Privacy Policy

Date of last update «4» November 2020

 We take your privacy very seriously because we understand that you want to know what's going on with your personal information.

Please read this text to learn more about Fin-Gears Ltd.’s privacy policy for the website «fin-gears.com» (hereinafter - the Site).

We control the ways in which your personal data is collected and determine the purposes for which the personal data is used by Fin-Gears Ltd.

We are the “data controller” for the purposes of the EU General Data Protection Regulation 2016/679 (hereinafter “GDPR”) and other current legislation on personal data protection.

By using our Site or accessing it in any way, you acknowledge that you accept the rules described in this Privacy Policy and consent to the collection, processing and dissemination of your personal data in the ways described and for the purposes described, consent to the use of cookie files in accordance with the terms of this Policy on the first and subsequent visits to our site, which allows us to use cookies every time you visit the Site.

If you do not agree with this Policy, please do not use this site.

 LEGISLATION REGULATING THE PROCESSING OF PERSONAL DATA

 The processing of personal data of individuals who are in the territory of the EU or are EU citizens is regulated, in particular, by the General Regulation on Personal Data Protection 2016/679 (“GDPR”).

Also, the legislation of other countries, with the residents of which we are in business, partnership relations, may set additional requirements.

 PERSONAL DATA WE COLLECT

When you visit the Site, we may collect the following types of data:

information about the device:

 - information about your device, including information about your web browser, IP address, device operating system, Internet service provider, time zone, geographic location, some cookies, and other tracking technologies (e.g. web beacons, pixel tags, CRPO), etc.) that are installed on your device, your language preferences;

  - information about how you interact with the site: information about individual web pages or products that you view, as well as which websites or search queries redirected you to the site, the page of exit and record date/time, information about your visits and use of this site, including the source of the links, the duration of the visit, page views and ways to navigate the site;

information you provide:

 - information you enter when creating a profile or registering on our site, such as your name, gender, date of birth, address, phone number, email, interests and hobbies;

 - information you enter to set up a subscription to our emails, including mailings such as your name and email address;

 - information about everything you buy, the services you use, or the transactions you make through our site, including your name, address, telephone number, email address, and payment information (credit card information), billing address, delivery address;

 - information contained in any messages you send us by e-mail or through our site, including content and metadata;

 - any other information you send us;

information we receive from third parties (eg business partners, service providers):

 account data that is transferred to third parties: if you provide us with your account data registered on third party sites/platforms, or share materials on our site through third parties, or log in to our site through third parties (for example, Facebook, Instagram), you understand that some material or information from these accounts may be transferred to our Site if you allow such data transfer in your account settings, and the third-party account information provided to us is subject to our Privacy Policy.

Information from our advertising partners: for instance, we receive information about you from some of our service providers who assist us in marketing or promotion, about how you interact with our websites, applications, products, services, advertisements or communications.

Information from other service providers: we receive information about you from some of our service providers who assist us in promoting and improving the quality of our services by sharing information about how you use our Site and by ensuring the security and integrity of our Site.

 We do not collect personal data of persons under the age of 13 or under 16 in countries subject to the EU General Data Protection Regulation 2016/679 ("GDPR"), except for individual exceptions in the case of individual states.

If you are under 13 years of age or, where applicable, 16 years of age, please do not visit our Site, register on our Site or send us any personal information about yourself. If we learn that we have collected personal information about a child who has not reached the appropriate age, we will delete this information as soon as possible. If you learn that a child under the age of majority has sent us their personal information, please contact us by support@fin-gears.com.

Please do not send us any personal data of third parties. If we learn that we have collected personal information about a third party without their consent, we will delete this information as soon as possible.

Before disclosing the personal data of third parties to us, you must obtain the consent of this person to both disclose and process this personal information in accordance with this Policy.

 CATEGORIES OF PERSONAL DATA RESOURCES

Our site uses cookies. A cookie is a file that contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The ID is then returned back to the server each time the browser requests a page from the server. Cookies can be either “permanent” or “session”: permanent cookies are stored by the web browser and remain valid until their expiration date, unless the user deletes them before the expiration date; session cookies, on the other hand, end at the end of the user’s session when the web browser is closed. Cookies usually do not contain any information that identifies the user, but the personal information we store about you may be related to the information stored in and received from cookies (we use both session and persistent cookies on cookies). our site).

We use Google Analytics and Adwords on our site to recognize the computer when a user: visits the site / tracks users as they move around the site / allows you to use the cart on the site / improves site usage / analyzes site use / administers the site / prevents fraud and increase the security of the site / personalize the site for each user / target ads that may be of particular interest to specific users / describe the goals); (Learn more about how Google uses your Personal Information here: https://www.google.com/intl/uk/policies/privacy/).

You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Most browsers allow you to refuse cookies, for example:

In Internet Explorer (version 10), you can block cookies by using cookie override settings by clicking “Service”, “Browser Properties”, “Privacy”, and then “Advanced Settings”.

in Firefox (version 24) you can block all cookies by clicking “Tools”, “Settings”, “Privacy”, selecting “Use custom settings for history” in the drop-down menu and unchecking “Accept cookies from sites”;

in Chrome (version 29) you can block all cookies by going to the “Settings and Management” menu and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the heading “Cookies”.

Blocking all cookies will negatively affect the usability of many sites. If you block cookies, you will not be able to use all the features of our site.

You can delete cookies already stored on your computer, for example:

in Internet Explorer (version 10) you can manually delete cookies (instructions for this can be found at http://support.microsoft.com/kb/278835);

in Firefox (version 24) you can delete cookies by clicking “Tools”, “Settings” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show cookies” and then |Delete all cookie files”

in Chrome (version 29) you can delete all cookies by going to the “Settings and Management” menu and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site data and plugin” before clicking “Clear browsing data”.

For more information about cookies and how to disable them, visit http://www.allaboutcookies.org;

- log files track events on the Site and collect data, including your IP address, browser type, Internet service provider, the page that redirected you, the exit and date/time entry page.

- web beacons, tags and pixels are electronic files that are used to record information about how you browse the site.

None of these actions are related to the visitor personally and are measured only as a whole.

 HOW DO WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSES?

 We use your personal data, as a rule, to fulfil any orders made on the Site (in particular to process payment information, arrange delivery and provide you with invoices and / or order confirmations), to improve and optimize our site, improve service delivery.

In addition, we use your personal information for purposes that are in our legitimate interests to:

- communicate with you about our services;

- send messages that you have specifically requested or consented to, including informational, promotional/commercial e-mails;

- work with inquiries and complaints that you have created or about you related to our site;

- provide you with the opportunity to use the services available on our Site;

- check compliance with the terms and conditions governing the use of our site (including monitoring of personal messages sent through our site personal message service);

- ensure security, check our orders for potential risk or fraud; prevent fraud, illegal or harmful acts;

- provide network and information security;

-  evaluate the success of our marketing and remarketing advertising campaigns;

- fulfil contractual and legal obligations;

- for internal administrative purposes within the company, group of companies, including for the processing of personal data of customers or employees;

- other purposes.

 The personal data provided to us on the Site will be used for the purposes specified in this Privacy Policy.

 TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA?

We may transfer your Personal Data to the following categories of recipients.

Affiliates and official partners. In some situations, companies with which we are affiliated or with which we have a partnership may sell or supply you with products or services directly through our services or with their help, independently, on our behalf or jointly with us.

In this case, your personal data will be transferred only to the extent necessary for this purchase or service.

Employees and officials. We may disclose your personal information to any of our employees, employees of our affiliates, officials, consultants. We may disclose your personal information to any member of our affiliates within the reasonable limits necessary for the purposes set forth in this Policy.

Agents: We hire other companies and people to perform tasks on our behalf, so we need to pass on your information to them to make our products and services available to you. Our agents have no right to use your personal information that we provide to them, except when it is necessary to assist us.

Such agents include:

 - payment systems;

            - fraud protection and security services;

            - advertising networks;

            - providers of analytical services;

            - accommodation service providers;

- telecommunication service providers.

Advertisers. We may allow advertisers and/or merchant partners (hereinafter referred to as the “Advertisers”) to select demographic information about users who see their ads or promotions, and you agree that we may provide the Advertiser with any information collected about you in a depersonalized form in order to so that the Advertiser can select the appropriate audience for advertising and/or promotions.

For instance, we may use your location information to show you ads in that geographic region, but we do not share this information with potential advertisers. Or we may allow Advertisers to show ads to users with behavior similar to yours, but we may not disclose information about your use of the Services, except in a generalized form, and only so as not to allow you to be identified.

Please note that if an advertiser asks us to show an advertisement to a specific audience and you view that ad, the advertiser may conclude that you fit the description of the target audience.

Business transfer. It may also happen that we want to buy or sell assets, and as part of the valuation or performance of such a transaction, we may provide and/or transmit customer information. Also, if our company (or our assets) are purchased, ceased to operate, go bankrupt or change ownership in any other way, your personal data may become an asset that will be transferred to or acquired by a third party.

Other third parties. We may share your personal information with third parties to use it as described above.

Depersonalized information. We may depersonalize your Personal Information in such a way that it will not be possible to identify you and pass it on to our partners. We may also provide aggregated information used by the Site to our partners (or allow them to collect such information) so that they can understand how often and how people use the Services and improve your experience of using the Services. However, we never disclose aggregated or depersonalized information to our partners (and do not allow them to collect such information) in a way that identifies you.

We may disclose your personal information as follows:

            - to the degree provided by law;

            - in connection with any ongoing or possible litigation, including the execution of requests from law enforcement agencies or other specially authorized governmental organizations;

- to establish, exercise or protect our legal rights (including providing information to others to prevent fraud and reduce credit risk);

            - any person who, in our opinion, may apply to a court or other competent authority for disclosure of such personal information, if, in our opinion, such court or authority is likely to order the disclosure of such personal information;

- to comply with applicable laws and regulations or to protect our rights in any other way;

- resolution of technical or other operational issues.

Except as provided in this Policy, we will not share your personal information with third parties.

We will also not sell your personal information that we have received.

 Please note that our site contains hyperlinks and information about third party sites. We do not control and are not responsible for the privacy policies and practices of third parties.

We cannot control the privacy policies and policies of websites and third party businesses or anything else, so if you wish to make a purchase or order a service related to third parties or official partners, please read their privacy policy.

 INTERNATIONAL DATA TRANSMISSION

The information we collect may be stored, processed and transmitted between any country in which we operate so that we may use the information in accordance with this Policy.

The information we collect may be passed on to the following countries that do not have data protection laws similar to those in force in the European Economic Area: the United States, Russia, Japan, China and India.

Personal data that you publish on our site by yourself or provide for publication on our site may be available online around the world. We cannot prevent the use or misuse of such information by others.

 STORAGE OF PERSONAL DATA

This section sets out our data storage policies and procedures to help us comply with our legal obligations regarding the storage and deletion of personal data.

The personal data we process for any of the purposes or purposes set forth in this Privacy Policy shall not be retained for longer than is necessary for that purpose or purposes.

After 12 months of receiving your personal information, we will normally delete your personal information, except as provided in this policy.

Despite the other provisions of this section, we retain documents (including electronic documents) that contain personal data to the degree required by law and to the extent of necessary to protect our legitimate rights and interests.

In the future, we may store some information in an impersonal or generalized form, but not in a form that identifies you.

 SECURITY OF YOUR PERSONAL DATA

We will take reasonable, technical and organizational security measures to prevent the loss, misuse or alteration of your personal data.

We will store all personal data that you provide on our secure (password and other possible secure) servers.

All electronic financial transactions carried out through our site will be protected by encryption technology.

You acknowledge that the transmission of information over the Internet is inherently dangerous, and we cannot guarantee the security of data transmitted over the Internet.

Your account is protected by password for your privacy and protecting your information. If you access your account through a third-party site or service, your account may be protected by additional third-party protections. You should take steps to prevent unauthorized access to your account: choose an appropriate password and/or other login mechanism and ensure its security, restrict access to your device, log out of your account after working with it.

You are responsible for maintaining the confidentiality of the password you use to access our site; we will not ask you for a password (except when logging in to our site).

 CHANGES TO THE PRIVACY POLICY

We may update this privacy policy from time to time to reflect, for example, changes in our policies or for other operational, legal or regulatory reasons.

You should check this page periodically to make sure you understand any changes to this policy. We may notify you of changes to this policy by email or through the personal messaging system on our website.

We will notify you about changes through the Services (for example, we will publish messages), via e-mail and/or in other ways. Please note that even if you choose not to receive emails from us with legal notices (or do not provide your e-mail address), or do not receive notifications from us, they will still regulate your use of the Site and you will bear responsibility for getting acquainted with them. If you continue to use the Site after changes to the Privacy Policy have been posted, it means that you agree to all changes. The use of the collected information is subject to the Privacy Policy in force at the time of collecting this information.

We update this privacy policy at least once every 12 months.

 YOUR RIGHTS

Access and confirmation. You can request more detailed information about what personal data we have, as well as request a copy of this data, confirm the processing of your personal data.

Correction. If you believe that your personal data stored in our system is incorrect or incomplete, you can request a correction or addition to the data by e-mail, explaining the reason for your request.

Deleting. You can ask to delete all your personal data that we have.

If you are a parent or guardian of a Site user under the age of 13 or, in some cases, 16, you may at any time send us a request to (a) stop collecting this user’s personal information and (b) delete the personal information already collected of this user.

Withdrawal of consent. We process your personal data with your consent (given during the collection of such data), and you have the right to withdraw your consent at any time. However, please note that in this case, you may be required to consent in certain cases of use and disclosure of certain personal data, if such consent is required in order to be able to use some or all of the services we provide.

Moving data. You can request a copy of your personal data in machine-readable format. You can also request a data transfer to another controller if such a transfer is deemed technically possible.

Denial. You may tell us that you do not wish to further use or disclose your personal information for certain purposes.

Restrictions on processing. You can send us a request to limit the further processing of your personal data.

The right to file a complaint. You have the right to apply a complaint against the company’s policy regarding your personal information with the higher authorities of your country or EU Member State.

If you would like to exercise your rights listed above, please contact us via the contact information below.

Please note that if necessary, we may request additional documentary evidence of your identity to fulfil your requests.

In addition, if you are a resident of Europe, we note that we process your information in order to fulfil any agreements we may have with you (for instance, if you place an order through the Site) or otherwise pursue our legitimate business interests, listed above.

The processing and decision-making of your applications is not automated, so you can be assured that all your applications will be considered within the rights granted to you.

 BEHAVIORAL ADVERTISING

As described above, we also use your personal information to provide you with targeted advertising or marketing communications that we believe may be of interest to you. For more information on how targeted advertising works, you can visit the Network Advertising Initiative (NAI) training page: http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can refuse of targeted advertising by following the links below:

            - Facebook: https://www.facebook.com/settings/?tab=ads

            - Google: https://www.google.com/settings/ads/anonymous

            - Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

You can also refuse from  some of these services by visiting the Digital Advertising Alliance: http://optout.aboutads.info/.

 «DO NOT TRACK»

Please note that we do not change our site’s collection and use practices when we see “Do Not Track” signal from your browser.

 DATA RECOVERY

When you place an order through the Site, we retain your information for our records unless and until you exercise your rights under this policy, including the right to delete that information.

 FOR ADDITIONAL INFORMATION ABOUT OUR PRIVACY POLICY, IF YOU HAVE A QUESTION OR DO YOU WANT TO FILE A COMPLAINT, PLEASE CONTACT VIA E-MAIL SUPPORT@FIN-GEARS.COM

 

Contact information of a person responsible for data protection

Fin-Gears Ltd., Alona Pastushenko

 

Address for correspondence

3422 Old Capitol Trail, PMB 660

Wilmington, DE 19808 USA

E-mail address

a.p@fin-gears.com

Telephone

+1 (416) 619-5994