This Privacy Policy is up to date as of 04/10/2023.
1. DATA PROCESSOR AND DATA CONTROLLER
The entity responsible for processing personal data, fulfilling the roles of both a data controller and a data processor in accordance with EU GDPR, is Wolvio, a registered company in Republic of Cyprus. Our registered office is located at Palaikythrou 7, Nicosia, Cyprus, 2572, and our company registration number is HE 426604.
We place utmost importance on safeguarding users' data and respecting their privacy. This policy outlines the information that is processed, the timing of processing, the purposes, and the legal basis for such processing. It provides users with an understanding of how our website services operate and how we ensure the protection of their personal data.
If you have any inquiries or concerns regarding this Privacy Policy, including requests to exercise your legal rights, please do not hesitate to reach out to our Data Privacy Controller using the contact information provided below:
Company name: Wolvio
Post address: Palaikythrou 7, Nicosia, Cyprus, 2572
Email address: [email protected].
2. COLLECTED DATA
Secret Digit collects various types of Personal Data, which may be obtained either directly from Users or through third parties. These data include usage data, as well as personal information such as names, last names, email addresses, phone numbers, passwords, company names, VAT identification numbers, countries, and Cookies.
Users may voluntarily provide Personal Data, while certain data, particularly Usage Data, are collected automatically when using this website.
It is important to note that some of the requested data are mandatory, and refusal to provide them may render it impossible for this website to deliver the Service. However, when specific data are indicated as non-mandatory, Users have the freedom to withhold such information without affecting the availability or functionality of the Service.
The use of Cookies or other tracking tools by the site or third-party service providers used by this website is primarily aimed at delivering the requested Service. This usage also aligns with other purposes outlined in this document and in the Cookies Policy.
Users are responsible for any Personal Data of third parties that they obtain, disclose, or share through Secret Digit. By doing so, Users confirm that they have obtained the necessary consent from these third parties to provide their Data to the Data Controller.
3. HOW AND WHERE THE COLLECTED DATA IS PROCESSED
A. Legal Basis for Processing
The Data Controller may process the User's Personal Data under the following conditions:
- When Data collection is necessary for the performance of a contract with the User and/or any pre-contractual obligations.
- When Users have given their consent for one or more specific purposes until they object to the processing.
- When processing is necessary to comply with a legal obligation that the User must adhere to.
- When processing serves the legitimate interests of the Data Controller or a third party.
- When processing is related to a task carried out in the public interest or in the exercise of official powers vested in the Data Controller.
In any case, Wolvio is available to specify the legal bases that apply to the processing, including whether the collection of Personal Data is a contractual or statutory requirement or a necessary step to formalise a contract.
B. Processing Methods
The Data Controller will process Users' Data in an appropriate manner and implement suitable security measures to prevent unauthorised access, disclosure, alteration, or destruction of the Data.
Data processing will be conducted using computers and/or IT tools, following organisational procedures and methods directly related to the stated purposes.
In addition to the Data Controller, certain authorised individuals associated with the operation of this Site or external contractors providing services to the Data Controller (such as external technical service providers, hosting companies, IT firms, and communication agencies) may access the Data. If necessary, these individuals will be appointed by the Data Controller as Data Processors. An up-to-date list of such individuals may be requested from the Data Controller at any time.
C. Retention Period
Personal Data will be processed and retained for the period required to achieve the purpose for which it was collected. Therefore:
- Personal Data collected for the formalization of a contract between the Data Controller and the User will be retained until such contract is fully formalised.
- Personal Data collected in the legitimate interest of Wolvio will be kept for as long as necessary to fulfil that purpose.
- The Data Controller may retain Personal Data for an additional period with the User's consent, provided the consent remains valid.
- Additionally, the Company may be obliged to retain Personal Data for a longer period to comply with legal obligations or orders from authorities.
- Secret Digit will delete any user information upon their request, no later than fifteen days after receiving the request.
Once the retention period expires, Personal Data must be deleted. Consequently, rights such as access, modification, rectification, and data portability may not be exercised after this period.
D. Location of Processing
Data is processed at the Data Controller's offices and any other locations where the parties involved in processing are situated. Depending on User locations, Data transfers may involve sending User Data to a country other than their own.
The information will be stored on secure servers, maintained and monitored with appropriate privacy protections. The Data Controller may store or transfer Data Subject Information located in the EU to servers situated in countries deemed appropriate by the European Commission, or in countries not deemed inappropriate by the European Commission, provided such countries implement adequate safeguards regarding the security of personal information.
4. PURPOSE OF THE PROCESSING OF DATA
User Data is collected by Secret Digit for the following purposes:
- To provide its Services.
- To detect malicious or fraudulent activity.
- To respond to execution requests.
- For advertising and infrastructure monitoring.
- For payment processing.
- To fulfil its legal obligations.
- For statistical analysis.
- For registration and authentication.
- To manage contacts and send messages.
- To protect its rights and interests (or those of its Users or third parties).
- For traffic optimisation and distribution.
If the Data Controller intends to use, handle, or process any Personal Data in a manner inconsistent with this Policy, Secret Digit will notify Users of such changes by posting a notice on the Site before the changes take effect. Users will be considered to have consented to these changes if no objection is received within one week from the date of the change. For EU-based Users, Secret Digit will also send notifications of such changes via email, and Users must respond accordingly to indicate their consent or objection to the changes.
5. COOKIES
Secret Digit employs cookies that are necessary for the proper functioning and operation of the services. Additional non-essential cookies will only be used with the user's consent. To learn more, please refer to secretdigit.com/en/page/cookie.
6.USER RIGHTS
Users have several rights regarding the processing of their Data by the Data Controller. These rights include:
- Withdrawal of Consent: Users can withdraw their consent at any time if they previously provided consent for the processing of their Personal Data.
- Access to Data: Users have the right to know if the Data Controller is processing their Data, obtain information about the processing details, and receive a copy of the Data being processed.
- Objection to Data Processing: Users can object to the processing of their Data if it is based on legal grounds other than consent.
- Data Processing Restriction: In certain cases, Users can request the restriction of their Data processing, during which the Data Controller will only store the Data.
- Verification and Amendment: Users can verify the accuracy of their Data and request updates or corrections.
- Deletion of Personal Data: Users can, in specific cases, request the deletion of their Data by the Data Controller.
- Complaint Submission: Users have the right to file a complaint with the relevant data protection authority.
- Data Portability: Users can receive their Data in a structured, machine-readable format and, if technically feasible, transfer it to another Data Controller without hindrance, provided the processing is based on consent, a contract, or pre-contractual obligations.
Users may also object to the processing of their Personal Data in certain circumstances, such as when it is for commercial purposes, without providing a specific reason.
Requests to exercise these rights can be made to the Data Controller using the contact details provided. The Data Controller will process these requests free of charge, promptly, and within one month.
7. FINAL CLAUSES
Except where prohibited by law, the Data Controller shall not be liable for any direct, indirect, special, incidental, consequential, or exemplary damages resulting from any aspect of the Company's use of third-party Personal Data provided by the User. These limitations shall apply to the fullest extent permitted by law. In some jurisdictions, certain limitations mentioned above may not be applicable.
The User's Personal Data may be used for the legal defence of the Data Controller before a court or during the judicial phases preceding a potential lawsuit arising from the inappropriate use of this website or the related Services. The User acknowledges that the Data Controller may be obligated by public authorities to disclose Personal Data.
Secret Digit reserves the right to modify this privacy policy at any time by notifying Users through this page and, if possible, via the user account area. If technically and legally feasible, direct notifications will be sent to Users if Secret Digit has the necessary contact information for this purpose. We strongly recommend that you regularly review this page, referring to the date of the last update provided at the bottom of the page.
If the changes affect processing activities based on the User's consent, the Data Controller will, if necessary, seek the User's new consent.