This document describes what personal data is collected or generated (processed) when you interact with MB Optimisation Solutions (hereinafter - “we”, “us” or “our”) through our websites and/or any other digital experiences when you purchase a product or service, sign up to receive communications from us, or request something from us and how such data is processed.

In case of any inquiries or if you would like to exercise any of your rights provided in this policy, you may submit such inquiries and requests by contact us regarding all privacy related issues by email: [support@testa-soft.com]

It is hereby noted that your personal data is processed in accordance with any and all applicable legal acts regulating the protection and processing of personal data.

Any changes to this policy will be published publicly and, in case of material changes, we may inform you about such via email or by other means which we will deem the most fitting in a particular case.

1. WHAT PERSONAL DATA IS COLLECTED BY US

Personal data or personal information means any information about an individual from which that person can be identified in any way. We may process, i.e. collect, use, store and transfer different kinds of personal information about you. Such information may include:

Identification information (name, username or similar identifier, date of birth, gender etc.)
Contact information (e-mail address, billing address when applicable etc.)
Service information (your account details, bank account and transaction details and other information that may you provide to us while registering and/or filling up the relevant questionnaires or forms from us)
Device and technical information (IP address, your login data, browser type and version, time zone setting and current geographical location, browser plug-in types and versions, language preferences, operating system and platform and other technology or other unique identifier (a set of numbers or characters that is assigned to your computer, mobile phone, or other device when you are on the Internet) for any computer, mobile phone, tablet or other device (any of which are referred to herein as a “Device”) used to access our websites or services).
Usage data (information about how you use our websites, mobile application, including all of the areas within our mobile application and websites that you visit or use and the time of day you visited the websites and mobile application, among other information, such as location upload etc.)
Marketing information (relating to your preferences in receiving marketing information and communication from us and our third parties and your communication preferences)
Correspondence data (communication content and metadata associated with the communication that you send to us)

We do not collect and/or process any special categories of personal data (such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences.

We obtain the aforementioned personal data either directly from you or automatically (as you navigate through our websites, we may automatically collect technical, usage information about your tools, browsing actions and patterns).

2. WHY DO WE USE YOUR PERSONAL INFORMATION

We may use the information we collect about you, including personal data, including, but not limited to:

provide you with our products and services at your request and related customer service;
to identify you as a user in our systems,
to provide improved administration of our websites and services,
to process transactions you initiate (if any),
process payments and provide accurate billing (if any),
respond to your inquiries,
to market our services, including recommending products/services that might be of interest to you,
to customize and tailor and improve quality of your experience on the websites,
to notify you about changes to our service, where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice,
to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities,
for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure,
to perform other functions as described at the time of collection, with your consent, or as described in this Privacy Policy.

We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.

3. OUR LEGAL BASIS

To process your personal data, we rely on certain legal grounds, depending on how you interact with our mobile application and/or website:

Fulfillment of our contract with you or to process your request to enter into such contract when you use our mobile application;
Your consent, when you provide us with such, as required per applicable legislation;
Our legitimate interests as a business to process information about the effectiveness of our marketing campaigns, our products, services, events and other promotional initiatives; to operate, improve and maintain our business, products and services; to protect our or others’ rights, property or safety; and for general research and analysis purposes. When processing personal data for our legitimate interests, we take appropriate measures to ensure that the interests we pursue are balanced with your interests, rights and freedoms, which we are happy to explain upon request.
In order to to comply with a legal obligation, or to protect vital interests.

4. YOUR RIGHTS

Your principal rights under data protection law are the following:

The right to access data. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
The right to rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data. Those circumstances include when: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing and there are no other legal basis to process data; (iii) you object to the processing under certain rules of applicable data protection laws; (iv) the processing is for direct marketing purposes; or (v) the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. Such exclusions include when processing is necessary: (i) for exercising the right of freedom of expression and information; (ii) for compliance with our legal obligation; or (iii) for the establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are when: (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data, however we will only further process such data in any other way: (i) with your consent; (ii) for the establishment, exercise or defence of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
The right to data portability. To the extent that the legal basis for our processing of your personal data is:

consent; or
performance of a contract or steps to be taken at your request prior to entering into a contract, necessary to enter into such, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

5. DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your personal data to other service providers insofar as it is reasonably necessary to provide specific services (including, providers of servers and maintenance thereof, email service providers, service providers used for data analysis or marketing, customer satisfaction surveys or market research). We take all the necessary measures to ensure that such subcontractors would implement proper organisational and technical measures to ensure security and privacy of your personal data.

We may disclose your personal data to our payment service providers. We will share service data with our payment services providers only to the extent necessary for the purposes of processing your payments, transferring funds and dealing with complaints and queries relating to such payments and transfers.

We may disclose your personal data to our anti-fraud, risks and compliance providers insofar as reasonably necessary for the purposes of protecting your personal data and fulfilling our legal obligations.

In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. RETENTION OF YOUR PERSONAL DATA

Your personal data will be retained for as long as is necessary to carry out the purposes set out in this privacy policy (unless a longer retention period is required by applicable law). For personal data related to product purchases, we retain this longer to comply with legal obligations (such as tax and sales laws and for warranty purposes).

7. COOKIES

Cookies are small textual files containing identifier that is sent by a web server to your web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

We use cookies of three main types, for the following purposes:

Functional cookies: These cookies are required for basic site functionality and are therefore always enabled. These include cookies that allow you to be remembered as you explore our services within a single session or, if you request, from session to session.
Performance cookies: These cookies allow us to improve our functionality by tracking usage. In some cases, these cookies improve the speed with which we can process your request and allow us to remember site preferences you have selected. Refusing these cookies may result in poorly-tailored recommendations and slow site performance.
Advertising cookies: Social media cookies offer the possibility to connect you to your social networks and share content through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond our services. In some cases, these cookies involve the processing of your personal data. Refusing these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via information provided in the relevant browser website, for example Chrome; Firefox; Internet Explorer; Safari.

8. THIRD PARTY WEBSITES

Our websites may include links to third-party websites, plug-ins and applications and certain content on the mobile application and/or websites may be hosted and served by third parties that we do not control. When you click on a link to any other website or location, you will leave our websites and go to another site and another entity may collect personal information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites, their privacy statements or content, or to any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. In addition, our content may be included on web pages and websites that are not associated with us and over which we have no control. These third parties may collect data through the use of their own cookies, pixel tags or other technology, independently collect information or solicit personal information, and may have the ability to track your use of their websites and services. We are not responsible for the privacy practices or the content of any third party.

9. CHILDREN’S PERSONAL DATA

Our websites are not designed for, or directed to, children under the age of 18 and we do not intentionally collect information about anyone under the age of 18. If we discover that we have inadvertently collected personal data from anyone younger than the age of 18, we will attempt to delete the information as soon as possible.