Privacy Policy

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By visiting the Company’s websites, mobile apps or other online properties, or by creating an account through our Services, you hereby agree to the Privacy Policy.

2.WHAT INFORMATION WE COLLECT?

We collect two types of information from our Users and from visitors of our Services:

3.MINORS

The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.

We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at DPO@usersupportteam.com.

4.HOW WE USE THE COLLECTED INFORMATION?

We use your Personal Information for the purposes listed below:

• To set up, manage and update your account;
• To provide and operate the Services (such as for payment processing);
• To communicate with you and to keep you informed of our latest updates to our Services and special offers;
• To market our Services (see more below under “Marketing”), as well as to serve you advertisements, including behavioral advertising;
• To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);
• For Customer Relationship Management purposes, and to support and troubleshoot the Services and to respond to your queries;
• To enable us to further develop, customize and improve the Services based on Users’ common preferences and uses;
• To communicate with your and to process any of your requests to exercise your User Rights;
• To identify and authenticate your access to certain features of the Services;
• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
• To investigate violations of our policies and User Agreement as well as enforce our policies and the User Agreement;
• To investigate and resolve disputes in connection with your use of the Services; and
• As required by law or regulation (such as Know Your Customer ("KYC") and Anti-Money Laundering regulatory requirements), or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.

5.MARKETING

The Company will use Personal Information collected through our In-House Brands, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Company; (ii) Company's business partners and affiliates, including but not limited to the website cybersays.club (collectively: “Marketing Affiliates”), which we believe may interest you.

We may also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS telephone marketing and push notifications.

You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to abuse@i-m-l-slu.com.. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications. Also, please note that you can unsubscribe from receiving browser push notification through your browser settings.

6.WITH WHOM WE SHARE INFORMATION?

We do not rent, sell, or share your Personal Information with third parties (“Recipients”) except as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.

We share Personal Information with any of the following recipients:

• Companies within the Company and other affiliated companies;
• Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
• Payment service providers, payment processors and banks;
• To any third parties who provide services in relation to the operation or promotion of the Services;
• Auditors, contractors or advisers of any of the Company’s business processes;
• To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);
• Governmental and regulatory bodies, in accordance with applicable laws and regulations; and
• Potential purchasers or investors in any of the companies within the Company or While Label Brand (if applicable), or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within the Company (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy).

In addition to the purposes listed in this Privacy Policy, we share Personal Information with those Recipients for any of the following purposes:

• Storing such information on our behalf, for example by using cloud computing service providers;
• Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
• Performing research, technical diagnostics or analytics;
• Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see above, under "Marketing"); and
• Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies (including our User Agreement and Privacy Policy), protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.

7.TRANSFER OF INFORMATION

Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union.

We use best efforts to ensure that your Personal Information is protected in accordance with our privacy policy, through contractual means (such as by using the contractual clauses approved by the relevant regulators for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection).

8.THIRD PARTY TRACKING TECHNOLOGIES

When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies ("Tracking Technologies").
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
We also allow third parties to collect information about you through Tracking Technologies. To learn more please visit our Cookie Policy.

9.THIRD PARTY SERVICES

While using the Services you may encounter links to third party websites, services or applications. Please keep in mind that this Privacy Policy does not apply to any third party websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services.
For example, when making a payment by credit card our third party billers / IPSP's (and not HolaFreeX.ImNude.com) collect your credit card information and other information necessary for processing / authorizing your credit card payments. These payment companies may also provide certain of your details to us.
Please be advised that such third party websites, services or applications are independent from the Company. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties.
You should always review their privacy practices carefully before providing Personal Information to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.

10.RETENTION OF PERSONAL INFORMATION

If you have registered with an account through our Services, the Company will retain your Personal Information during the period your account is active. In addition, the Company will retain your Personal Data for additional periods, to enable the Company to meet its legal obligations under applicable laws or regulations, Know-Your-Customer and Anti-Money Laundering regulations.
In addition, the Company may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Company’s legitimate interests, such as fraud prevention and record keeping.
If for any reason you wish to delete your Personal Information, please send us an e-mail to: DPO@usersupportteam.com, and we will make reasonable efforts to address your request.

11.YOUR RIGHTS

If you reside in the EU or in other locations that provide you with the below rights, you may contact us at any time by email (at: DPO@usersupportteam.com), and request:

1. To access or delete any Personal Information relating to you;
2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
3. That we will restrict or cease any further use of your Personal Information;
4. That we will provide the Personal Information you volunteered to us in a machine-readable format.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including any legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

You are able to submit a complaint to the applicable supervisory authority in relation to our processing of your personal data. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve this.

12.HOW WE KEEP YOUR INFORMATION SECURED

We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:

• Secure network topology, which includes intrusion prevention and Firewall systems;
• Encrypted communication;
• Authentication and Access Control;
• External and Internal audit tests; etc.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

13.CHANGES TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Services and/or we will send you an e-mail regarding such changes to the e-mail address that you volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

14.HOW TO CONTACT US

If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at DPO@usersupportteam.com or by sending a letter to:

• I.M.L. SLU
• Attn: Data Protection Officer
• Edifici Burge's Planta 3, Avinguda St. Antoni 27, La Massana AD 400 Principat d'Andorra.

You may contact our representative in the EU by the following contact details:

• Nicolaou Pentadromos Center , corner of Agias Zonis & Thessalonikis St, 3025, Limassol, Cyprus
• privacy@usersupportteam.com

15.CALIFORNIA RESIDENTS

This part of the Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, "CCPA").

15.1 Categories of Personal Information We Process?
In the 12 preceding months, we have collected and disclosed the categories of Personal Information as listed in the above sections "What Information We Collect?" and "With Whom We Share Information?"
We do not sell (as this term is defined under the CCPA) any Personal Information.
We may share or transfer Personal Information to third parties as assets that are part of a merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of the Company. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a sale of Personal Information under the CCPA.

15.2 Sources of Personal Information
In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

• Consumer directly;
• Social Networks;
• Internet Service Providers;
• Data analytics providers;
• Operating Systems;
• 3rd party billers.

15.3 User Rights under the CCPA
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Personal Information

You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business purpose for sharing your Personal Information, if applicable.

Deletion Requests

You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.

Exercising Your Rights

You can exercise your rights (such as access and deletion) by submitting a verifiable consumer request to our email address: DPO@usersupportteam.com or by sending a mail to our physical address specified in the HOW TO CONTACT US section.

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information

The request must:

• Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.



You may only request a copy of your data twice within a 12-month period.




If you have any general questions about the Personal Information that we collect about you how we use it, please contact us at DPO@usersupportteam.com.





Response Timing and Format

Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request. Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.




Designating Agents




You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
• You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.




15.4. Non-Discrimination

Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.