We do not maintain profiles of our customers, except for sets of data required for mailing lists.

We may share personal information with the following recipients:

• our employees;
• hosting providers;
• email dispatch providers.

Providing information to our data processors is subject to signing a data processing agreement.

The data will be stored during 3 years after the last email.

We do not process the following information in any manner:

• racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data and health data or data concerning a person's sex life or sexual orientation.

Each data subject has the following rights which may be exercised by contacting us. All the rights below have specific exceptions in certain cases. The requests will be processed within 30 days.

Right to access allows any data subject to request the following information from us:

• if its data is processed;
• which data is processed;
• which are the recipients or categories of recipients of personal data;
• data storage period;
• existence and nature of the rights to rectification/erasure/restriction/objection,
• existence of the right to lodge a complaint to supervisory authorities;
• sources of data;
• existence of profiling and automated decision making including their logic and consequences;
• existence of safeguards of international data transfers.

Right to rectification is the right to correct incorrect data and the right to complete the incomplete data.

Right to erasure ("to be forgotten") means that the data subject may request erasure of his or her data in the following cases:

• the data is no longer needed for the purposes of processing;
• consent for processing is withdrawn and no other grounds of processing apply where such processing is based on consent;
• data subject objects to processing;
• processing is unlawful;
• the data is related to a child and was processed in the context of offering a service directly to a child.

Right to restriction means that processing shall be restricted if:

• the data subject claims that the data is inaccurate and controller needs to verify if it's really inaccurate;
• processing is unlawful but the data subject wants processing to be restricted rather than the data to be erased;
• processing is no longer required for its purposes but the data subject requires it for specific purposes;
• processing is under objection but the controller needs to verify if objection is not overridden by legitimate interest of the controller.

Right to notification means that the data controller shall communicate the request of the data subject in exercise of his or her rights to each recipient unless it proves that it will take disproportionate effort.

Right to data portability means that data subject may request the data controller to provide collected data in structured and readable form.

Right to object means that the data subject based on its personal circumstances may override legitimate interests of the controller which constitute the basis for processing.

The data subject has the right not to be subject to profiling which significantly affects his or her interests.

We take the following measures on protection of personal data to prevent the data breaches, misuse and the violation of rights of data subjects:

• providing this Policy for review to any person or entity which is about to process the personal data.
• keeping our officers and contractors responsible for proper data processing conducted by such officers and contractors.
• providing advice to any officer, data subject or partner on the subject of compliance with this Policy.
• making sure no access to personal data is provided to unauthorized parties.
• using only reliable and tested software for processing or personal data.
• assuming technical and organizational risks of data processing before such processing takes place.
• ensuring that all actions in respect of the data are exercised by protected accounts to access the data and all data storages are available only to a limited number or persons on a password basis.
• ensuring that we are able to suspend data processing or withdraw any piece of data from processing if we believe that such processing may violate applicable law.
• in case of change in any business process we will determine whether such change is data-related and check if such change falls in line with this Policy.
• providing that each location and device where personal data may be stored is a safe environment.
• utilizing firewall to minimize the risk of unauthorized access to the hosting infrastructure.
• where necessary using third-party vendors to perform security assessments to identify issues with its data security that could result in security vulnerabilities.
• providing encryption of most sensitive personal data.
• ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services.
• providing the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
• processing regular testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the data processing.