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1. Data Controller and General Presentation of the Policy
Data controller: Spotware Systems Ltd, a limited liability company incorporated in the Republic of Cyprus, with a registered address at 78 Spyrou Kyprianou, Magnum House, 3rd Floor, 3076 Limassol, Cyprus and incorporation number HE301668, owner of the website spotware.com (hereinafter "Spotware" or "we").

Spotware, through its website, collects and processes certain personal data relating to its users ("You" or the "user").

Personal data is any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more specific elements such as his or her physical, economic, cultural or social identity (the "personal data").

In accordance with the General Regulation of the European Parliament and of the Council on Data Protection No. 2016/679 of 27 April 2016 (the "GDPR"), in its current version, the purpose of this Privacy Policy (the "Policy") is to inform You about the data we collect about You, the processing we carry out and its purpose, the periods of retention of Your data, the recipients of Your data as well as the rights You have.

The Policy completes the contractual conditions which govern the Website and which You accept by using the Website (as well as the other conditions which You accept for specific services or according to Your status, hereafter jointly the "Terms").

1. Modification of the Policy
   The Policy can be modified at any time. The current version is the one available on the Website. In the event of a significant change to the Policy, we will inform You within a reasonable period of time (by email or by banner ("push") on the Website).
   
   Spotware may ask You at any time and by any means that can be recorded to confirm that You have read and understood the Policy.
2. Personal Data Collected on the Website
   We collect Your data mainly from You directly, but also from third parties who want You to benefit from our services, advertising partners and social networks depending on the authorisations You provide them directly.
   
   On our Website, the mandatory nature of the data to be provided is indicated to You at the time of collection (e.g. by an asterisk). If You do not fill in the mandatory fields, we will not be able to provide You with all our services.
3. Collection of Data
   We collect Your data mainly from You directly, but also from third parties who want You to benefit from our services, advertising partners and social networks depending on the authorisations You provide them directly.
   
   You will find below a list of all the data that we may collect and process about You depending on Your use of the Website and the authorisations You provide.
   
   Information related to Your identity and the creation of Your account: full name, username, email address, phone number, password, date of birth or confirmation of majority, profile picture and other information that may be related to the creation of your account.
   Information about Your device, account and activity: IP address, session information, cookies and trackers, consent and refusal, date and time of consent, user profile, language, preferences, browser used by your device, content and URLs You connect to, date and time of Your connections.
   Information about Your interactions with the Website and other users: name of the user You are communicating with, messages, date and time of messages, photos shared, other data indicated in messages, reviews, rating, date and time of review, response to review, Your comments and public messages on the Website.
   Information relating to the management of the messages You write to us, the management of disputes and inappropriate behaviour: messages (requests, complaints) sent to customer service, type of warning received by the user, date of receipt of the warning by the user, complaint from a user (content, reason, date and time).
   Sensitive data: We do not collect sensitive data. Any sensitive personal data collected and/or processed by us will be done so only with Your explicit consent and never without Your knowledge. In any case, we invite You to communicate only strictly necessary information, in particular in the free comment zones.
4. Processing that We Carry Out to Execute Pre-contractual Measures and Our EULA Terms and Conditions
   We process Your personal data in order to:
   1. allow You to create an account on the Website;
   2. help You manage Your account;
   3. enter into contracts with us;
   4. provide You with our services;
   5. notify You of any event related to Your account, from its creation to its deletion by emails and notifications;
   6. notify You when we update (add, modify, delete, etc.) our EULA Terms and Conditions, the Policy, our commission grid and, more generally, our services and features by emails and notifications;
   7. notify You when Spotware and/or its partners need to carry out some additional verifications (identity, proof of residence, etc.) by emails and notifications;
   8. notify You when we have detected a problem that is blocking or may block Your use of the Website by emails and notifications;
   9. answer Your questions, requests and complaints addressed to the customer support department by emails and notifications.
5. Processing that We Carry Out on the Basis of Our Legitimate Interests
   This category of processing is based on our legitimate interests. In order to legally base a processing operation on legitimate interest, three cumulative conditions must be met: (i) the interest pursued must be legitimate (i.e. lawful, clearly and precisely determined, real and present); (ii) the processing carried out must be necessary and; (iii) the processing must not adversely affect the rights and interests of data subjects.
   For Your complete information, we detail below the processing operations and the corresponding legitimate interests. We have ensured that these processing operations do not infringe Your fundamental rights and freedoms.
   
   We process Your personal data in order to:
   1. give You advice by emails and notifications;
   2. present You, by emails and notifications, with content, products and information that may be of interest to You based on the content You view as we have a legitimate interest in seeking the best possible user experience and improving our Website, services and features, to personalise the experience for everyone;
   3. offer You the opportunity, by emails and notifications, to participate in surveys (e.g. satisfaction, opinion, poll, etc.) because we have a legitimate interest in collecting feedback from our users to improve the Website. You are free to participate or not, without any consequences. Your answers are then processed on the basis of Your consent;
   4. allow other users to have access to certain information about You (username, date of registration, as we have a legitimate interest in building trust between users and between our users and us;
   5. implement detection measures to fight against fraud and ask You to perform security checks on Your account. A review is then carried out by our anti-fraud department, which may contact You to verify Your identity. We have a legitimate interest in guaranteeing the security of the Website and of users and to fight against all forms of fraud;
   6. access and moderate content, messages and conversations because we have a legitimate interest in improving the security and quality of this service, ensuring compliance with our Terms and Conditions, detecting illegal, unsolicited content or malware, improving the functionality of the messaging system, resolving disputes between users, processing reports and complaints sent by users, fighting against fraud and counterfeiting and protecting our users;
   7. perform marketing statistics and analysis in order to (i) understand how You use the Website and our services and to (ii) improve our Website and our service because we have a legitimate interest in seeking the best possible user experience and improving our Website, services and features, and in personalising the experience for everyone;
   8. train our customer care team and improve our customer care service by reviewing the conversations You have with our agents so as to ensure customer satisfaction.
6. Processing We Carry Out Only with Your Consent
   We process Your personal data in order to:
   1. Subscribe You to our newsletters. You can deactivate them at any time through the link provided in the newsletters or directly from Your account;
   2. send You the product alerts You have set up from Your account. You can deactivate Your alerts directly from your account that You have programmed directly from Your account;
   3. customise the ads that appear on third-party sites so that You are not exposed to ads that are not relevant to you. You can disable them by changing Your cookie settings (see the "Cookies" section of the Policy);
   4. analyse the answers you agree to share with us when You respond to our surveys (satisfaction, poll, feature testing, etc.);
   5. share Your strictly necessary data with our partner brands when You agree to participate in operations. In this case, You will be given information specific to the operations and partner brands;
   6. collect Your phone number for the purpose of performing specific activities such as our customer care service, which includes, for example, our call-back feature.
7. Length of time personal data are kept
   We retain Your personal data for the strict period of time necessary to fulfil the purpose of the processing concerned. Thus:
   1. the data associated with Your account is retained as long as You maintain Your account and until Your account is deleted;
   2. the data relating to the sending of newsletters and alerts are kept as long as You do not withdraw Your consent by unsubscribing;
   3. the data collected in the context of the execution of specific contracts are kept for the duration of their execution and are then archived for the strict legal prescription periods applicable;
   4. the data related to the management of complaints, disputes and litigation are kept for the duration necessary to resolve the dispute and for the duration of any applicable statute of limitations;
   5. the answers to surveys are kept for the time necessary for the survey and are then anonymised if they were not already;
   6. the data related to online applications are kept for two (2) years and then deleted. In some cases, we may retain certain personal data about You even if You delete Your account, by legal obligation, or if we have an overriding legitimate interest in retaining some of Your data (e.g. there is an issue with the account, the presence of an unresolved claim or dispute, the defence and exercise of our rights, etc.). In this case, the data necessary for the resolution of the case will be kept for as long as the dispute lasts within the limit of the applicable rules on prescription.
8. Recipients to Whom Your Data Are Transmitted
   Spotware is committed to implementing and maintaining appropriate technical and organisational measures for the processing and security of personal data in accordance with Articles 32 to 34 of the GDPR in order to protect Your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. We pass on these obligations to our service providers and subcontractors.
9. Cookies
   Spotware uses internet cookies to facilitate navigation throughout the website and to enhance the visitor's experience. Your internet browser is likely to accept these cookies by default. However, You can refer to Your browser’s help guide if You would like to reject or delete them from Your system. We may use both "analytic" cookies and "social" cookies on the website. Cookies used by Spotware do not retrieve any personal information or any information from the visitor’s computer.
10. Contact
    If You have any further questions about how Spotware collects and processes Your personal data, please contact us via our Data Protection Officer at dpo@spotware.com