Privacy Policy

This website located at http://startfrank.com (the “Site”) is run by Easyfy OÜ (“Easyfy”). By using the Site and submitting personal data to Easyfy, you acknowledge and agree that you have consented to the collection, processing, disclosure and transfer practices set out in this Privacy Policy as they relate to your personal data. Therefore, please read this Privacy Policy before using the Site and before providing any personal data to Easyfy. This Privacy Policy describes how Easyfy uses personal data collected or received from visitors and users of the Site. It describes how Easyfy may collect or receive your personal data, the types of personal data Easyfy may collect, how Easyfy uses, discloses and protects these data, your rights, and how you can contact Easyfy about its privacy practices.

1. How Easyfy May Collect or Receive Personal and Non-Personal Data from You

Easyfy may collect or receive personal and non-personal data from you through your use of the Site in various ways. Easyfy collects your personal data when you register as user of the Site and create your user account. Easyfy only collects your personal data about you after you have voluntarily and knowingly provided such data to Easyfy. You may always choose not to provide personal data, but if you so choose, certain products and services may not be available to you. Easyfy may also have to collect certain other personal data in relation to inquiries or claims you make to or against Easyfy in order to be able address to your inquiry or complaint. In order to reduce errors in Easyfy’s database, authenticate users, and prevent abuse of the system, Easyfy may on occasion supplement the personal data you submit to Easyfy with information from third-party sources. Easyfy collects certain kinds of non-personal data technical and routing information about your computer. For example, Easyfy may log variables such as browser type and language, access times, operating system, CPU speed, the website that referred you to the Site, and navigational information (including information about the pages you view, the links you click, and other actions taken in connection with the Site). Easyfy may use these data to facilitate and track your use of the Site and its services. Easyfy also uses such data to measure traffic patterns on the Site. To better understand the needs of visitors and user of the Site, Easyfy may occasionally match such information with your personal data. Easyfy may use cookies or similar technologies that collect certain website usage information when you access, view, browse and use the Site. A cookie is a data file placed on a computer or mobile device when it is used to visit websites. Cookies may be used for many purposes, including for tracking user preferences and web pages visited while using websites. You may disable cookies in your browser’s settings (e.g., under the “Preferences” or “Internet Options” features of your browser). Note, however, that some features of the Site may not function properly if you disable the use of cookies.

2. The Types of Personal and Non-Personal Data Easyfy May Collect

Easyfy may collect the following personal data:

– Upon registering as a user and creating your account: your user name and password, your name, your mailing address, email address, IP address and phone number, as well as certain demographic information such as your job title, job description and company name and company type.

– Upon making an inquiry or complaint: content of your inquiry or claim and any other information required to appropriately handle and respond to your inquiry or claim.

You may also voluntarily provide other data that is related to you in connection with your inquiries or claims. Easyfy encourages you, however, to provide no more personal data relating to you than is necessary in order for Easyfy to provide an appropriate response to your inquiries or claims. In particular, please do not provide any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or data concerning health or sex life.

3. How Easyfy Uses the Personal Data

Easyfy may collect and use your personal data to:

– Create and manage your user account;

– Process your transactions;

– Provide customer service;

– Address your inquiries and claims;

– Perform research and analysis aimed at improving its products and services;

– Display content that is customized to your interests and preferences;

– Run contests, select entrants, and choose prize winners;

– Improve the Site, including to enhance user experience;

– Diagnose problems with Easyfy’s servers;

– Communicate with you about your transactions, new products and services including transaction-related communications such as purchase confirmations, notices and reminders;

4. How Easyfy May Disclose Personal Data

Easyfy does not sell, rent or trade your personal data. Easyfy may disclose your personal data only to:

– Entities within the Easyfy group to whom it is reasonably necessary or desirable for Easyfy to disclose personal data;

– Third party service providers that Easyfy may use to maintain the Site, to handle the processing of payments, to provide data storage, to assist in marketing, to conduct audits, etc. These third party service providers are not permitted to use your personal data for their own purposes;

Government authorities or other third parties, if required by law or reasonably necessary to protect the rights, property and safety of others or Easyfy itself.

If you have entered into and/or won a Easyfy contest, Easyfy or a contest sponsor may publish your name and city of residence. Information about Easyfy’s customers, including personal data, may be disclosed as part of any merger, acquisition, or sale of the company and/or its assets, as well as in the unlikely event of insolvency, in which personal data would be transferred as one of the business assets of the company. Easyfy reserves the right to disclose your personal data if required or permitted to do so by law.

5. International Data Transfers

Personal data collected by Easyfy and its affiliates may be stored and processed in Estonia or any other country in which Easyfy or its affiliates maintain facilities. Easyfy may transfer such personal data to countries other than the country in which the data were originally collected. The laws of those countries may not have the same level of data protection as the country in which you initially provided the data. When Easyfy transfers your personal data to other countries, it will protect that data as described in this Privacy Policy and in accordance with applicable law. By providing Easyfy with your personal data using the Sites or its services, you consent to any such transfer of information outside of your country.

6. How Easyfy Protects Personal Data

Easyfy follows generally accepted industry standards to help protect your personal data including without limitation:

– Limiting access to your personal data to those of employees who require it to provide services to you;

– Requiring employees to sign confidentiality agreements to protect customer and other confidential information;

– Ensuring that third party service providers sign confidentiality agreements to maintain the confidentiality of your personal data and not to use it for any unauthorized purposes;

– Personal data collected is retained as long as it is reasonably required for the purposes it was collected;

Storing your personal data in secure computer systems which protect it from unauthorized access or use.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while Easyfy strives to protect your personal data, it cannot guarantee its absolute security. If a password is used to protect your account and personal data, it is your responsibility to keep your password confidential.

7. Links to Other Websites

Links on the Site may take you outside the Site to websites maintained by third parties, whose information and privacy practices are different than Easyfy’s. Easyfy accepts no responsibility for the information or privacy practices employed by such third parties. Easyfy encourages you to read the privacy statements of all third party websites before using such websites or submitting any personal data or any other information on or through such websites.

8. Referrals

If you choose to use Easyfy’s referral services to tell a friend about Easyfy’s products or services, Easyfy will ask you for your friend’s name and email address. Easyfy will use that information to send your friend a one-time email inviting to visit the site, review the product or service you have selected and if they choose to join us, to track the referral services. Easyfy may use a third-party provider to administer this function, but any such third-party provider may only use the information submitted to facilitate this one-time email. If you are the person who was referred (either by email or otherwise, including through Easyfy’s referral program by clicking on a link on a third party site or email) and you choose to join Easyfy, your Easyfy user name and any information you choose to put on your profile page may be viewable to the person that referred you so that they may track their referral services.

9. Updates to the Privacy Policy

This Privacy Policy may be updated from time to time. Updated versions will be posted on the Site and are effective immediately. When Easyfy makes changes, it will revise the “last updated” date at the top of the policy. Easyfy encourages you to review the Privacy Policy regularly.

10. Your Rights

Your rights under applicable law may include access to the personal data Easyfy processes about you, the right to have such personal data corrected, erased or blocked, and the right to object to certain data processing activities. If you would like to know more about Easyfy’s privacy practices or if you would like to exercise any of your personal data related rights, please make a written request using Easyfy’s contact details set out below.

11. How to Contact Easyfy

If you have any comments or inquiries about this Privacy Policy, if you would like to update information Easyfy has about you, or to exercise your rights, you may contact Easyfy by e-mail at hello@startfrank.com