Cybertino Privacy Notice

Effective Date: [May 15th, 2021]

Welcome! We are Cybertino, the world’s first interactive NFT platform for influencers and fans. This Privacy Notice explains how Cybertino, Inc. (“Cybertino”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our website, cybertino.com (the “Site”), and the related content, platform, services, products, and other functionality offered on or through the online services (the “Services”). It does not address our privacy practices relating to Cybertino employees and other personnel.

This Privacy Notice is not a contract and does not create any legal rights or obligations.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

  • Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at privacy@cybertinolab.com to submit such a request.
  • California: If you are a resident of the State of California in the U.S., please see our California Privacy Notice for additional California-specific privacy information.
  • European Economic Area, United Kingdom or Switzerland: If you are located in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland, or otherwise engage with our European operations, please see the European Privacy Notice for additional European-specific privacy information, including what constitutes your personal data, the lawful bases we rely on to process your personal data, how we use cookies when you access our Site from the EEA, UK or Switzerland, and your rights in respect of your personal data.

What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Our Collection of Personal Information

Sometimes we collect personal information automatically when an individual interacts with our Services and sometimes we collect personal information directly from an individual. At times, we may collect personal information about an individual from other sources and third parties, even before our first direct interaction.

Personal Information Collected from Site Visitors and Account Holders

We collect the following personal information submitted to us by visitors to our Site and account holders:

  • Contact Information, including first and last name, email address, mailing address, employer, job title, company name, phone number and communication preferences.
  • Inquiry Information, including information provided in custom messages sent through the forms or contact information provided on our Site.
  • Account Information, including first and last name, email address, username and password, profile information, cryptocurrency wallet address and related information, account balances, payment and purchase history information, and any other information you provide to us. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Site.
  • Online Marketplace and Community-Related Information, including username, photo, location, social media profiles, company name, and areas of expertise and interests.
  • Employment Application Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.
  • Event Information, including registration information, attendee badge information, and contact information.

Personal Information Automatically Collected

As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions and site usage patterns automatically when visiting or interacting with our Site, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Site and any errors that may occur during the visit to our Site), analytics data (such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site) and location data (such as general geographic location based on the log data we or our third-party providers collect).

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information.

For more information about these practices and your choices regarding cookies, please see our Cookie Notice.

Personal Information from Thrid Parties

We also obtain personal information from third parties; which we often combine with personal information we collect either automatically or directly from an individual.

We may receive the same categories of personal information as described above from the following third parties:

  • Third-Party Wallet Extensions: Cryptocurrency wallets may provide us with your Ethereum address and certain other information you choose to share with other cryptocurrency wallets.
  • Business Partners: We may receive your information from our business partners who provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Services.
  • Social Media: When an individual interacts with our Services through various social media networks, such as when someone logs in through a social network, “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
  • Service Providers: Our service providers that perform services solely on our behalf, such as payout processing and marketing providers, collect personal information and often share some or all of this information with us.
  • Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual.
  • Third Parties Related to Employment Applications: If you apply for a job with Cybertino, we may receive information from your current or past employers, background check providers, third-party social media platforms and other third parties we use to obtain information about job applicants.
  • Publicly Available Sources: We collect personal information about individuals that we do not otherwise have, such as contact information, employment-related information, and interest-in-services information, from publicly available sources. We may combine this information with the information we collect from an individual directly. We use this information to contact individuals, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.

Our Use of Personal Information

We use personal information we collect to:

  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions, including facilitating your cryptocurrency transactions;
  • Manage our organization and its day-to-day operations;
  • Communicate with individuals, including via email, text message, social media and/or telephone calls;
  • Market our Services to individuals, including through email, direct mail, phone or text message;
  • Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site;
  • Process payment for our Services;
  • Facilitate client benefits and services, including customer support through our command center services;
  • Identify and analyze how individuals use our Site and Services;
  • Conduct research and analytics on our client base and our Services;
  • Improve and customize our Services to address the needs and interests of our client base and other individuals we interact with;
  • Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
  • Help maintain the safety, security and integrity of our property and Services, technology assets and business;
  • Evaluate your candidacy for employment, to communicate with you during the application process and to facilitate the onboarding process, if you are applying for employment.
  • Defend, protect or enforce our rights or applicable contracts and agreements;
  • Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and
  • Comply with legal obligations.

Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

Our Disclosure of Personal Information

We disclose Personal Information in the following ways:

  • Affiliates. We may share personal information with other companies owned or controlled by Cybertino, and other companies owned by or under common ownership as Cybertino, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
  • Third-Party Wallet Extensions. We may share your information with cryptocurrency wallets to process cryptocurrency transactions.
  • Your Employer / Company: If you apply for a job with Cybertino, we may disclose your information to your current or former employer or company, including another representative of such employer or company.
  • Online Marketplace Community Members: If you participate in any of our online communities or buy or sell on our Services, we may disclose your public profile information to other online community members, as well as any other information you choose to provide or make public.
  • Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
  • Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other sites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see our Cookie Notice for more information.
  • Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
  • Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services and administrative services.
  • Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
  • Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
    • in connection with the establishment, exercise, or defense of legal claims;
    • to comply with laws or to respond to lawful requests and legal process;
    • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
    • to detect, suppress, or prevent fraud;
    • to protect the health and safety of us and others; or
    • as otherwise required by applicable law.
  • Otherwise With Consent or Direction: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Site or service-related publications.

Children's Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

Our Site and Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

Updates to This Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on this Site or our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@cybertinolab.com.

Alternatively, inquiries may be addressed to:

Cybertino, Inc. Attn: Privacy Department 651 N Broad St STE 206 Middletown, DE 19709

CYBERTINO CALIFORNIA PRIVACY NOTICE

Effective Date: [May 15th, 2021]

Scope of Notice

This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”). This CA Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA).

Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For the purposes of this CA Notice, personal information does not include:

  • Publicly available information from government records;
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer;
  • Information excluded from the CCPA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
  • Information relating to our employees, contractors and other Cybertino personnel.

Collection and Use of Personal Information

We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the “Our Collection of Personal Information” and “Our Use of Personal Information” sections of our Privacy Notice. In the last 12 months, we have collected the following categories of personal information:

  • Identifiers, such as your name and email address;
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your username and password and phone number;
  • Commercial Information, such as NFTs purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet/Network Information, such as device information, logs and analytics data;
  • Geolocation Data, such as your geolocation;
  • Education Information, such as academic background (for job applicants only);
  • Professional/Employment Information, such as your job history and information relating to your professional references (for job applicants only);
  • Sensory Information, such as photo or avatar, videos, and recordings of any phone calls between you and Cybertino;
  • Other Personal Information, including information you submit into the feedback form and any communications between you and Cybertino, as well as information we receive from social networking sites and address book information; and
  • Inferences, such as information generated from your use of the Services reflecting predictions about your interests and preferences.

We collect this information from the following sources: directly from you, from our business partners and affiliates, from your browser or device when you visit our Site or use our Services, or from third parties that you permit to share information with us. Please see the “Our Collection of Personal Information” section of the Privacy Notice for more information about the sources of personal information we collect.

Disclosure of Personal Information

As described in the “Our Disclosure of Personal Information” section of our Privacy Notice, we share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales.

The categories of third parties to whom we sell or disclose your personal information for a business purpose may include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) marketing and strategic partners; (iv) ad networks and advertising partners; (v) analytics providers; and (vi) social networks.

In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the “Collection and Use of Personal Information” section of this CA Notice, to third parties for a business purpose.

Unless you have exercised your Right to Opt Out of personal information sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):







The Right to Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: • The specific pieces of personal information we have collected about you; • The categories of personal information we have collected about you; • The categories of sources of the personal information; • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; • The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and • The business or commercial purposes for collecting or, if applicable, selling the personal information.



The Right to Request Deletion

You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

“Shine the Light”

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).

How to Exercise Your California Consumer Rights

To Exercise Your Right to Access, Right to Know or Right to Deletion

To exercise your Right to Know or your Right to Deletion, please submit a request by:

  • Emailing us at privacy@cybertinolab.com with the subject line, “California Rights Request”;
  • Filling out our California Consumer Rights Request Form.

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and/or date of last transaction on our Services. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

To Exercise Your Right to Opt Out of Personal Information Sales

As is common practice among companies that operate online, we allow certain third-party partners and providers to collect information about consumers directly through our Services, from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, and Inferences generated from your browsing history and interactions with our service as well as other sites and services. These third parties use your personal information for purposes of analyzing and optimizing our services and ads on our site, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, and may sell the information to third parties, including other advertising networks, for advertising and other purposes.

By visiting www.privacyrights.info or www.optout.privacyrights.info, you can also opt out from “sales” of this type of personal information by businesses that participate in the DAA’s CCPA Opt-Out Tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.

Please refer to the “Choices About Online Ads” section of the Cookie Notice for more information about the choices and opt-out options you may have in relation to those practices.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Notice where we can verify the authorized agent’s authority to act on your behalf. For requests to know or delete personal information, we require the following for verification purposes:

  • a power of attorney valid under the laws of California from you or your authorized agent; or
  • sufficient evidence to show that you have:
    • provided the authorized agent signed permission to act on your behalf; and
    • verified your own identity directly with us pursuant to the instructions set forth in this CA Notice; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of personal information “sales”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Minors Under 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at privacy@cybertinolab.com to inform us if you, or your minor child, are under the age of 16.

California’s “Shine the Light” Law

California's “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please contact us at privacy@cybertinolab.com and provide your contact information to be added to our suppression list.

Updates to This CA Notice

We will update this CA Notice from time to time. When we make changes to this CA Notice, we will change the "Effective Date” at the beginning of this CA Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this CA Notice or other privacy-related matters, please send an email to privacy@cybertinolab.com.

CYBERTINO EUROPEAN PRIVACY NOTICE

Effective Date: [May 15th, 2021]

This European Privacy Notice contains information on how we collect, store, process, transfer, share use data that identifies or is associated with residents of the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”) ("personal data") and information regarding our use of cookies and similar technologies. This European Privacy Notice applies solely to residents of the EEA, Switzerland, and the UK (“you”). Please ensure that you have read and understood this European Privacy Notice before accessing or using the Services. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in our Privacy Notice or as otherwise defined in the General Data Protection Regulation (“GDPR”). Cybertino, Inc. is the controller of the personal data we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal data is used.

Information We Collect About You Automatically

We also automatically collect personal data indirectly about how you access and use the Services, and information about the device you use to access the Services, or otherwise engage with us. Please see the “Personal Information Automatically Collected” section of our Privacy Notice for more information about what data we collect and how we use it.

  • The table at Annex 2 sets out in detail the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data and recipients of that personal data. For more information on cookies and other tracking technologies we use, please see our Cookie Notice.
  • We may link or combine the personal data you provide and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
  • We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you), and may use the anonymised and aggregated information or disclose it as set out in our Privacy Notice.

How Long Will We Store Your Personal Data

We will usually store the personal data we collect about you for no longer than necessary for the purposes set out in Annexes 1 and 2, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements, and in accordance with our legal obligations and legitimate business interests. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

Recipients of Personal Data

We may share your personal data with the recipients as set out in the “Our Disclosure of Personal Information” section of our Privacy Notice (as required in accordance with the purposes set out in Annexes 1 and 2).

Marketing and Advertising

From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

  • For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.
  • We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by updating your preferences via the App settings.

Storing and Transferring Your Personal Data

  • Security. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
  • International Transfers of Your Personal Data. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. If you are accessing our Site from the EEA, your personal data will be processed outside of the EEA.

In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this European Privacy Notice.

Your Rights in Respect of Your Personal Data

In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:

  • Right of access. You have the right to obtain:
    • confirmation of whether, and where, we are processing your personal data;
    • information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
    • information about the categories of recipients with whom we may share your personal data; and
    • a copy of the personal data we hold about you.
  • Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
  • Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
  • Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
  • Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
  • Right to withdraw consent. If you have provided consent for the processing of your personal data, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason. You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available here. If you wish to exercise one of these rights, please contact us using the contact details at the end of this European Privacy Notice. Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

Cookies and Similar Technologies Used on Our Site

Our Site use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to monitor and analyse how you use and interact with our Site so that we can continue to improve our Site. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements. Please see our Cookie Notice for more information about these practices and your choices regarding cookies.

Our Policy Towards Children

The Services is not directed at persons under 16. We do not knowingly collect or solicit personal data from any persons under the age of 16. In the event that we learn that we have inadvertently collected personal data from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us using the details at the end of this European Privacy Notice.

Changes to This European Privacy Notice

We may update this European Privacy Notice from time to time and so you should review this page periodically. When we change this European Privacy Notice in a material way, we will update the "Effective Date" above. Changes to this European Privacy Notice are effective when they are posted on this page.

Contact Us

Please contact privacy@cybertinolab.com if you have any questions, comments and requests regarding this European Privacy Notice.

CYBERTINO COOKIE NOTICE

Effective Date: [May 15th, 2021] Unless otherwise expressly stated, terms in this notice have the same meaning as defined in the Privacy Notice.

SCOPE OF NOTICE

This Cookie Notice supplements the information contained in the Privacy Notice and explains how we and our business partners and service providers use cookies and related technologies in the course of managing and providing our online services and our communications to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the Privacy Notice.

As is common practice among websites, our Site and Services use cookies, which are tiny files downloaded to your computer that allow us and our third-party partners to collect certain information about your interactions with our email communications, websites and other online services, and that improve your experience. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).

WHAT WE COLLECT WHEN USING COOKIES

We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications, Site and other online services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure usage and activity trends for our online services and better understand our customer base. We also may collect location data, including general geographic location based on IP address or more precise location data when a user accesses our online services through a mobile device.

We use the following types of cookies: (a) Strictly necessary cookies. These cookies enable core functionality such as security, network management and accessibility. You may disable these by changing your browser settings, but this may affect how the Site and online services function. The legal basis for our use of strictly necessary cookies is our legitimate interests, namely being able to provide and maintain our Site and online services. Please see Annex 3 for more information. (b) Functionality cookies. These enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. The legal basis for our use of functionality cookies is our legitimate interests, namely being able to provide and maintain our Site and online services. Please see Annex 3 for more information. (c) Analytical/performance cookies. These cookies allow us to recognize and count the number of visitors to our Site and online services, and to see how visitors move around our Site and online services when they are using them. This helps us to improve the way our Site and online services work, for example, by ensuring that users are finding what they are looking for easily. If you are accessing our Site with a European IP address, you have been asked to consent to the use of these cookies. You are free to deny your consent. Please see Annex 3 for more information. (d) Targeting cookies. These cookies record your visit to our Site and online services, the pages you have visited and the links you have followed. They are used to track visitors across our Site. We will use this information to make our Site and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose. If you are accessing our Site with a European IP address, you have been asked to consent to the use of these cookies. You are free to deny your consent. Please see Annex 3 and the section “Third Party Data Collection and Online Advertising” below for more information. (e) Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our Site or online services. These third parties are responsible for setting out their own cookie and privacy policies. Please see the section “Third Party Data Collection and Online Advertising” below for more information.

THIRD PARTY DATA COLLECTION AND ONLINE ADVERTISING

We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider. Please see “Your Choices About Online Ads” below, to learn more about interest-based advertising.

Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

Third Party Partners. The following is a sample of the third-party service partners we work with to provide advertising services. We will strive to update this list if or when we work with new partners which offer you choices about the collection of your information, but as partners change and new technologies become available, this list is likely to change over time and may not always reflect our current partners. We use Google Analytics to recognize you and link the devices you use when you visit our Site or Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

HOW WE USE INFORMATION COLLECTED VIA COOKIES

We use cookies for a variety of reasons outlined below:

  • If you create an account with us, then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out; however, in some cases, they may remain afterwards to remember your site preferences when logged out.
  • We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.
  • The Services offer newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
  • The Services offer e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.
  • When you submit data through a form, such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence.
  • In order to provide you with a great experience on the Services, we provide the functionality to set your preferences for how the Services run when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a website page.
  • We use cookies to provide and monitor the effectiveness of our Site and online services, monitor online usage and activities of our Site and online services, and facilitate the purposes identified in the “Our Use of Personal Information” section of our Privacy Notice.
  • We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.

Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Notice.

YOUR CHOICES ABOUT COOKIES

If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

YOUR CHOICES ABOUT ONLINE ADS

We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

We will update this Cookie Notice from time to time. When we make changes to this Cookie Notice, we will change the “Effective Date” at the beginning of this notice. If we make material changes to this notice, we will notify you by email to your registered email address, by prominently posting on this Site or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

CONTACT US

If you have any questions or requests in connection with this Cookie Notice or other privacy-related matters, please contact us at privacy@cybertinolab.com.