Privacy Policy

Last Updated On 22-Jan-2025
Effective Date 22-Jan-2025

1. GENERAL

1.1 This Website is owned and operated by Odin Pay s.r.o., a company registered in the Czech Republic, registration number 223 56 312 and having its official registered address at Děčínská 552/1, Střížkov, 180 00 Praha 8, Czech Republic, which is duly authorized to provide custody and administration of crypto-assets on behalf of Customers, exchange of crypto-assets for funds (and vice versa), and exchange of crypto-assets for other crypto-assets.

1.2 We are a Personal Data Controller and are responsible for the processing of your Personal Data.

1.3 This Privacy Policy provides for the security measures we have implemented to protect and manage your Personal Data, in accordance with applicable data privacy regulations listed below. We respect your privacy, and we are committed to protecting your Personal Data.

1.4 The privacy of your Personal Data is important for us. We respect your rights to privacy and rights under GDPR, are committed to complying with the requirements of GDPR in the collection and processing of your Personal Data.

1.5 Privacy Policy explains how we use your Personal Data in connection with usage of our Services, access, or use of the relevant areas of our Website, or when any Third Party provides your Personal Data to us or any Third Party dealing with us on your behalf.

1.6 By using our Services by the Customer and/or our Website by our User, they expressly agree with Privacy Policy and expressly consents to and agrees with Personal Data processing as stipulated herein and by the applicable law.

2. DEFINITIONS

2.1 The following terms have the meaning as defined below:

2.1.1 “AML” means Anti-Money Laundering, referring to measures and procedures implemented to prevent financial crimes, as outlined in the AML/CTF Policy.

2.1.2 “AML/CTF Policy” means our Anti-Money Laundering, Countering Financing of Terrorism available via the link;

2.1.3 “Customer” means any person using our Website, the Services, and has concluded these Terms and the Customer Agreement.

2.1.4 “Customer Agreement” means a legally binding agreement between the Company and Customer, specifying the terms for using our Services.

2.1.5 “Company”, “we” means Odin Pay s.r.o., a company registered in the Czech Republic, registration number 223 56 312 and having its official registered address at Děčínská 552/1, Střížkov, 180 00 Praha 8, Czech Republic, an authorized crypto-assets service provider registered in the Czech Republic.

2.1.6 “Controller” of your Personal Data means a legal entity that determines the purposes, conditions, and manner of any processing activities that it carries out.

2.1.7 “Cookies” means small files that store information on your computer, mobile phone or other device. They enable us to recognize you across different websites, services, devices and/or browsing sessions. Cookies also assist us to customize online content and advertising, save your preferences for future visits to the Website, measure the effectiveness of our promotions, prevent potential fraud and analyse Users’ interactions with the Website.

2.1.8 “GDPR” means the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016 On the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced, or superseded and in force from time to time, and as transposed into member-state legislation.

2.1.9 “KYC” means Know Your User, referring to identity verification processes as outlined in the AML/CTF Policy.

2.1.10 “Personal Data” means any information which relates to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It does not include data where the identity has been removed (anonymous data).

2.1.11 “Privacy Policy” means this Privacy Policy.

2.1.12 “Third Party” means any individual, organization, or entity that is not the data subject, data controller, or data processor, and who is authorized to process personal data under the direction of the controller or processor. This may include external service providers, partners, regulatory authorities, or other entities involved in supporting the operations, services, or compliance requirements of the Company.

2.1.13 “User”, “you” means any users of the Website, including visitors and Customers.

2.1.14 “Website” means https://odinpay.eu and/or any other website as we may operate from time to time.

2.2 All capitalized terms not otherwise defined elsewhere in the Privacy Policy shall have the same meanings assigned to them in the Terms & Conditions and Cookies Policy.

3. WHAT DO WE OFFER?

3.1 Our Website, Terms & Conditions, Customer Agreement contain detailed information about our Services we offer.

3.2 We only use the Personal Data for the purposes specified in the Privacy Policy. We only transfer your Personal Data to the Third Parties if it is needed as set forth below.

4. TYPES OF PERSONAL DATA

4.1 We classify our Personal Data into the following three types:

4.1.1 Directly collected Personal Data refers to the information, which Users directly provides us (e.g., by filling the website forms). We usually collect and store information including in paper, physical and electronic form provided by our Users when communicating with us by telephone, email, web-based form, letter, facsimile or other means, including, but not limited to, when:

4.1.1.1 The User contacts us over the phone;

4.1.1.2 we provide you with our services via telephone, email, or our Website;

4.1.1.3 we provide the Customer, potential Customer with assistance or support for our Services;

4.1.1.4 The Customer participates in our functions, events, or activities or on our social media pages;

4.1.1.5 The Customer, potential Customer, requests that we provide information concerning our Services;

4.1.1.6 The User uploads or submits information to us or our Website; or

4.1.1.7 The User completes any forms requesting information, including on registration with us, completes any survey or provides feedback to us concerning our Services.

4.2 Indirectly collected Personal Data refers to information that relates to you but is not provided directly by you. For example, we may collect data through the use of our services, your interaction with our website, or other technical means. This can include:

4.2.1.1 The IP address;

4.2.1.2 Information about the device used to access our services, such as the type of device, operating system, browser version, and device settings;

4.2.1.3 Data regarding your interactions with our website or platform, such as pages visited, time spent on certain sections, and other engagement metrics;

4.2.1.4 Cookies;

4.2.1.5 Location Data.

4.3 Automatically collected / generated Personal Data. Though such information isn’t provided by a User, it relates to you and according to the the GDPR is considered to be Personal Data. It has 2 subtypes:

4.3.1.1 Static. This information doesn’t usually change once it’s created. For instance, an internal user id;

4.3.1.2 Dynamic. This subtype changes based on the activities performed by you.

4.4 For information about your ability to restrict the collection and use of such information, please use the settings available on your device.

5. WHAT PERSONAL DATA DO WE COLLECT?

5.1 Depending on whether and how you use our Services, Website, we will collect, use, store and transfer different kinds of your Personal Data, grouped in the following categories:

5.2 This information is not exhaustive, and is laid out to give you an idea about use of fundamental collected information. We will record all information collected and purposes for which we process that Personal Data.

5.3 Furthermore, we treat certain categories of Personal Data to be sensitive, and such sensitive data requires additional safeguards. We will only collect, use, store, and transfer your sensitive data if we can meet both the legal basis requirement and at least one of the required extra conditions.

5.4 The extra conditions include:

5.4.1 circumstances prescribed by regulations: Personal Data is processed in the conditions prescribed by regulations;

5.4.2 information made public by you: the sensitive data has become public as a result of your actions;

5.4.3 consent: you have provided your consent to the processing of your sensitive data.

5.4.4 judicial proceedings: the processing is required for the purpose of or in connection with any legal proceedings, for seeking legal advice, or for establishing, exercising, or defending legal rights;

5.4.5 public functions: the processing is necessary for the exercise of any functions conferred on any person by or under an enactment.

6. LAWFULNESS OF PROCESSING AND DISCLOSURE

6.1 You consent to these terms of processing of your Personal Data. We take all reasonable means to ensure that your Personal Data is treated securely and in compliance with this Privacy Policy, when we process your Personal Data for one of the legal purposes specified in this Privacy Policy. We protect your Personal Data under internationally recognized standards, employing physical, technological, and administrative security measures to minimize the risks of loss, misuse, unauthorized access, disclosure, and alteration. Firewalls and data encryption are among the measures we employ, as well as physical access controls to our data centres, and information access authorization controls.

6.2 We also limit access to the Personal Data only to those employees, contractors, advisors, auditors who require it to fulfil their job or service duties. Our employees, contractors are trained on procedures of the Personal Data processing, including limitations on the release of information. Access to the Personal Data is limited to those of our employees and contractors whose work needs it. We perform periodic evaluations to ensure that proper information processing policies and procedures are understood and followed. All of our physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations.

7. PURPOSE AND LEGAL BASIS OF PERSONAL DATA PROCESSING

7.1 We process the Personal Data only for purposes stipulated in the Privacy Policy or those prescribed by the applicable law.
7.2 We process the Personal Data for various purposes to ensure the proper functioning of our Website, Services, compliance with legal obligations, and an improved User experience. The key purposes for processing personal data include:

7.2.1 Contractual Purpose. We process Personal Data to fulfil our contractual obligations and provide our Services effectively, including:
7.2.1.1 Entering into and performing the Customer Agreement;
7.2.1.2 Disclosing necessary information to the relevant Third Parties as required for the Service delivery;
7.2.1.3 Enabling proper access to and improvement of features on our Website;
7.2.1.4 Registering Customers and processing their orders, instructions, and transactions;
7.2.1.5 Managing, collecting, and transferring payments, fees, and charges;
7.2.1.6 Recovering payments owed to us.

7.2.2 Compliance with Legal and Regulatory Obligations. We process Personal Data to comply with applicable legal and regulatory requirements, including:
7.2.2.1 Conducting KYC and AML checks;
7.2.2.2 Complying with AML/CTF laws and financial crime prevention regulations;
7.2.2.3 Performing identity verification, fraud detection, and risk assessments;
7.2.2.4 Maintaining legally required business and transaction records;
7.2.2.5 Reporting to law enforcement and regulatory authorities where necessary;
7.2.2.6 Cooperating with financial institutions, auditors, and compliance service providers.

7.2.3 Legitimate Interests. We process Personal Data based on our legitimate business interests, provided that such processing does not override the fundamental rights and freedoms of data subjects. This includes:
7.2.3.1 Analysing and improving our Services, Website performance, and User experience;
7.2.3.2 Preventing fraudulent activity, unauthorized access, and security breaches;
7.2.3.3 Conducting Customer Service activities, including support, troubleshooting, and feedback collection;
7.2.3.4 Ensuring the integrity, safety, and security of our Website and Services;
7.2.3.5 Managing our business relationships and internal operations;
7.2.3.6 Investigating and enforcing compliance with legal terms, policies, and contractual obligations.

7.2.4 Marketing and Advertising. We process Personal Data to conduct marketing activities and inform Customers about our Services, including:
7.2.4.1 Sending Service-related communications, such as welcome emails and Service updates;
7.2.4.2 Conducting direct marketing and promotional activities;
7.2.4.3 Maintaining a Customer database to assess business performance and market trends;
7.2.4.4 Contacting Customers for surveys and feedback purposes;
7.2.4.5 Displaying targeted advertisements to existing and potential Customers;
7.2.4.6 Analysing the effectiveness of marketing campaigns to improve Customer engagement.

7.2.5 Communication and Customer Interaction. We process Personal Data to facilitate Customer communication and Service-related interactions, including:
7.2.5.1 Sending administrative notifications regarding updates, technical issues, or policies changes;
7.2.5.2 Contacting Customers to address support requests, complaints, or disputes;
7.2.5.3 Providing essential Service-related notifications;
7.2.5.4 Seeking feedback from Customers to improve the quality of our Services;
7.2.5.5 Providing updates on our Terms, policies, and security measures;
7.2.5.6 Enhancing User engagement through personalized communication.

7.2.6 Regulatory, Security, and Business Management. We process Personal Data to ensure regulatory compliance, operational security, and risk management, including:
7.2.6.1 Monitoring, analysing, and improving the performance, security, and functionality of our Website;
7.2.6.2 Investigating and enforcing compliance with legal terms, policies, and contractual obligations;
7.2.6.3 Protecting our intellectual property, assets, and legal rights;
7.2.6.4 Creating backups of business records to ensure continuity and security;
7.2.6.5 Implementing fraud prevention mechanisms, including identity verification and transaction monitoring;
7.2.6.6 Managing internal audits, risk assessments, and corporate governance processes.

8. HOW WE USE PERSONAL DATA FOR COMMUNICATING WITH YOU AND DIRECT MARKETING

8.1 We may communicate with you by phone, email, SMS or push notification, to inform you about existing and new Services that may be of interest to you.

8.2 We will ensure that any email we send as direct marketing complies with the GDPR and contains an “unsubscribe” option so that you can remove yourself from any further marketing communications. To opt-out of communications via email, SMS, reply with “STOP”. You may decline marketing messages sent by push notifications by refusing the relevant permission in your phone or tablet settings, however this setting will prevent you from receiving other messages from us via push notification. You may also opt out of receiving marketing materials from us using the contact details set out below.

8.3 You can also call or write to us to request that your details be removed from our direct marketing list. We will endeavour to remove your details from our direct marketing list within a reasonable time (ordinarily 5 working days).

8.4 Our direct marketing list may be operated by software and servers located overseas, and your Personal Data may be sent overseas as part of our marketing.

8.5 We will also send communications that are required or necessary to send to users of our Website that contain information about important changes or developments to or the operation of the Website or as well as other communications you request from us. You may not opt out of receiving these communications, but you may be able to adjust the media and format through which you receive these notices.

9. THIRD PARTIES

9.1 We have taken steps to ensure that Third Parties engaged by us in processing your Personal Data, have suitable technical and organizational measures in place to protect this Personal Data, and we will also ensure that they are GDPR-compliant. We have taken steps to ensure that Third Parties engaged by us, protect the confidentiality and security of Personal Data, and ensure that Personal Data is processed only for Service providing and in compliance with applicable law.

9.2 We may transfer your Personal Data to Third Parties, such as:

9.2.1 to our related entities, employees, officers, agents, contractors, other companies that provide services to us, sponsors, government agencies or other Third Parties to satisfy the purposes for which the information was collected or for another purpose if that other purpose is closely related to the primary purpose of collection and an individual would reasonably expect us to disclose the information for that secondary purpose;

9.2.2 to Third Parties who help us analyse the information we collect so that we can administer, support, improve or develop our business and the Services we provide to the Customers;

9.2.3 to merchants and the recipients of funds to identify you as the sender of the funds and to a party who sends you funds in connection with a transfer to you of funds;

9.2.4 legal and regulatory authorities to whom we are obligated to disclose your Personal Data under the law, AML and CFT requirements; agencies that deal with law enforcement; entities in cases of fraud or collusion prevention, identity verification, payment processing, credit reference; banks/financial institutions; courts;

9.2.5 identification and verification service providers engaged by us for the Users, your verification, performance of AML and CFT requirements, as well as other software service providers who assist us to provide Services we provide to the Customers;

9.2.6 to our professional advisers such as consultants, bankers, professional indemnity insurers, brokers, and auditors so that we can meet our regulatory obligations, and administer, support, improve or develop our business;

9.2.7 server hosts, which store our data, communication service providers, which help us stay in touch with you;

9.2.8 to Third Parties, including those in the blockchain and fintech industry, marketing and advertising sectors, to use your information in order to let you know about Services which may be of interest to you in accordance with GDPR;

9.2.9 banking, financial service providers, helping us in the Services to our Customers;

9.2.10 to debt recovery agencies who assist us with the recovery of debts owed to us;

9.2.11 to any other person, with your consent (express or implied);

9.2.12 to facilitate the sale of all or a substantial part of our assets or business or to companies with which we propose to merge or who propose to acquire us and their advisers; and

9.2.13 other Third Parties which services, facilities we use, in order to provide our Services and deal with certain processes necessary for the operation of the Website, perform internal procedures and law requirements.

9.3 This list of the Third Parties is non-exhaustive and may change and be supplemented. The procedure for collecting, processing, storing and using Personal Data is determined by the privacy policy of the relevant Third Party.

9.4 The privacy policies of the Third Parties are available for review at the following links:

Safelement Limited (AMLBot): https://amlbot.com/privacy-policy

Kycaid Limited: https://kycaid.com/privacy-policy/

9.5 In addition to the above recipients, we will disclose your Personal Data if we are required to do so under law or if the disclosure is made in connection with either the normal operation of our business in a way that you might reasonably expect, for example, if such disclosure is incidental to IT services being provided to our business or for the resolution of any dispute that arises between you and us. This disclosure may involve your Personal Data being transmitted overseas.

9.6 In the event of a proposed restructure or sale of our business (or part of our business) or where a company proposes to acquire or merge with us, we may disclose Personal Data to the buyer and their advisers without your consent subject to compliance with GDPR. If we sell the business and the sale is structured as a share sale, you acknowledge that this transaction will not constitute the “transfer” of Personal Data.

9.7 We do not transfer Personal Data outside the European Economic Area (EEA) unless appropriate safeguards are in place to ensure compliance with GDPR. These safeguards include:
9.7.1 The use of Contractual Agreements with Third Parties.
9.7.2 Obtaining explicit consent from the data subject, where necessary.

9.8 We are obliged to disclose your Personal Data in following cases:
9.8.1 in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements;
9.8.2 to protect, establish, or exercise our legal rights or defend against legal claims, including to collect a debt; to comply with a subpoena, court order, legal process, or other legal requirement;
9.8.3 when we believe in good faith that such disclosure is required to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of Terms & Conditions;
9.8.4 to Third Parties in case of: merger, restructuring, joint venture, assignment, sale of part of the business or the whole business.

9.9 If we are acquired or merged with a Third Party entity, we reserve the right to transfer or assign the data we have collected from our Users as part of such merger, acquisition, sale, or other change of control. If we become involved in a merger, acquisition, or any form of sale of some or all our assets, we will notify Users, you before Personal Data is transferred and become subject to a different privacy policy. We may not be able to control how your Personal Data is treated, transferred, or used in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights in general.

10. WHERE DO WE STORE PERSONAL DATA?

10.1 Please note that we use our own and Third Party computers, servers including our Website hosts, data backups and payment gateway(s), which may be located overseas, and your Personal Data will likely be stored and transmitted overseas as part of the normal operation of our business. To ensure the security and privacy of your Personal Data, we take measures designed to protect that information from loss, misuse, unauthorized access, disclosure, alteration, or destruction.

11. HOW LONG DO WE STORE PERSONAL DATA?

11.1 We retain your Personal Data for the duration of our business relationship and for 5 years after termination of Services, unless a longer retention period is required by applicable law. Under AML/CFT regulations, we are legally required to store certain Personal Data for a minimum of 10 years from the termination of our relationship. After the relevant retention period expires, your data will be securely deleted unless otherwise required by law.

12. SECURITY OF PERSONAL DATA

12.1 When you provide your Personal Data over our Website, it is securely sent across the Internet using industry standard encryption. Your Personal Data will be held encrypted on secure servers.

12.2 We will endeavour to take all reasonable steps to keep secure and protect any Personal Data which we hold about you, including:
12.2.1 securing our physical premises and digital storage media;
12.2.2 using computer safeguards technology to ensure that your information is encrypted and sent across the Internet securely;
12.2.3 placing password protection and access control over our information technology systems and databases to limit access and protect electronic information from unauthorized interference, access, modification, and disclosure; and
12.2.4 taking regular back-ups of our electronic systems.

12.3 Notwithstanding that we will take all reasonable steps to keep your Personal Data secure, data transmission over the Internet is never guaranteed to be completely secure.

13. BREACHES NOTIFICATIONS

13.1 In case of a Personal Data breach, we shall notify the supervisory competent authority within 72 hours in accordance with GDPR, unless the breach is unlikely to result in a risk to the rights and freedoms of individuals.

13.2 If the breach is likely to result in a high risk to your rights and freedoms (such as financial loss, identity theft, or reputational harm), we will notify you directly and without undue delay via email or other secure communication methods, as required under GDPR. Our notification will include details of the breach, potential impact, and steps you can take to protect yourself.

14. YOUR RIGHTS

14.1 Obtain confirmation. You have the right to request confirmation that Personal Data pertaining to you is being processed.

14.2 Access Personal Data. You have the right to access such data, or ask us to provide a copy of your Personal Data processed by us.

14.3 Request of information. You have the right to request the following additional information concerning your Personal Data:
14.3.1 the purposes of the processing;
14.3.2 the categories of Personal Data concerned;
14.3.3 the recipient(s) or category(ies) of recipient to whom/which Personal Data have been or will be disclosed;
14.3.4 the criteria determining the period for which Personal Data will be stored, etc.

14.4 Request rectification. You have the right to rectify Personal Data in case the data is incorrect or incomplete.

14.5 Right to Withdraw Consent for Data Processing. You are entitled to withdraw the consent granted for the processing of Personal Data at any time. Withdrawal does not affect the lawfulness of the processing conducted before the withdrawal. If you withdraw your consent, we may not be able to provide certain Services to you, but we will advise you if this is the case at the time you withdraw your consent;

14.6 Right to erasure. Sometimes called Right-to-be-forgotten. You have the right to revoke previously provided consent and have the Personal Data erased from our system. In this case, Third Parties will no longer have access to your Personal Data. However, it does not mean that your data will be erased immediately; it will still be stored at our facility in order to comply with numerous statutory obligations, specifically a provision of the GDPR regulations, AML and CFT requirements, under which we are required to store any collected information for a minimum period of 10 years from relations termination, for the purposes of the prevention, detection, analysis, and investigation of money laundering or funding of terrorism activities. Your Personal Data will be erased from our records after this period has elapsed.

14.7 Restrict processing. You have the right to ask us to restrict the processing of the Personal Data in case the data is incorrect or incomplete, or in case Personal Data is processed unlawfully. Nevertheless, the AML/CFT Regulations require us to store your Personal Data for at least 10 years after the end of the relationship between us and a User. Biometrics are processed and stored so long as the other Personal Data as set forth in this Privacy Policy. This period may be further extended in certain cases if so provided by and in accordance with the applicable legislation. Upon amendment or removal of your Personal Data, it is archived and safekept separately from processed Personal Data.

14.8 Receive Personal Data. You have the right to receive the Personal Data concerning you provided to us, in a structured, commonly used and machine-readable format. We are obliged and have provided all the information which you have right to receive. This Privacy Policy concludes all the information and is available to you on our Website at any point of time.

14.9 Have Personal Data transmitted. You have the right to have the Personal Data transmitted directly from one Controller to another, where technically feasible. You may request the transfer of the Personal Data to you or to a Third Party, and we will provide to you, or a Third Party you have chosen (where technically feasible), your Personal Data; note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

14.10 Right to Object. You have the right to object, on grounds relating to your particular situation, where there is a reason to believe that we have no lawful grounds for processing Personal Data, at any time to processing of Personal Data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

15. REQUESTS AND COMPLAINTS

15.1 If you have any queries in relation to this policy, you wish to access or correct the Personal Data we hold about you, or make a complaint, please contact us in writing at:
15.1.1 Email: [email protected]; or
15.1.2 Mail: Děčínská 552/1, Střížkov, 180 00 Praha 8, Czech Republic

15.2 You have the right to file complaints regarding processing of your Personal Data to the Company as set forth above.

15.3 We aim to acknowledge receipt of all privacy complaints from you within 15 business days from the date of receipt of the complaint, except for cases where additional time is needed for appropriate checks (up to 35 business days after the acknowledgement of receipt of the complaint). Where we cannot resolve a complaint within that period, we will notify you of the reason for the delay, as well as advising the time by which we expect to resolve the complaint.

15.4 In order to disclose information to you in response to a request for access, we may require you to provide us with certain information to verify your identity. GDPR may prescribe exceptions which may affect your right to access your Personal Data.

15.5 In the event that you believe that there has been a breach of GDPR, we invite you to contact us as soon as possible.

15.6 If you are not satisfied with our handling of a complaint or the outcome of a complaint, you have the right to lodge a complaint with an appropriate authority:

The Office for Personal Data Protection of the Czech Republic:
Address: Pplk. Sochora 27, 170 00 Praha 7
Phones: +420 234 665 800 / +420 234 665 111
E-mail: [email protected]
Website: https://uoou.gov.cz/en

15.7 Should we lawfully receive your Personal Data from a Third party, you will have the same rights regarding the information in question as related to information you provided to us directly, or we have collected during cooperation with you.

16. USE OF COOKIES

16.1 When you visit our Website or the website of our partners, we and our partners may use the Cookies to recognize you and customize your online experience. For more information, please refer to the Cookie Policy.

17. IMPLEMENTATION OF CHANGES

17.1 Our Privacy Policy is reviewed and updated on a regular basis to ensure that any new obligations and technologies, as well as any changes to our business operations and practices, are taken into account, as well as that it remains abreast of the changing regulatory environment. Any Personal Data we store will be subject to our most recent Privacy Policy.

17.2 If we decide to update our Privacy Policy, we will post those changes here and other places we deem necessary.

17.3 Any changes to this Policy will take effect from the moment this Policy is published on the Website. You shall regularly review the Privacy Policy and pay attention to its revisions. Your continued use of our Website and Services following the posting of changes constitutes your acceptance of the amended Privacy Policy. We always indicate the date the last changes were published.