Privacy Policy

1. Introduction

The protection of your privacy is a very serious concern to Octavian.SPb.Ltd (hereinafter referred to as “Octavian”, “we”, “our”) therefore we want you to be able to use our website and applications for mobile devices (“App”) without being concerned about security issues. The following Privacy Policy will provide you with an overview of how Octavian guarantees the protection of your privacy, the type of data being collected as well as the rights of our customers with regard to the applicable data protection and privacy law.

2. Data Security

The technologies employed by Octavian to process your personal information (hardware, software, network, infrastructure) comply with state-of-the-art security technologies.

3. Consent

This Policy is intended to be agreed to by users 18 years of age or older. For users younger than 18 years of age (“Child”), a parent or guardian is required to agree to this Privacy Policy on their behalf.

Where this Policy has been entered into by a Child without the agreement of a parent or guardian, then the parent or guardian should contact us and we will remove the Child’s personal information held by us. See below for our contact details.

4. IP address

We might collect your IP address.

The IP address is transmitted on every server request to let the server know where the response has to be sent. Your Internet Service Provider (ISP) gives you an IP address as soon as you connect to the Internet, and the ISP can retrace which IP address was assigned to which of its customers at any given time. For as long as the IP address is saved, it is theoretically possible to identify the owner of the Internet connection via the ISP.

We collect your IP address for the following reasons:

  • to target or exclude specific visitors based on a visitor’s demographic information such as their location, including country, city, and region;

  • to geo-target messages based on the location of users but also to display the App to individuals based on device type;

  • to provide users with continuous service via their device;

  • to help optimize user’s acquisition funnel based on location and device type; and

  • statistics, analytics and customisation of this App.

5. Cookies

We and our third party services don’t use any cookies to collect domain names or learn about our customers’ preferences.

6. Personal data

We will collect information from you in relation to your use of the App, including App installation, App use, purchase decisions and App ratings. We will also collect information on your country, region, and city.

We collect this information to use for statistics, analytics and customisation of the App. We will not collect this information to identify our customers.

7. Sensitive data

There are no sensitive personal data processed about you.

8. Transferring and surrendering data

Data transfer to third parties shall not take place without your consent. However, you authorise us to disclose your personal information to the following people or organisations:

  • Organisations within our corporate group;

  • Third parties to conduct market, statistical, research and/or business analysis for us;

  • Third parties contracted by us to perform our services;

  • Third parties required for contract fulfilment;

  • Third parties where the information is to be used in a form which the individual concerned is not identifiable;

  • Our assignees or potential assignees; and

  • Order processors (service providers).

9. Refusal to provide personal information

If you choose not to provide us with the personal information that we request, in full or in part, then this may significantly reduce the functionality of the App.

10. Your rights to access, correct and remove personal information

You may be entitled to access, delete and correct personal information held by us. This can be done by contacting us at the address set out below.

We reserve the right to refuse or limit access or corrections to your personal information where permitted by law.

If we refuse to provide access or correct your personal information, we will provide you the reasons for this in writing. If we refuse to correct your information, we may attach to the personal information a statement of the correction sought.

As permitted by law, we may charge you a reasonable fee in relation to providing access to, or correcting, your personal information.

11. Further information

We value the trust you place in us. Should you have any questions on how we use and utilise your personal information, please contact Octavian by sending a written message to e-mail:
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