Rafflu.com Service (hereinafter referred to as “Rafflu.com service”, “we” or “our” and similar terms) fully appreciate the trust of the users and is aware of its responsibility for the security and confidentiality of the data. Our Privacy Policy describes what kind of information we collect when you use Rafflu.com Service. We hereby explain why it is necessary and how these data help us evolve.

Our Privacy Policy regulates the collection, use, transfer, and protection of information by us and some companies we cooperate with when using our website, platforms, and any software provided via Rafflu.com Service (together referred to as “the Service”) as well as your opportunities on control of the collection and use of your information. The present document is applied to all Visitors, Users, and Licensees who obtain access to the Service under the Terms of Use (hereinafter referred to as “Users”, “You”, “Your” and similar terms).

We also process personal information on behalf of Users as the Private data processor, for instance, the content published via our Service according to the instructions submitted to us by our Users (hereinafter referred to as “the Content of the User”, “User-Generated Content”). Our Users control the way the content submitted by them is collected and used. In legal terms, this means that our Users are controllers of the User-Generated Content. Thus, we use only User-Generated Content for giving access to the Service to our Users in accordance with the instructions based on the legislation, which they submit to us via the Service.
The Authorities are not responsible for the verification of private data submitted by the User of Rafflu.com Service and the provision of the necessary consents, presuming that the User acts diligently and in good faith and uses all best endeavors to maintain such the information at the actual state and obtain all required consents of personal data subjects.

Collection and processing of personal data

Since you register Rafflu account and start using the Rafflu.com Service, we have the right to collect the following information:

• The E-mail address and password entered when registering an account as well as details for issuing the invoice as follows: billing address (optional); Tax ID of the User (optional); Username (optional);
• Unique User ID which is assigned upon registration on Rafflu.com Service website;
• Data related to the User’s real-time location; the geographical area in which your computer and/or mobile device or any other device is used; and language data;
• Any other additional information as a part of your Rafflu account;
• User-Generated Content (for instance, profile image, display name, username/page ID/handle, access tokens, texts of comments and texts of sent or received private messages, social account insights data and social account demographic data, sent tweets, social account follower counts, social account insights data and social account audience data and other materials located on supported platforms);
• Your correspondence with Rafflu.com Service, including chats(contact details when you provide them with respect to customer, vendor, and partner relationships with us) and comments published on the Blog. For instance, we can send you e-mails related to the Service (such as registration confirmation, information on changes and updates of the Service functionality, technical and security notifications). Note that you cannot unsubscribe from e-mails related to the Service;
• Images and other files which you can publish via our Service;
• Your IP address and other data on your device (for instance, browser type and the type of device which you use to work with our Service).

We may also receive private information about your business profiles from social network profiles linked to your Rafflu.com Service account, including Facebook, LinkedIn, Twitter, Odnoklassniki, etc.

We also securely store Google access tokens which allow us to publish content on Google My Business and YouTube on your behalf. These access tokens can be revoked at any time.

In all cases when we receive data from any platform the Rafflu.com Service is integrated with, we will let you know which data is collected by the Rafflu.com Service, and you will need to give your consent to the receipt of your personal data from these platforms and processing it by the Rafflu.com Service on your behalf.

For more information on the purpose and extent of the data acquisition and how data are processed and used by the respective supported platforms as well as regarding your rights and optional settings to protect your privacy, please refer to the privacy policies of the respective supported platforms:

• Facebook Privacy Policy: https://www.facebook.com/about/privacy;
• Twitter Privacy Policy: https://twitter.com/en/privacy;
• Google Privacy Policy: http://www.google.com/policies/privacy, etc.

We cooperate closely with other third parties (including e.g. business partners, technical, payment, and delivery services sub-contractors, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. The information we receive is used to enhance your experience on the Rafflu.com Service.

When making payment of the rate under the selected tariff plan, payment data, such as credit or debit card number or any other information related to it is processed by the provider of payment services and is neither stored nor processed on the servers of Rafflu.com Service.

Use of cookies and similar technologies

1) Сookies
Rafflu.com Service uses cookies and active components (e.g. JavaScript) to improve the functionality and working level.
“Cookies” are small text files that are designed to hold a modest amount of data specific to a particular website you visited. Cookies allow websites to save data about users that visited them in order not to request their login and password repeatedly.
You can instruct your browser to refuse all cookies or to indicate when cookies are being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Additionally, Rafflu.com Service uses four (4) categories of cookies:

• Functional cookies. We may use Session Cookies to ensure proper operation of the Service;
• Statistical cookies. We may use Session Cookies to measure the audience of the website;
• Advertising (marketing) cookies. We may use first-party or third-party cookies and web beacons to deliver content, including advertising relevant to your interests, on our Website or on third parties websites. This includes using technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement;
• Preference Cookies. We may use cookies, web beacons, or other similar technologies to assess the performance of our Website, Service, and tools, including as part of our analytic practices to help us understand how our visitors use our Website, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Website content, applications, services, or tools.

2) Third-party сookies
Rafflu.com Service uses plug-ins and platforms of third-party web resources (e.g. Facebook, Instagram, etc.) which, in their turn, may use cookies and active components. Rafflu.com Service is not responsible for the processing of personal data by these web resources. Note that the Settings configuration type of cookies used by Rafflu.com Service does not affect the cookies and active components of third-party web resources (e.g. Facebook, Instagram, etc.).
Please visit the websites of the corresponding web resources to be informed of how the data are processed:

• Facebook is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). You will find an overview on Facebook’s Plugins and what they look like at https://developers.facebook.com/docs/plugins ;
• Instagram is operated by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. You will find an overview on Instagram’s Plugins and what they look like at https://developers.facebook.com/docs/instagram-api/
• Twitter is operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”). You will find an overview on Twitter’s Plugins and what they look like at https://developer.twitter.com/en/docs/api-reference-index;

3) Web Analytics

We use third-party tools to analyze and estimate traffic and Service usage trends. These tools collect information sent by your device or our Service including data on web pages you visited, browser extensions, and other information that may help us improve the Service. We collect and use this analytical information together with the same kind of information received from other Users way it is impossible to identify any specific User on its base. Access to these anonymized data is given to authorized persons. We may use:

• Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the collected data to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the advertisements of its own advertising network. For more information on the privacy practices of Google Analytics, please click here.
• Yandex.Metriсa service. Yandex. Metriсa service is a web analytics service offered by Yandex that tracks and reports website traffic. For more information on the privacy practices of Yandex. Metriсa service, please click here.

How we use your personal data

The main purpose of processing personal data is the fulfillment of the obligations under the Terms of Use and the License Agreement by Rafflu.com Service to the Users with respect to use of the Service. We also process User’s personal data for the following purposes:

• Identification of the User with respect to the use of the Service and ability to make agreements and contracts with Rafflu.com Service. The User’s Rafflu account is associated with his login and password or e-mail address;
• Fulfillment of the obligations under agreements and contracts for the use of the Service as well as compliance with all applicable laws and regulations;
• Providing you with the efficient customer and technical support related to the use of Rafflu.com Service with respect to the fulfillment of obligations under contracts and agreements;
• Informing you of services, features, offers, competitions, and events which may be useful to you in our opinion or on which you requested the information from us;
• Storing data in order not to cause inconvenience to you by entering them repeatedly during the current or future session on the website of Rafflu.com Service;
• Maintaining in operational condition, improving, testing, and monitoring the work of the Service;
• Developing and testing new products and features;
• Monitoring metrics, e.g. the total number of visitors.

Links

The Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. We strongly advise you to review the Privacy Policy of every website you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites or services.

Retention

We collect and retain Personal Data submitted to the Service in an identifiable format for the amount of time necessary to meet your request or fulfill our legal or regulatory obligations unless it is in our legitimate business interests and not prohibited by law to maintain the Personal data for longer periods.

Consent

By using our Service as well as submitting or collecting any personal data via the Service you agree to the collection, transfer, and disclosure of the information on storage and use of your personal data under the procedure specified in the present Privacy Policy. If you do not agree to the use of your personal data in any of the indicated ways, you shall stop using the Service.

Security

Security and confidentiality are essential to us and our Users, this is why Rafflu.com Service undertakes all necessary organizational and technical measures to protect the personal data of the User from unauthorized or occasional access, destruction, blocking, copying, distribution as well as any other unjustified actions of third parties. Thus, Rafflu.com service uses security policies that prescribe that browsers supporting HTTPS to use this encryption protocol for every connection between the end Users and servers. The personal data are available merely to the limited number of persons, related to Rafflu.com Service, which is bound not to disclose these data.
We ask you to undertake precautionary measures on your part to provide assistance to us. You are responsible for the non-disclosure of your unique password and the data related to Rafflu account as well as for the control of access to the electronic correspondence between you and Rafflu.com Service.

Sharing of your personal data

We do not share the personal data of the Users with any third parties except the cases explicitly provided herein. Personal data of the Users may be transferred in response to an official request of public authorities of the place of incorporation of Rafflu.com Service merely by virtue of and in accordance with the legislation of the place of incorporation of Rafflu.com Service. We also have the right to obtain access to, store, and transfer the data if we have a reasonable cause to believe that it is necessary to detect, prevent or suppress fraud or any other illegal activity; to protect ourselves, you and other persons including in the course of an investigation or to prevent death щк imminent danger to health. We have the right to provide access to, process, and store your personal data for a longer period of time if they become a matter of an official request, a legal obligation, a public authorities investigation or an investigation for possible violations of our Terms of Use or Privacy Policy and in any other cases in order to prevent harm. Additionally, in the case of reorganization, merger, or sale of Rafflu.com Service we have the right to share any or all of the collected personal data with the corresponding third party.
Rafflu.com Service has the right to submit personal data in case if sharing is necessary under the use of the functionality of Rafflu.com Service by the User or for the protection of Rafflu.com Service (and its Users) activity.

How long we store your personal information
We store your Personal Information only as long as required for the relevant purpose unless it is required by law to store them for a longer period.

Rights of the users

The User has the right to change (update, add) the submitted personal data in full or in part at any time using the option of personal data editing in the Account Settings section. You can unsubscribe from marketing e-mails sent by Rafflu.com Service by following the unsubscribe instructions included in the body of each marketing e-mail.
The User is responsible for non-disclosure of his unique password and the data related to the Rafflu account as well as for the control of access to the electronic correspondence between him and the Rafflu.com Service Management Team.
The Management Team blocks personal data related to the corresponding User upon receiving an application or request from the User or his legal representative or an authorized body for protecting the rights of personal data subjects as well as in cases of unlawful action detection. Personal data of the User is subject to destruction in the following cases:
– When deleting Rafflu account by the Management team in cases stipulated by the License Agreement or Terms of Use.
– When a personal data subject revokes the consent for personal data processing.
Requests to access, correct, or delete your information will be handled within thirty (30) days unless they are unusually extensive or complex, in which case we will advise you of the expected timeline for handling your request.
You can delete personal data associated with added third-party accounts (e.g. the respective accounts of supported platforms). To delete your account simply send your request to support@rafflu.com. Also, as the Rafflu.com Service entirely relies on its links to supported platforms, and their APIs (for example, the Twitter API, the LinkedIn API, the YouTube API services, etc.), you can revoke access to your data for YouTube or Google My Business using the Google Security Settings page — https://security.google.com/settings/security/permissions. You can revoke access to your data for Facebook using this link: https://www.facebook.com/settings?tab=business_tools; you can revoke access to your data for Instagram using this link: https://instagram.com/accounts/manage_access/.
Note that certain personal data may be stored by Rafflu.com Service for a certain period of time after the deletion of your Rafflu account, if necessary, as well as for our lawful business purposes or is required or permitted by the current legislation.

International data transfer

The GDPR replicates Data Protection Directive provisions on data export outside the territory of the EU and prohibits the transfer of personal data from the EU to non-EU countries if the transfer does not comply with certain criteria.
Notwithstanding that our headquarters are located in the Russian Federation, Rafflu.com Service has data centers and users in the EU. In some cases, we will transfer, process, and store your information outside the territory of your country of residence, wherever we or our third-party service providers grant you access to the Service. Our privacy protection level complies with the EU rules.

Children’s privacy

Our Service is not intended for use by children and should only be accessed by individuals at least 18 years old.

Additional conditions

From time to time, we may use customer information for new, unanticipated uses of which we did not notify before. If our information practices change at some time in the future we will post the policy changes to our Web site to notify you of these changes and provide you with the ability to opt-out of these new uses. If you are concerned about how your information is used, you should check back at our Web site periodically.

An individual who seeks access to, or wants to correct or, amend inaccuracies in, or delete the Content stored or processed by us on behalf of the User, should send his/her request directly to the Rafflu.com Service user (the data controller) or to the social network or third-party app developer. Upon receiving a request from our user to delete the data, we reply to it within thirty (30) days. Please note that we may need to retain certain information in our Systems for the purposes of record-keeping, in order to comply with our legal obligations, to resolve disputes, to enforce our Terms (the License Agreement, the Privacy Policy, and the Terms of Use), or as required or authorized by applicable law, for as long as you maintain your account on our Services. Please refer to the HOW LONG WE STORE YOUR PERSONAL INFORMATION section above for further details.

The new Privacy Policy comes into effect from the moment of its placement, unless otherwise provided for in the new edition of the Privacy Policy. Further use of the Rafflu.com Service after making such changes is the User’s consent to such changes. The current Privacy Policy is posted on the page at rafflu.com/privacy-policy.
If you have a question about this policy statement or a complaint about Rafflu.com Services’ compliance with this privacy policy, you may contact Rafflu.com Service by e-mail at support@rafflu.com or comments sent to us via the online support window in your browser.

Rafflu digital s.r.o.
nam. 14. rijna, Smíchov, 150 00 Praha, Czech Republic
E-mail: support@rafflu.com

Effective date: 21.12.2020