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Privacy Policy

Love Eden: Interactive Stories

Effective Date: July 22, 2024

This Privacy Policy is a legally binding contract between Noderno Limited, Pavlou Nirvana, 4 ALPHA TOWER, 1st floor, Flat/Office 13, 3021, Limassol, Cyprus (referred to as “Noderno”, "we," "us," or "our"), and users of the Love Eden: Interactive Stories application, which is distributed via application stores (referred to as the "App"). We encourage you to read this Privacy Policy carefully. By using the App provided by us, you, as a user of the App, must agree to and accept the terms outlined in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please refrain from accessing or using the App. This Privacy Policy applies to all users and anyone else who accesses the App (referred to as "Users"). Under the General Data Protection Regulation (GDPR), we act as the data controller, unless stated otherwise.

 

INFORMATION THAT WE PROCESS

Information Provided by You: We ask for and collect the following personal information about you when you use the App. This information is necessary to provide complete functionality of the App and perform the requested services.

 

Authorization and/or Account Information. When you sign up for an account or log into your account, we require your mobile phone number. We collect, store and process it by our cloud storage provider. However, we may also engage third party - Google (Firebase) - for storing this personal data in order to improve protection against spam and abuse in Google services.

Activity Information, e.g., information about the device itself, information about internet connection, location-related information, device identifiers. Otherwise, you cannot use the App. For more information about the rules, you must follow when you record any call using the App, please check our Terms of Use.

Contact Information (name, e-mail address, as well as any other content included in the email) which you may fill in by yourself when you contact us via email, support form and that we will use for communication purposes.

 

Automatically Processed Information. Based on your consent and permission we use third-party automatic data processing technologies to analyze certain information sent by your device via our App used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Such Processing starts automatically once you allow our App to track your activity. You can withdraw your permission at any time.

We may process some information about your device and your user behavior on the ground of our legitimate interest in aggregated non-identifiable form to improve user experience of our App.

 

Device Details. When you use a mobile device to access our App, some details about your device are reported, including “device identifiers” which uniquely identify your mobile device but not your personality. Device identifier enables generalized reporting or personalized content and ads by the third parties. This data includes: 

a) Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage; b) Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser; c) Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest; d) Other device identifiers: e.g. user identifiers (if they are set up by the App’s developer).

Information about the applications. Name, API key (identifier for application), version, properties of our App can be reported for automated processing and analysis, list of applications and/or processes which are installed or run on your device.

Cookies and similar technologies. When you use the App, cookies and similar technologies may be used. This enables us to operate the App more effectively and We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that are of interest to you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.

Log file information. Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, your interaction with the App.

Ad-related information. The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked” or if it was shown as a “conversion” event; what the ad offer is about; what type of ad it is (text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.

In-app events. When you use our App, analytics tools automatically record your activity information (tutorial steps, levelling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).

Transactions. We may have access to technical information about in-app purchases (Apple receipt file information).

 

Information provided automatically to advertising or analytics tools does not generally come to our control, therefore we cannot be responsible for processing such information. We do not control or supervise how the third parties process your personal data, that might be collected by their own means (not through our App). 

Please note that we have no access to your payment information (your credit or debit card information), billing, processing and charging for in-app purchases, handling of your relevant personal data is on AppStore exclusively and are subject to “in-app” purchase rules and policies directly from the AppStore.

 

THE PURPOSES AND LEGAL BASIS OF YOUR PERSONAL DATA PROCESSING

We use your information for the following purposes:

 

Availability of the service. We use the information that you submit and information that is processed automatically to provide you with all requested services.

Testing, monitoring and improvement of our App. We use the information that is processed automatically to analyze behavior and patterns, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.

Interest-based / targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences).

Communication. We use the information we have to respond to your requests, to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms.

Compliance and law enforcement. We are doing our best to protect you of spam and fraudulent content. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities.

 

Any other purposes for processing your personal data are subject to prior modification of this Privacy Policy.

 

Our processing of your personal data is contingent upon a legal basis. This basis is determined by the purpose for which we have collected and intend to use your personal data. The legal grounds for processing your personal data include:

  • Consent: We will process your personal data if you have provided your explicit consent for us to do so. We will provide visible notice and obtain your valid, specific, and informed consent before collecting, using, sharing, or processing your personal data for advertising and related purposes. This includes serving interest-based advertising and improving our services, including our AI-powered technologies.

  • Legal Obligation: When required to adhere to legal obligations, we may process your personal data.

  • Legitimate Business Interests: Processing may occur when it aligns with our legitimate business interests.

  • Specifically, personal data submitted through this website and collected from you, third parties, or public sources will be utilized for purposes grounded in the following legal foundations:

  • Communications - Legitimate Interest: If you have engaged with us via the Website or App or other means, we might process your personal data to facilitate effective communication, arrange meetings, calls, or virtual sessions. It's important to note that such communication could be recorded and stored within our corporate system.

  • Marketing and Public Relations - Consent: For visitors of our Website and User of App, we may employ cookies to conduct marketing research, analyze visitor characteristics, evaluate the efficacy of our marketing communications, tailor them to identified trends, plan future marketing initiatives, deliver ads in our mobile application, and create analytics and profiles for business insights. Additionally, for subscribers or potential subscribers, we may utilize the personal data you've provided to share promotional materials, announce service updates, deliver email notifications, and circulate newsletters. We are committed to upholding the principles of data protection while ensuring transparent and lawful processing based on the appropriate legal grounds.

  • Automated Processing in accordance with our Legitimate Interest: For visitors of our Website and App, essential cookies and third-party services will automatically process data concerning your interactions with the site or app. This process assists us in gaining deeper insights into your preferences and enhancing your overall experience on our website.

 

DATA SHARING AND DATA TRANSFER

We will share your information with third parties only in the ways that are described in this Privacy policy and with application of necessary technical and organizational measures to protect your personal data. But please be aware that we are not responsible for any accidental loss or unauthorized access to your personal data through a fault of third parties. 

We will not rent or sell your personal data to any third parties, but we may share your information from tools like log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used. We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements. We work with AppLovin to deliver ads in our mobile application and other devices and/or platforms. For more information about AppLovin’s collection and use of your information visit: https://www.applovin.com/privacy/ 

Third-party service providers we engage in order to provide our services:

 

Name

Services 

location

Privacy Policy

Google Inc.

Cloud storage provider

U.S.A.

https://cloud.google.com/terms/cloud-privacy-notice  

Amplitude Inc.

Analytics service provider

U.S.A.

https://amplitude.com/privacy

AppsFlyer Inc.

Analytics service provider

U.S.A.

https://www.appsflyer.com/legal/privacy-policy/
https://www.appsflyer.com/legal/services-privacy-policy/

Apple Inc.

Cloud storage provider (for iOS devices)

U.S.A.

https://www.apple.com/lae/privacy/

Google Inc.

Analytics and marketing service provider

 

https://policies.google.com/privacy?hl=en-US 

Facebook (Meta Platforms, Inc.)

Analytics, user acquisition and marketing service provider

U.S.A.

https://www.facebook.com/privacy/explanation

Firebase (Google LLC)

Data storage, user authentication, analytics and marketing service provider

U.S.A.

https://policies.google.com/privacy
https://firebase.google.com/support/privacy

AppLovin Corporation

App monetization solution

USA 

https://www.applovin.com/privacy/  

Playfab

Game Server services

USA

https://privacy.microsoft.com/privacystatement 

 

Our App may contain links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it is needed for objective reasons, due to the public interest: a) as required by law; b) when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; c) if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.

 

THE TERM OF YOUR PERSONAL DATA USE

Your personal information retains for as long as is necessary for performing the service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and your account. Please be informed that some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other illegal activity.

 

YOUR PRIVACY RIGHTS

You have the following options in relation to your personal data we collected:

 

Data Access and Portability. You can request copies of your personal information held by us.

Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask to correct, change, update or rectify your data.

Data Retention and Deletion. The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.

Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

 

To exercise any of the rights described above, you can contact us through support@noderno.tech. When your personal information is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third-party services listed in the relevant section of this Privacy Policy.

 

YOUR RIGHT TO OPT OUT

Opt-out of marketing tracking. If you don’t want third-party service providers to use the personalized ads on the basis of your interests, please choose option "Limit Ad Tracking" on your iOS device in Settings/ Privacy/ Advertising, please find additional information here: https://support.apple.com/en-us/HT202074

Choose option “Opt out of Ad Personalization” on your Android device in Settings/ Google/ Ads. You can also visit https://youradchoices.com for the same purpose. Even if you opt out of certain interest based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

Opt-out of Location Data Processing. If you don’t want third-party service providers to use your precise location data, or street-level location information about you turn Location Services off for the applicable Product via the menu “Settings > Privacy > Location Services” (iOS 11 or later). Then select the applicable App and set the “Share My Location” status to “Never”. Please see additional information here: https://support.apple.com/en-us/HT203033. Android 5.0 or later: turn Location off for the applicable Product via the menu “Settings > Apps > [applicable Product] > Permissions > Location”.  Then turn off the “Location” button.

 

OUR SECURITY MEASURES

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible. While we do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us through the email support@noderno.tech .

 

CHILDREN’S PRIVACY

We do not knowingly collect or solicit any personal information from children under 18. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us via support@noderno.tech .

 

CALIFORNIA RESIDENT NOTICE

Under the California Consumer Privacy Act of 2018 (CCPA) California residents shall have the right to request: a) the categories of personal information that is processed; b) the categories of sources from which personal information is obtained; c) the purpose for processing of user personal data; d) the categories of third parties with whom we may share your personal information; e) the specific pieces of personal information that we might have obtained about a particular user provided that the data given in the request is reliable enough and allows to identify the user.

 

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above. Be informed that according to CCPA personal information does not include de-identified or aggregated consumer information.

DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

OPT-OUT OPTIONS. If you don’t want us to process your personal information any more, please contact us through support@noderno.tech . Please be informed that such opt out may impact App’s further operation without functional data and you will be advised to remove the App from your device. If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described above. 

REQUESTS. To submit a verifiable consumer request please contact us through the email support@noderno.tech. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

CALIFORNIA PRIVACY RIGHTS. 

  • The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months. Please, note that we shall not be required to provide personal information to you more than twice in a 12-month period.

  • The right to prohibit sale of information means that you have the right to request that we stop the processing of your data for direct marketing purposes either by asking us to cease processing all data about you or asking us not to send you direct marketing communications. We generally do not sell your Personal Information for profit.

  • The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.

  • The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

  • The right to opt out of automated decision-making technologies means your right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.

  • The right to restrict the use of your sensitive information means directly contacting us to stop such processing of your sensitive personal information for such purposes. We do not process any sensitive personal information to infer characteristics about you.

  • The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. Please note that under the CCPA we are under no obligation to comply with your request if we need to maintain your information if we need it to, among other things: (a) complete the transaction for which the personal information was collected, or (b) fulfill the terms of a written warranty or product recall; (c) detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; (d) debug to identify and repair errors that impair existing intended functionality; (e) comply with the California Electronic Communications Privacy Act; (f) enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business; (g) comply with a legal obligation.

  • Otherwise use the personal information internally in a lawful manner that is compatible with the context in which the consumer provided the information, etc.

  • The rights to portability means your right to receive your personal information  in an electronic and structured form to you or to another party. 

SALE OF DATA. We do not sell any of your personal data to third parties.

 

COLORADO RESIDENT NOTICE

This section applies only to Colorado residents in addition to the rest of this Privacy Policy. We process personal data in compliance with the Colorado Privacy Act that requires us to disclose the following additional information related to our privacy practices.

 

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will provide you with the required information in an alternative format that you can access.

 

 

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTS. To submit a verifiable consumer request please contact us through the email support@noderno.tech. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

COLORADO PRIVACY RIGHTS. 

  • The right of access means the right to know if a controller is processing the consumer’s data.

  • The right to portability provides the ability for you to receive the data in their right to access in a portable and machine-readable format, where technically feasible, that enables you to transmit the data to another entity without hindrance. Please note that you may only exercise the right to data portability twice per calendar year.

  • The right to opt-out means your right to object to the processing of your personal data for such purposes as (1) the sale of your personal data. Please note that we do not sell any of your personal data to third parties; (2) Targeted advertising, or (3) Profiling to help make decisions that produce legal or similarly notable effects concerning a consumer.

  • The right of correction means your right to request that we rectify inaccurate information about you.

  • The right of deletion means that you can ask us to delete or stop processing your personal data.

  • The right of appeal means that if you are not satisfied with resolving your privacy request, you can initiate an appeal procedure described below.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts.

If you send us a request we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee.

If we refuse to take action on your request, you can follow the appeal procedure within 30 days after receiving such refusal sending your appeal to this email  support@noderno.tech. adding in the subject of email “Appeal to answer on privacy request”.

We are obliged to consider your appeal within 45 after receipt of the appeal and inform you of any action taken or not taken in response to the appeal. We can extend this term by 60 additional days where reasonably necessary, taking into account the complexity and number of requests serving at this time.

If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

AUTHENTICATION. For the purpose of safeguarding your Personal Data against unauthorized access or deletion, we may need to authenticate your credentials before accepting a request pertaining to your rights. If you do not possess an account with us or if we suspect unauthorized access to your account, we may request additional personal information from you to verify your identity. If after these steps  we are unable to verify your identity, we reserve the right to decline your rights request.

SALE OF DATA. We do not sell any of your personal data to third parties.

 

VIRGINIA PRIVACY NOTICE

 

The following section pertains exclusively to residents of Virginia. It outlines our practices regarding the collection, utilization, and sharing of Personal Data belonging to Virginia residents, in our capacity as a business operating under the Virginia Consumer Data Protection Act ("VCDPA"). Additionally, it outlines your rights in relation to your Personal Data. Please note that the term "Personal Data" used in this section holds the definition ascribed to it by the VCDPA, with the exception of information exempted from the VCDPA's scope.

 

 

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTS. To submit a verifiable consumer request please contact us through the email support@noderno.tech. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

VIRGINIA PRIVACY RIGHTS. As a resident of Virginia, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations.

  • Correct inaccuracies in the consumer’s personal data that is collected by the controller.

  • Confirm if the controller is actually processing their personal data or request a copy of the personal data.

  • Delete personal data provided by or obtained about the consumer. 

  • Obtain copies of the personal data collected by the controller. 

  • Opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling.

  • The right to restrict processing of your sensitive personal information. We do not process any sensitive personal information to infer characteristics about you.

  • You have the right to be free from discrimination related to your exercise of any of your Virginia privacy rights.

  • Appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. Please, specify clearly what you want to exercise and identify yourself. Please note that we are not required to comply with the request if we are unable to authenticate your request using commercially reasonable efforts.

If you send us a request we will reply to you within 45 calendar days free of charge, except that, for a second or subsequent request within a twelve-month period, we may charge a reasonable fee.

If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email  support@noderno.tech. adding in the subject of email “Appeal to answer on privacy request”.

We are obliged to consider your appeal within 45 after receipt of the appeal and inform you of any action taken or not taken in response to the appeal. We can extend this term by 60 additional days where reasonably necessary, taking into account the complexity and number of requests serving at this time.

If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

AUTHENTICATION. For the purpose of safeguarding your Personal Data against unauthorized access or deletion, we may need to authenticate your credentials before accepting a request pertaining to your rights. If you do not possess an account with us or if we suspect unauthorized access to your account, we may request additional personal information from you to verify your identity. If after these steps  we are unable to verify your identity, we reserve the right to decline your rights request.

SALE OF DATA. We do not sell any of your personal data to third parties.

 

CONNECTICUT PRIVACY NOTICE

     

This notice outlines the manner in which we, acting as a "Controller" under Connecticut's Data Protection Act ("CTDPA"), collect, utilize, and disclose your personal data, as well as the rights you have concerning your personal data, including sensitive personal data. In this context, "personal data'' and "sensitive data" carry the definitions provided in the CTDPA and do not encompass information excluded from the scope of the CTDPA.

 

 

PERSONAL INFORMATION. All about the categories of information, its sources and purposes of processing is described above.

DATA SHARING. Data sharing scope and basis are defined above. All third parties that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

REQUESTS. To submit a verifiable consumer request please contact us through the email support@noderno.tech. Before processing most requests, we will need to verify your identity and confirm that you are a resident of the State of Connecticut. When submitting a verifiable request, you should be ready to: a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm that personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

 

If you are submitting a request on behalf of a Connecticut resident, including a minor child, we will also need sufficient information to verify that the individual is the person about whom we collected personal data, and that you are authorized to submit the request on their behalf.

 

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

CONNECTICUT PRIVACY RIGHTS. As a resident of Connecticut, we would like to inform you about your privacy rights, which are outlined below. While we respect and uphold these rights, it is important to note that they are not absolute, and there may be instances where we are unable to fulfill your request in accordance with applicable laws and regulations.

  • Right to know. You have the right to verify whether we are processing your personal data or not.

  •  Right to deletion. You have the right to request the deletion of your personal data under certain circumstances. If you make such a request, we will assess whether we are legally obligated to comply or if there are reasons that limit the scope of the deletion. If there are any reasons, we will provide you with an explanation in our response.

  • Right to access. The right to access and obtain a copy of personal data you previously provided to us, in a readily usable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible.

  • The right to opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or further profiling.

  • The right to ppt out of profiling. You have the right to choose not to have your personal data processed for profiling purposes that could lead to decisions with significant legal or similar effects on you. If you wish to exercise this right, you can opt out of such profiling activities.

  • The right to appeal our valid refusal of your initial request. If we reject your request relating to any of the rights outlined in the above sections, you have the option to request a reconsideration of our decision.

HOW TO EXERCISE YOUR PRIVACY RIGHTS. You can exercise any of your privacy rights specified above using any of the ways described in the Section “Contact information”. 

If we refuse to take action on your request, you can follow the appeal procedure within 45 days after receiving such refusal sending your appeal to this email  support@noderno.tech. adding in the subject of email “Appeal to answer on privacy request”. If your appeal is denied, you may contact the Attorney General to submit a complaint by visiting the Office of the Attorney General’s website to complete an Online Consumer Complaint Form.

 

 

UPDATES AND EDITIONS TO THE PRIVACY POLICY

This Privacy policy is updated regularly. Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

 

CONTACT INFORMATION

If you have any questions, please contact us:

Noderno Limited, Pavlou Nirvana, 4 ALPHA TOWER, 1st floor, Flat/Office 13, 3021, Limassol, Cyprus

support@noderno.tech .

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