SileskaSeo Agency will be the controller of your Personal Data provided to, collected by or for, or processed by SILESKASEO in connection with our Services.

5.4.2 Legal Basis for Processing Personal Data

If you are a Customer, Visitor, or User from Brazil, under the Lei Geral de Proteção de Dados federal law 13,709/2018 (the “LGPD”), our legal basis for collecting and using the Personal Data described above (also referred to in this Section 5.4 as “Brazil Data”) will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only

1. • where we have your consent to do so,
   • where we need the Personal Data to perform a contract with you, or
   • where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms

In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), a notice will be provided to you in our disclosure statement.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, please contact us via [email protected].

5.4.3 Your Rights to Your Personal Data

You have the right to request that SILESKASEO

1. • confirm whether we are processing your Personal Data,
   • provide you with access to the Personal Data we hold about you,
   • disclose the public and private entities with which we have shared use of your Personal Data,
   • correct your Personal Data,
   • export your Personal Data, for your own use or use by another controller
   • anonymize, block, or delete any unnecessary or excessive data,
   • delete all your Personal Data, and
   • cease or restrict processing of your Personal Data.

If you are a User and would like to understand what Personal Data and behavioural information SILESKASEO holds about you, specifically, and how you can exercise any of your rights with respect to your Personal Data, please submit a data subject access request by emailing us at [email protected] so that SILESKASEO may either respond with the relevant information or, if applicable, direct this request to, and cooperate with, your employer to respond.

5.4.4. Brazil Data Transfers

SILESKASEO transfers data outside Brazil. As part of SILESKASEO’s global operations, our data flows between Brazil, the EEA, the United States, and other countries. To ensure that Brazil Data is adequately protected when transferred outside Brazil, the LGPD mandates that such transfers take place using certain legal mechanisms. SILESKASEO has in place an Inter Group Data Transfer Agreement across its international entities, which is based on the EEA’s standard model clauses, and which may be updated upon further guidance from the future ANPD.

1. 1. Rights of individuals

6.1. It is important for our User, Visitors and Customers to be aware about individual rights under the General Data Protection Regulation (GDPR). SILESKASEO has a responsibility to make individuals aware of their rights and ensure mechanisms are in place to act on these. In order to do this it is important that you are aware of these rights.

6.2. The rights are:

6.2.1. Right to be informed.

Providing clear and correct information is a key duty in many regards. Personal data that have undergone an action as a consequence of one of the other data subject rights, the controller must inform recipients who got these data, where feasible.

6.2.2. Right of access which means:

1. 1. the right to know whether data concerning him or her are being processed and
   2. if so, access it with loads of additional stipulations (GDPR Article 15). The data subject’s right to rectification. When personal data are inaccurate, then controllers need to correct them indeed (GDPR Article 16).

6.2.3. Right to rectification.

Individuals have the right to have personal data rectified. If find out that your personal data is not accurate, contain incorrect information, our Users, Visitors, Customers have the right to contact SILESKASEO with request to rectified it via [email protected]. SILESKASEO must rectify any inaccurate personal data that relates to the individual without undue delay and in any event within one month.

6.2.4. Right to erasure/to be forgotten.

The underlying principle of this right is that when there is no compelling reason for their data to be processed, the data subject can:

1. 1. request the data controller erase/remove their personal data);
   2. stop any further distribution of their personal data;
   3. potentially stop third parties from processing their personal data.

Individuals have the right to have their data erased and stopped processing:

1. • when the original purpose for the personal data is no longer necessary or the data itself is no longer necessary for the purpose.
   • when the individual no longer consents.
   • if the individual objects to their data being processed and there is no legitimate reason to override this objection.
   • if the data being processed relates to the offer of information society services to a child.
   • if the data is ever processed in breach of data protection regulations (i.e. GDPR).

6.2.5. Right to restrict processing.

Users, Visitors and Customers have the right to make a request for restriction via [email protected]. This is not an absolute right and only applies in certain circumstances. When processing is restricted, SILESKASEO are permitted to store the personal data, but not use it.

6.2.6. Right to data portability, Users, Visitors and Customers have the right to move, copy, or transfer personal data from one data controller to another, in a safe and secure way, in a commonly used and machine-readable format.

6.2.7. Right to object and rights in relation to automated decision making and profiling.

Users, Visitors and Customers have the right to object to being subject to SILESKASEO processing their data without explicit consent. Users, Visitors and Customers have the right to stop personal data from being included in direct marketing databases. To perfom these rights Users, Visitors and Customers have to contact SILESKASEO with request via [email protected].

1. 1. Cookies Policy

7.1. Cookies Information:

Like many websites, we mostly use cookies and pixel tags to collect this Usage Information. A cookie is a small file containing a string of characters that is sent to your computer and stored on your hard drive when you visit a website; each website can send its own cookies to your browser. A pixel tag is a small graphic file that allows us to measure the use of SILESKASEO services. Pixel tags allow us to collect information such as IP address of the computer that downloaded the page on which the tag appears, the URL of the page on which the pixel tag appears, the time (and length of time) the page containing the pixel tag is viewed, and the identification number (the long string of characters) of any cookie previously placed by that server on your computer. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

7.2. Cookies Options:

We use cookies to uniquely identify a browser, which gives advertisers the ability to show targeted ads that are relevant to you. If you would prefer us not to store a unique cookie in your browser, you may opt out. Note that by opting out, you still will receive advertising from SILESKASEO when you visit our websites – it just will not be targeted to you.

Our tracking mechanisms operate at the device and browser level, to fully opt-out across devices, you will need to do so on each device and browser individually. If your browsers are configured to reject cookies, your opt-out may not be effective, since we identify your choice to opt-out based on an opt-out cookie we deliver to you. In this case, you will need to confirm that your browser is configured properly in order for the opt-out to be effective. If you are using a Safari browser on iOS11 or macOS High Sierra, you must first adjust your Privacy and Security Settings to turn off both “Prevent Cross-Site Tracking” and “Block All Cookies”, and then return to this privacy policy or your preferred opt out platform to reset your opt out preferences.

We may use non-cookie technologies in limited cases. Like cookies, these technologies allow Us to recommend ads that are tailored to your interests and to remember whether you have chosen to opt-out from our Services. Please note that some web browsers may not permit you to block the use of non-cookie technologies, but you can do so by simply clicking on the Opt Out feature.

7.3.Analytics Information:

We use both our and third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, your browser’s width and height, and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

7.4. Log File Information:

Log file information is automatically reported by your browser each time you access a web page. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

7.5. Clear Gifs/Web Beacons Information:

When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users anonymously. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information is allows for more accurate reporting and improvement of the Service.

7.6. Information Collection on Partner Sites

We may receive, transfer and collect information from users of third party sites which use the SILESKASEO service (“Partner Sites”) about you and your usage of the SILESKASEO Service on their sites. Unless you have allowed the Partner Site to share Personally Identifiable Information, such information will not include Personally Identifiable Information, but may include Non-Personally Identifiable Information and/or report anonymous information about your usage of the Partner Site and the SILESKASEO Service on that site.

8.Ads on SILESKASEO

We may also share certain information such as your location, browser and cookie data and other data relating to your use of our Service with our business partners to deliver advertisements (“ads”) that may be of interest to you. SILESKASEO may allow third-party ad servers or ad networks to serve advertisements on the Service. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Service, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browser’s or device’s visits and usage patterns on the Service, and to measure the effectiveness of their ads and to personalize the advertising content. SILESKASEO does not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.

Please note that an advertiser may ask SILESKASEO to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, SILESKASEO determines the target audience and SILESKASEO serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

The SILESKASEO Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

1. 1. Changing or Deleting Your Information

All registered users may review, update or correct the Personally Identifiable Information provided in their registration or account profile by changing their “user preferences” in their account. If you choose to opt out entirely, then your account may become deactivated and you will need to re-register should you decide to opt-in again. To delete your account and information entirely or to prevent SILESKASEO from processing your data please email us at [email protected]. However, you understand and agree that we are not able to remove your Personally Identifiable Information from the records of any third party who has been provided with your information in compliance with the use and sharing policy outlined above.

We retain User Information, which is directly collected for purposes of Services, for at most thirteen (13) months from the User’s last interaction with our Services (often for a shorter period of time), after which time we de-identify the data by removing unique identifiers or aggregating the data.

We retain deidentified or aggregated data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as commercially necessary. We keep opt-out information for longer than this period so that we can continue to honor your opt-out requests.

In the event that we are unable to isolate certain Personal Data and comply with a deletion request, we will instead enforce strict access controls and data destruction.

1. 1. Security

SILESKASEO is very concerned with safeguarding your information. SILESKASEO uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from SILESKASEO, at all times. Notwithstanding the foregoing measures, SILESKASEO cannot ensure or warrant the security of any information you transmit to SILESKASEO or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of SILESKASEO‘ distributors, such as social networks. SILESKASEO is not responsible for the functionality or security measures of any third party.

11.Policy Towards Children

This Site is not directed to children under 16. We do not knowingly collect or solicit personal information from children under 16 or knowingly allow such persons to register for an account. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 is allowed to provide any personal information to or on SILESKASEO. In the event that we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at [email protected].

1. 1. Data Protection Terms for European Economic Area

If your agreement with SILESKASEO incorporates this policy, or you otherwise use a SILESKASEO product that incorporates this policy, you must ensure that necessary disclosures are given to, and consents obtained from, end users in the European Economic Area or outside. If you fail to comply with this policy, we may limit or suspend your use of the SILESKASEO’s services and/or terminate your agreement.

Properties under your control. For SILESKASEO services used on any site, app or other property that is under your control, or that of your affiliate or your client, the following duties apply for end users in the European Economic Area.

You must obtain end users’ legally valid consent to the use of cookies or other local storage where legally required and the collection, sharing, and use of personal data for personalization of ads.

When seeking consent you must retain records of consent given by end users; and provide end users with clear instructions for revocation of consent. You must clearly identify each party that may collect, receive, or use end users’ personal data as a consequence of your use of SILESKASEO Services. You must also provide end users with easily accessible information about that party’s use of end users’ personal data.

Properties under a third party’s control. If personal data of end users of a third party property is shared with SILESKASEO due to your use of, or integration with, SILESKASEO services, then you must use commercially reasonable efforts to ensure the operator of the third party property complies with the above stated duties.

Protection of Data Provider Personal Data. If you are accepting these Privacy Policy on behalf of your customer, you warrant that: (a) you have full legal authority to bind Customer to these Privacy Policy; (b) you have read and understand these Privacy Policy; and (c) you agree, on behalf of Customer, to these Privacy Policy. If you do not have the legal authority to bind Customer or your level of protection is not at least equivalent to that required under this Privacy Policy you should either cease processing the personal data or take reasonable and appropriate steps to remedy such non-compliance

1. 1. Accesses, uses, stores, or shares Google user data

When you register for a SILESKASEO, you allow this Service to identify and give you access to dedicated services.

Direct registration – The User registers by filling out the registration form and providing the Personal Data directly to SILESKASEO.

If third party registration and authentication services are used SILESKASEO will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Google OAuth (Google Inc.)

Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network. Personal Data collected: various types of Data as specified in the on-screen privacy notice displayed when using this registration method and in the general privacy policy of the service https://www.google.com/policies/privacy/

When you register for a SILESKASEO account with the Service we may receive your email from such third parties as Google and use this email for registration and authorisation. We use, store, or/and share this information solely in the ways and for the purposes provided in this Privacy Policy.

SILESKASEO App’s use of information received from Gmail APIs will adhere to Google’s Limited Use Requirements.

1. 1. Links to Other Web Sites

We are not responsible for the practices employed by websites linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our website, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

SILESKASEO may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the bottom of this page. Your continued use of the Site following the posting of any changes to this policy means you accept such changes.

We reserve the right to transfer your personal information in the event of a transfer of ownership of SILESKASEO, such as acquisition by or merger with another company.

From time to time we may update this Privacy Policy. You should visit this page periodically to review any such changes to the privacy policy. In such cases, your continued use of this website or our service means that the provision of personally identifiable information to us after such material changes will be subject to the new terms. If we make material changes to this Privacy Policy that expand our rights to use your personal information that we have collected, we will notify you to seek your consent through email or a prominent posting on the site. You always have the option to cancel your account with us at any time. Simply de-install the widget from your site. If you have any questions or need some clarification on our privacy policy, please do not hesitate to email us at [email protected].

1. 1. Introduction:

SileskaSeo Agency together with its Affiliates (“SileskaSeo”, “we”, “us”, or “our”), recognizes the importance of your privacy. This policy governs only SileskaSeo to use and disclosure of information we collect when users elect to use the SileskaSeo widget, visit a publisher web site that includes the SileskaSeo widget or uses SileskaSeo Services, or view advertisements we serve. This policy does not otherwise apply to the practices of other web sites, third-party advertisers or advertising networks, or other services or companies that we do not own, manage or control. We do not control the privacy practices of such third parties, and you are subject to the privacy policies of those third parties when you use their services.

We may collect information about you through the following means:

1. • when you complete a SILESKASEO registration,
   • when you visit our web site,
   • when you use our widget,
   • when you visit a web site using SILESKASEO services, or
   • when you view or respond to advertisements served by us or on our behalf.

If you elect to register with us, you will be providing us with certain information, some of which identifies you personally, such as your email address, IP address and other registration information. From time to time, you may also provide us with additional information about yourself if you engage in any other transactions with us, for example, when you give us your phone number to seek customer support. We call this information you provide to us directly “Registration Information“.

1. 1. Information Collection on the Site

Our Service allows for an interactive experience by integrating a commenting platform. By using our Service you understand and agree that we are providing a public comment sharing platform and that we or other Users may search for, see, use, re-post any of your User Content that you make publicly available through the Service.

When you visit the Sites, or use or interact with any of our Services, we will collect information from or about you or your device, which may include personal information or personal data as defined by applicable privacy laws (“Personal Information” or “Personal Data“) (collectively, the “Information”), and this Information will be handled as described in this Privacy Policy.

We may use Information collected through the Sites and Services in various ways, depending on whether you are(i) a User; (ii) a Customer; or (iii) a Visitor to the Sites. Therefore, this Privacy Policy outlines specific provisions for each of these categories and outlines provisions that apply to all three categories.

2.1. Personally Identifiable Information about Users:

We use and disclosure of information we collect when users elect to use the SILESKASEO‘s widget, visit a publisher web site that includes the SILESKASEO‘s widget or uses SILESKASEO services, or view advertisements we serve.

User Information that we collect includes, but is not limited to, Information about a User’s device and operating system, IP address, the web pages accessed by Users, event information (e.g., system crashes), general location information (e.g., city and state).

We ask for Personally Identifiable Information such as: (i) your name and e-mail address when you register for a SILESKASEO account with the Service, or if you correspond with us (in which case we will also retain our responses), IP address, location. If you purchase services or sign up for a paid subscription, then we will also ask for additional information, such as your full name, credit card number and billing address. We may also retain any messages you send through the Service, and may collect information you provide in User Content you post to the Service. We may receive Personally Identifiable Information about you from third parties, including, for example, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications.

2.2. Personally Identifiable Information about Visitors:

We collect information when you visit our web site, use or interact with SILESKASEO services, when you visit our partner publishers’ web sites that use our widget or SILESKASEO services, and when you view or click advertisements that we serve or are served on our behalf. This information could include general click stream behavior such as web pages viewed (including the URL addresses of such pages), search queries from which users are directed to a page, navigation from page to page through the SILESKASEO services, time spent on each page, and items that you click or select (“Usage Information“). This Usage Information also may include IP address, information about your geographic location derived from your IP address and the domain name of your Internet Service Provider. We also collect and use information about your interactions with the Service in a manner and format that does not identify you as an individual (“Non-Personally Identifiable Information“). We may collect, use, and disclose Non-Personally Identifiable Information as set forth below.

2.3. Personally Identifiable Information about Customers:

We collect Customer Information directly from our Customers. For example, we will collect a Customer’s contact details when a Customer enters a contractual relationship with SILESKASEO (Customer Information from Agreement, IO), when Customers accepted SILESKASEO TOS. When a Customer sends us an email asking a question, or signs up to receive our email newsletters, we will collect the Information that the Customer submits to us. We will also collect other Information that Customers choose to provide to us, such as the contents of a message or form that a Customer submits through our Sites or via email. We may also collect Information from prospective customers through publicly-available sources.

When a Customer signs up to use our Services, we collect and store only Information such as the Customer’s name, email address, telephone number, payment card information (card number, wallet number), billing information, and any other Information the Customer may choose to provide to us on the platform. We do not store payment systems Client ID, billing information, payment information (such as pin, expiration date, cvv code etc). We may also work with third party vendors to process payments to or from our Customers on our behalf. We do not have access to the Information that you provide to these third parties, and we encourage you to visit their privacy policies to understand their practices.

1. 1. Use of the Information

3.1. How we use Personal Information of Users and for what purposes

Use: We use Personally Identifiable Information of Users for the following purposes:

1. • internally for purposes such as analyzing how the Service is used, diagnosing service or technical problems or maintaining security,
   • to operate, maintain, and provide to you the features and functionality of the Service,
   • to fulfill requests you may make to us,
   • to personalize your experience and
   • to provide you with information and offers from us or third parties that we believe you may find useful or interesting, including newsletters, marketing or promotional materials and other information on services and products offered by us or third parties.

Following termination or deactivation of your SILESKASEO account, SILESKASEO may retain your pseudonymized profile information and User Content for a commercially reasonable time for backup, archival, or audit purposes. Furthermore, SILESKASEO may retain and continue to use indefinitely all information (including User Content) contained in your communications to other Users or posted to public or semi-public areas of the Service after termination or deactivation of your SILESKASEO account. SILESKASEO reserves the right, but has no obligation, to monitor the User Content you post on the Service. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Service, or to protect or defend our rights or property or those of any third party. SILESKASEO also reserves the right to remove information upon the request of any third party.

3.2. How we use Personal Information of Visitors and for what purposes

We will use your Non-Personally Identifiable Information:

1. • to fulfill requests for our services;
   • to communicate with you and respond to your inquiries;
   • to conduct research about the use of the SILESKASEO services;
   • to enable you to create an account, store log-in credentials, and customize your SILESKASEO services;
   • to contact you from time to time about SILESKASEO services; and
   • for SILESKASEO to provide offers for products and services of SILESKASEO.

We use the Usage Information we collect and information collected from our third-party partners to assemble non-personal, demographic and behavioral information to group users that share a common interest into “Audience Segments.” These Audience Segments do not contain Personally Identifiable Information; for example, these segments may disclose that a user located in a geographic area may be interested in cars, but this information does not identify or include the name, e-mail address, phone number, mailing address, or user name of any specific individual. We will use these Audience Segments (a) to match advertisements that may be of interest to our users that fall within that segment and (b) to assist our advertisers, ad networks, and publisher web sites to deliver advertisements and offers that may be of interest to users within a given segment.

3.3. How we use Personal Information of Customers and for what purposes

Use: We use Personally Identifiable Information of Customers for the following purposes:

1. • internally for purposes such as analyzing how the Service is used, diagnosing service or technical problems or maintaining security, for financial, accounting, statistics matters of SILESKASEO;
   • to provide our Sites and Services and for other customer service purposes in relation to Customer accounts;
   • to communicate, via email or otherwise, about Customers’ accounts;
   • to operate, maintain, and provide to you the features and functionality of the Service,
   • to fulfill requests you may make to us,
   • to personalize your experience and
   • to provide you with information and offers from us or third parties that we believe you may find useful or interesting, including newsletters, marketing or promotional materials and other information on services and products offered by us or third parties.

Following termination or deactivation of your SILESKASEO account, SILESKASEO may retain your pseudonymized profile information and User Content for a commercially reasonable time for backup, archival, or audit purposes. Furthermore, SILESKASEO may retain and continue to use indefinitely all information (including User Content) contained in your communications to other Users or posted to public or semi-public areas of the Service after termination or deactivation of your SILESKASEO account. SILESKASEO reserves the right, but has no obligation, to monitor the User Content you post on the Service. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Service, or to protect or defend our rights or property or those of any third party. SILESKASEO also reserves the right to remove information upon the request of any third party.

1. 1. Transfer (Sharing of Personal Information)

4.1. Sharing of Personal Information within SileskaSeo Agency.

We may disclose User, Visitor and Customer Information to any current or future Affiliates, parent companies, or subsidiaries to process data for the purposes described in this Privacy Policy in accordance with Agreements between the companies within the SileskaSeo Agency.

4.2. Sharing of Personal Information with Third Party.

We may disclose Visitor, Customer, Users Information to vendors, service providers, agents, contractors, or others third parties who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, card processing, data hosting, fraud detection) on our behalf.

We will not rent or sell your Personally Identifiable Information to third parties outside SILESKASEO and its controlled subsidiaries and affiliates without your consent, except as noted below:

1. • Who we may share your Personally Identifiable Information with: We may share your Personally Identifiable Information with third-party business partners for the purpose of providing the Service to you. Those business partners will be given limited access to the Personally Identifiable Information that is reasonably necessary to deliver the Service, and we will require that such third parties comply with this Privacy Policy.
   • Who you may choose to share your User Content with: Any Personally Identifiable Information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. To change your privacy settings on the Service, please change your profile setting. 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.

1. • What happens in the event of a change of control: We may buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personally Identifiable Information such as customer names and email addresses, User Content and other user information related to the Service will likely be among the items transferred in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
   • Instances where we are required to share your Personally Identifiable Information: SILESKASEO will disclose Personally Identifiable Information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of our Service; and/or (c) to prevent/ investigate fraudulent activity, to exercise or protect the rights, property, or personal safety of SILESKASEO, our Users or others.

We may share Non-Personally Identifiable Information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.):

1. • in any manner permitted for Personally Identifiable Information; and
   • with our third-party business partners for the purposes described in the section above.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

We may share non-aggregate, non-personally identifiable Usage Information, including audience segments, with third party advertisers and publishers to assist us and them in delivering relevant, targeted advertising that is aligned with user interests. For example, these companies may use such information (e.g., click stream information, time and date, subject of advertisements clicked or scrolled over) in order to provide advertisements about goods and services likely to be of greater interest to you. Your preferences collected through this process may be used to influence which types of marketing messages you receive across sites that we work with.

We may also share aggregate statistical information about our services with advertisers and publishers. We do not provide any personally identifiable information to these third parties.

We may use User Information to improve a unique User’s experience across multiple browsers and devices (such as smartphones, tablets, or other viewing devices) by providing better targeted ad campaigns to that User. For instance, should we recognize a User on a web browser, we may want to provide that User similar or personalized content on mobile apps, as well. To do this, we identify unique Users across devices, or we may sync cookies and identifiers with our Customers that do this, to help our Customers enhance their own data and data segments, or to help them target the right audience.

4.3 International Data Transfers

We may transfer your Information outside the country in which it is collected, including to a country that may not offer the same level of protection for Information as the country in which you reside. Rest assured however, that SILESKASEO has arranged all contractual safeguards to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among SILESKASEO Affiliates, subsidiaries, and/or parent companies. More over SILESKASEO transfers Data according to the relevant provisions of GDPR regarding “Transfers of personal data to third countries or international organisations” and according to Standart Contractual Clauses for particular cases.

SILESKASEO currently stores Customer, User, and Visitor Information in our data centers located in the United States, The Netherlands and Singapore.

1. 1. Reginal transfer of Data

5.1. Data transfer within the European Economic Area (“EEA”)

5.1.1. Data Controller and Representative

If you reside in the EEA or UK, SILESKASEO in EEA will be the controller of your Personal Data provided to, collected by or for, or processed by SILESKASEO in connection with our Services.

5.1.2. Legal Basis for Processing Personal Data

If you are a Customer, Site Visitor, or User from the EEA or UK, our legal basis for collecting and using the Personal Data described above and will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only

1. • where we have your consent to do so,
   • where we need the Personal Data to perform a contract with you, or
   • where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms

In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirements or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, please contact us at [email protected]

5.1.3 Your Rights to Your Information

You have the right to request that SILESKASEO

1. • provide you with access to the Personal Data we hold about you,
   • correct your Personal Data,
   • Export your Personal Data,
   • delete your Personal Data, and
   • cease or restrict processing of your Personal Data

If you are a User and would like to understand what Personal Data and behavioural information SILESKASEO holds about you, specifically, and how you can exercise any of your rights with respect to your Personal Data, please submit a data subject access request by emailing us at [email protected] so that SILESKASEO may either respond with the relevant information or, if applicable.

You have the right to complain to a data protection authority about our collection and use of your Personal Data. To learn more, please contact your local data protection authority, via the contact methods available here. However, if you have any questions about our collection and use of your Personal Data, please first contact us at [email protected]

5.1.4 EEA/UK Data Transfers

As part of SILESKASEO’s global operations, our data flows between the EEA, the UK and other country.

When SILESKASEO transfers any personal data from the EEA within the SileskaSeo Agency in the United Kingdom, it relies on the European Commission’s decision that the UK provides a level of data protection that is adequate for personal data from the EEA.

Beyond that, when SILESKASEO transfers EEA/UK Data to other countries then, if those countries do not have a European Commission adequacy finding and are not the subject of UK adequacy regulations (as applicable), SILESKASEO implements Standard Contractual Clauses approved by the European Commission and/or competent UK authorities (as applicable) to protect the transferred data.

In particular, non-EEA/UK SILESKASEO Affiliates, like our Company in the United States, have accordingly adopted Standard Contractual Clauses to ensure the legality, privacy, and security of the data flows necessary to provide, maintain, and develop our services.

5.2. Data transfer in the State of California

5.2.1. Your Rights to Your Personal Information

California residents have the right to request that SILESKASEO

1. • provide you with access to the Personal Information that we hold about you,
   • correct your Personal Information,
   • delete your Personal Information, and
   • cease or restrict disclosures or sales of your Personal Information to third parties.

You also have a right against discrimination for exercising any of these rights, which SILESKASEO is committed to upholding and honouring at all times. If you would like to opt out of SILESKASEO‘s disclosures and sales of your Personal Information, you may do so by emailing us at [email protected].

5.2.2. Categories of Data that SILESKASEO Holds about You

If you are a Customer, Site Visitor, or User our legal basis for collecting and using the Personal Data described above and will depend on the Personal Data concerned and the specific context in which we collect it.

At the same time SILESKASEO may maintains unidentifiable information about you in only pseudonymized form, which means that we do not know your identity because we do not process your name, email address, or other identifiable information. Instead, we only process digital identifiers such as cookie IDs, IP addresses, dUser Agent on your device, network browsing history and associated preferences.

5.2.3. Why SILESKASEO Collects your Personal Information

SILESKASEO processes your Personal Information in order to provide personalized content and advertisements to you, as well as for fraud-analysis to fraud-prevention with in-house product and Our Services.

5.2.4 Where SILESKASEO Collects Your Personal Information

We automatically collect User Information when Users interact with our Services that appear on our Customers’ websites and digital properties. Like most other web-based services, we collect this User Information through cookies and other technologies. We may also obtain Information about you from our data partners.

SILESKASEO collects Information either directly from you during your use of our Sites and Services or from third parties that independently collect this Information from you, and we may combine the Information that we collect from these various sources.

5.2.5 How SILESKASEO Shares Your Personal Information

SILESKASEO may disclose or make available your pseudonymous Personal Information to our trusted partners and other persons/companies as descrived above. In most cases when we do so, we have contractually restricted their uses of this data for only SILESKASEO‘s business purposes. Under the CCPA, such disclosures of Personal Information to service providers are not deemed to be a “sale” and thus are not prohibited after you exercise your right to cease or restrict disclosures or sales of your Personal Information to third parties. In any instances where we have not entered into a service provider relationship with such third parties, we will stop sharing your Personal Information when you instruct us not to “sell” your Personal Information.

5.3. Data transfer in Thailand

5.3.1 Data Controller/Processor

If you reside in Thailand, Affiliate/Subcidiary of SileskaSeo Agency will be the controller of your Personal Data provided to, collected by or for, or processed by SILESKASEO in connection with our Services.

5.3.2 Legal Basis for Processing Personal Data

If you are a Customer, Visitor, or User from Thailand, our legal basis for collecting and using the Personal Data described above and will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only

1. • where we have your consent to do so,
   • where we need the Personal Data to perform a contract with you, or
   • where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms

In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

5.3.3 Your Rights to Your Information

You have the right to request that SILESKASEO

1. • provide you with access to the Personal Data we hold about you,
   • export your Personal Data,
   • delete your Personal Data, and
   • cease or restrict processing of your Personal Data.

If you are a User and would like to understand what Personal Data and behavioural information SILESKASEO holds about you, specifically, and how you can exercise any of your rights with respect to your Personal Data, please submit a data subject access request by emailing us at [email protected] so that SILESKASEO may either respond with the relevant information or, if applicable, direct this request to, and cooperate with, your employer to respond.

If you have any questions about our collection and use of your Personal Data, please first contact us at [email protected].

5.3.4 Thailand Data Transfers

SILESKASEO transfers data outside of Thailand. SILESKASEO has in place an Inter Group Data Transfer Agreement across its international entities and ensures a high level of security of transferred data.

As part of SILESKASEO’s global operations, our data flows between Thailand, the EEA, the United States and other countries. To ensure that Thailand Data is adequately protected when transferred outside of Thailand, the Personal Data Protection Act, B.E. 2562 mandates that such transfers take place using certain legal mechanisms.

When transferring Thailand data elsewhere, SILESKASEO relies on Standard Contractual Clauses, set forth by the European Commission, that outline contractual privacy and security commitments between companies that transfer personal data (for example, between companies within SileskaSeo Agency). SILESKASEO and its Affiliates have accordingly adopted Standard Contractual Clauses to ensure the legality, privacy, and security of the data flows necessary to provide, maintain, and develop our services.

5.4. Data transfer in Brazil

5.4.1 Data Controller

If you reside in the Federative Republic of Brazil (“Brazil”), Affiliate/Subcidiary of SileskaSeo Agency will be the controller of your Personal Data provided to, collected by or for, or processed by SILESKASEO in connection with our Services.

5.4.2 Legal Basis for Processing Personal Data

If you are a Customer, Visitor, or User from Brazil, under the Lei Geral de Proteção de Dados federal law 13,709/2018 (the “LGPD”), our legal basis for collecting and using the Personal Data described above (also referred to in this Section 5.4 as “Brazil Data”) will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only

1. • where we have your consent to do so,
   • where we need the Personal Data to perform a contract with you, or
   • where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms

In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), a notice will be provided to you in our disclosure statement.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, please contact us via [email protected].

5.4.3 Your Rights to Your Personal Data

You have the right to request that SILESKASEO

1. • confirm whether we are processing your Personal Data,
   • provide you with access to the Personal Data we hold about you,
   • disclose the public and private entities with which we have shared use of your Personal Data,
   • correct your Personal Data,
   • export your Personal Data, for your own use or use by another controller
   • anonymize, block, or delete any unnecessary or excessive data,
   • delete all your Personal Data, and
   • cease or restrict processing of your Personal Data.

If you are a User and would like to understand what Personal Data and behavioural information SILESKASEO holds about you, specifically, and how you can exercise any of your rights with respect to your Personal Data, please submit a data subject access request by emailing us at [email protected] so that SILESKASEO may either respond with the relevant information or, if applicable, direct this request to, and cooperate with, your employer to respond.

5.4.4. Brazil Data Transfers

SILESKASEO transfers data outside Brazil. As part of SILESKASEO’s global operations, our data flows between Brazil, the EEA, the United States, and other countries. To ensure that Brazil Data is adequately protected when transferred outside Brazil, the LGPD mandates that such transfers take place using certain legal mechanisms. SILESKASEO has in place an Inter Group Data Transfer Agreement across its international entities, which is based on the EEA’s standard model clauses, and which may be updated upon further guidance from the future ANPD.

1. 1. Rights of individuals

6.1. It is important for our User, Visitors and Customers to be aware about individual rights under the General Data Protection Regulation (GDPR). SILESKASEO has a responsibility to make individuals aware of their rights and ensure mechanisms are in place to act on these. In order to do this it is important that you are aware of these rights.

6.2. The rights are:

6.2.1. Right to be informed.

Providing clear and correct information is a key duty in many regards. Personal data that have undergone an action as a consequence of one of the other data subject rights, the controller must inform recipients who got these data, where feasible.

6.2.2. Right of access which means:

1. 1. the right to know whether data concerning him or her are being processed and
   2. if so, access it with loads of additional stipulations (GDPR Article 15). The data subject’s right to rectification. When personal data are inaccurate, then controllers need to correct them indeed (GDPR Article 16).

6.2.3. Right to rectification.

Individuals have the right to have personal data rectified. If find out that your personal data is not accurate, contain incorrect information, our Users, Visitors, Customers have the right to contact SILESKASEO with request to rectified it via [email protected]. SILESKASEO must rectify any inaccurate personal data that relates to the individual without undue delay and in any event within one month.

6.2.4. Right to erasure/to be forgotten.

The underlying principle of this right is that when there is no compelling reason for their data to be processed, the data subject can:

1. 1. request the data controller erase/remove their personal data);
   2. stop any further distribution of their personal data;
   3. potentially stop third parties from processing their personal data.

Individuals have the right to have their data erased and stopped processing:

1. • when the original purpose for the personal data is no longer necessary or the data itself is no longer necessary for the purpose.
   • when the individual no longer consents.
   • if the individual objects to their data being processed and there is no legitimate reason to override this objection.
   • if the data being processed relates to the offer of information society services to a child.
   • if the data is ever processed in breach of data protection regulations (i.e. GDPR).

6.2.5. Right to restrict processing.

Users, Visitors and Customers have the right to make a request for restriction via [email protected]. This is not an absolute right and only applies in certain circumstances. When processing is restricted, SILESKASEO are permitted to store the personal data, but not use it.

6.2.6. Right to data portability, Users, Visitors and Customers have the right to move, copy, or transfer personal data from one data controller to another, in a safe and secure way, in a commonly used and machine-readable format.

6.2.7. Right to object and rights in relation to automated decision making and profiling.

Users, Visitors and Customers have the right to object to being subject to SILESKASEO processing their data without explicit consent. Users, Visitors and Customers have the right to stop personal data from being included in direct marketing databases. To perfom these rights Users, Visitors and Customers have to contact SILESKASEO with request via [email protected].

1. 1. Cookies Policy

7.1. Cookies Information:

Like many websites, we mostly use cookies and pixel tags to collect this Usage Information. A cookie is a small file containing a string of characters that is sent to your computer and stored on your hard drive when you visit a website; each website can send its own cookies to your browser. A pixel tag is a small graphic file that allows us to measure the use of SILESKASEO services. Pixel tags allow us to collect information such as IP address of the computer that downloaded the page on which the tag appears, the URL of the page on which the pixel tag appears, the time (and length of time) the page containing the pixel tag is viewed, and the identification number (the long string of characters) of any cookie previously placed by that server on your computer. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

7.2. Cookies Options:

We use cookies to uniquely identify a browser, which gives advertisers the ability to show targeted ads that are relevant to you. If you would prefer us not to store a unique cookie in your browser, you may opt out. Note that by opting out, you still will receive advertising from SILESKASEO when you visit our websites – it just will not be targeted to you.

Our tracking mechanisms operate at the device and browser level, to fully opt-out across devices, you will need to do so on each device and browser individually. If your browsers are configured to reject cookies, your opt-out may not be effective, since we identify your choice to opt-out based on an opt-out cookie we deliver to you. In this case, you will need to confirm that your browser is configured properly in order for the opt-out to be effective. If you are using a Safari browser on iOS11 or macOS High Sierra, you must first adjust your Privacy and Security Settings to turn off both “Prevent Cross-Site Tracking” and “Block All Cookies”, and then return to this privacy policy or your preferred opt out platform to reset your opt out preferences.

We may use non-cookie technologies in limited cases. Like cookies, these technologies allow Us to recommend ads that are tailored to your interests and to remember whether you have chosen to opt-out from our Services. Please note that some web browsers may not permit you to block the use of non-cookie technologies, but you can do so by simply clicking on the Opt Out feature.

7.3.Analytics Information:

We use both our and third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, your browser’s width and height, and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

7.4. Log File Information:

Log file information is automatically reported by your browser each time you access a web page. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

7.5. Clear Gifs/Web Beacons Information:

When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users anonymously. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information is allows for more accurate reporting and improvement of the Service.

7.6. Information Collection on Partner Sites

We may receive, transfer and collect information from users of third party sites which use the SILESKASEO service (“Partner Sites”) about you and your usage of the SILESKASEO Service on their sites. Unless you have allowed the Partner Site to share Personally Identifiable Information, such information will not include Personally Identifiable Information, but may include Non-Personally Identifiable Information and/or report anonymous information about your usage of the Partner Site and the SILESKASEO Service on that site.

8.Ads on SILESKASEO

We may also share certain information such as your location, browser and cookie data and other data relating to your use of our Service with our business partners to deliver advertisements (“ads”) that may be of interest to you. SILESKASEO may allow third-party ad servers or ad networks to serve advertisements on the Service. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Service, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browser’s or device’s visits and usage patterns on the Service, and to measure the effectiveness of their ads and to personalize the advertising content. SILESKASEO does not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.

Please note that an advertiser may ask SILESKASEO to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, SILESKASEO determines the target audience and SILESKASEO serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

The SILESKASEO Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

1. 1. Changing or Deleting Your Information

All registered users may review, update or correct the Personally Identifiable Information provided in their registration or account profile by changing their “user preferences” in their account. If you choose to opt out entirely, then your account may become deactivated and you will need to re-register should you decide to opt-in again. To delete your account and information entirely or to prevent SILESKASEO from processing your data please email us at [email protected]. However, you understand and agree that we are not able to remove your Personally Identifiable Information from the records of any third party who has been provided with your information in compliance with the use and sharing policy outlined above.

We retain User Information, which is directly collected for purposes of Services, for at most thirteen (13) months from the User’s last interaction with our Services (often for a shorter period of time), after which time we de-identify the data by removing unique identifiers or aggregating the data.

We retain deidentified or aggregated data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as commercially necessary. We keep opt-out information for longer than this period so that we can continue to honor your opt-out requests.

In the event that we are unable to isolate certain Personal Data and comply with a deletion request, we will instead enforce strict access controls and data destruction.

1. 1. Security

SILESKASEO is very concerned with safeguarding your information. SILESKASEO uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from SILESKASEO, at all times. Notwithstanding the foregoing measures, SILESKASEO cannot ensure or warrant the security of any information you transmit to SILESKASEO or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of SILESKASEO‘ distributors, such as social networks. SILESKASEO is not responsible for the functionality or security measures of any third party.

11.Policy Towards Children

This Site is not directed to children under 16. We do not knowingly collect or solicit personal information from children under 16 or knowingly allow such persons to register for an account. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 is allowed to provide any personal information to or on SILESKASEO. In the event that we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at [email protected].

1. 1. Data Protection Terms for European Economic Area

If your agreement with SILESKASEO incorporates this policy, or you otherwise use a SILESKASEO product that incorporates this policy, you must ensure that necessary disclosures are given to, and consents obtained from, end users in the European Economic Area or outside. If you fail to comply with this policy, we may limit or suspend your use of the SILESKASEO’s services and/or terminate your agreement.

Properties under your control. For SILESKASEO services used on any site, app or other property that is under your control, or that of your affiliate or your client, the following duties apply for end users in the European Economic Area.

You must obtain end users’ legally valid consent to the use of cookies or other local storage where legally required and the collection, sharing, and use of personal data for personalization of ads.

When seeking consent you must retain records of consent given by end users; and provide end users with clear instructions for revocation of consent. You must clearly identify each party that may collect, receive, or use end users’ personal data as a consequence of your use of SILESKASEO Services. You must also provide end users with easily accessible information about that party’s use of end users’ personal data.

Properties under a third party’s control. If personal data of end users of a third party property is shared with SILESKASEO due to your use of, or integration with, SILESKASEO services, then you must use commercially reasonable efforts to ensure the operator of the third party property complies with the above stated duties.

Protection of Data Provider Personal Data. If you are accepting these Privacy Policy on behalf of your customer, you warrant that: (a) you have full legal authority to bind Customer to these Privacy Policy; (b) you have read and understand these Privacy Policy; and (c) you agree, on behalf of Customer, to these Privacy Policy. If you do not have the legal authority to bind Customer or your level of protection is not at least equivalent to that required under this Privacy Policy you should either cease processing the personal data or take reasonable and appropriate steps to remedy such non-compliance

1. 1. Accesses, uses, stores, or shares Google user data

When you register for a SILESKASEO, you allow this Service to identify and give you access to dedicated services.

Direct registration – The User registers by filling out the registration form and providing the Personal Data directly to SILESKASEO.

If third party registration and authentication services are used SILESKASEO will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Google OAuth (Google Inc.)

Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network. Personal Data collected: various types of Data as specified in the on-screen privacy notice displayed when using this registration method and in the general privacy policy of the service https://www.google.com/policies/privacy/

When you register for a SILESKASEO account with the Service we may receive your email from such third parties as Google and use this email for registration and authorisation. We use, store, or/and share this information solely in the ways and for the purposes provided in this Privacy Policy.

SILESKASEO App’s use of information received from Gmail APIs will adhere to Google’s Limited Use Requirements.

1. 1. Links to Other Web Sites

We are not responsible for the practices employed by websites linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our website, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

SILESKASEO may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the bottom of this page. Your continued use of the Site following the posting of any changes to this policy means you accept such changes.

We reserve the right to transfer your personal information in the event of a transfer of ownership of SILESKASEO, such as acquisition by or merger with another company.

From time to time we may update this Privacy Policy. You should visit this page periodically to review any such changes to the privacy policy. In such cases, your continued use of this website or our service means that the provision of personally identifiable information to us after such material changes will be subject to the new terms. If we make material changes to this Privacy Policy that expand our rights to use your personal information that we have collected, we will notify you to seek your consent through email or a prominent posting on the site. You always have the option to cancel your account with us at any time. Simply de-install the widget from your site. If you have any questions or need some clarification on our privacy policy, please do not hesitate to email us at [email protected].