Privacy Policy

We are dedicated to safeguarding the privacy of users who visit our Website and utilize our Internet Products. This Privacy Policy is an integral part of our Terms and Conditions and provides important information about how we collect your Personal Data on our Website or through our Internet Products. It also outlines your rights regarding the use of such data and explains the measures we take to protect it. We strongly encourage you to read this Privacy Policy thoroughly.

WHO ARE WE?

This Privacy Policy is applicable to our website that you are currently visiting (“Website”) and any offerings, products, features, tools, or resources provided through our Website or App (collectively referred to as our “Internet Products”).
The data controller responsible for your Personal Data collected through our Internet Products, as defined under Art. 4(7) GDPR, is ROWOON SERVICE LTD, with its registered office located at: 98R2, Belmont, Tortola, Freshwater Pond, XW2, British Virgin Islands
For the purpose of this Privacy Policy, “Journey” or “we” refers to ROWOON SERVICE LTD.

HOW IS DATA COLLECTED ABOUT ME AND HOW IS IT USED?

Which Personal Data We Collect
Personal Data refers to any information that can identify you or be used to identify or contact you (“Personal Data”).

The Personal Data we collect may include the following:
When you use our Website or subscribe to our Internet Products, we may collect Personal Data in the following ways:

We will only process the Personal Data you provide directly to us or that we automatically collect from you in accordance with the terms outlined in this Privacy Policy. We will not share or use your Personal Data in any other way, except as explicitly stated in this Privacy Policy, or if you give us permission to do so.

How we Collect and Use Your Personal Data

Revocation of Consent and Legitimate Interests:

Using Our Internet Products

When you choose to use our Internet Products, we begin to gather information, including your Personal Data. This data may be collected through interactions with our services, such as when you use our Website, subscribe to our products, or engage with features like the personal assistant (chat-bot).

Additionally, we may collect information directly provided by you through specific Internet Products, including but not limited to:
  1. Responses to surveys or questionnaires
  2. Feedback provided through interactions with the personal assistant or chat-bot

This collected data is used to improve our services, tailor your experience, and ensure the functionality of our offerings. The information provided through these interactions may include Personal Data, which we process in accordance with this Privacy Policy.

Purpose for processing

We use the data we collect to personalize our Internet Products, which may include customizing pricing and enhancing the efficiency of our solutions and recommendations that are tailored specifically for you. Additionally, we collect certain information automatically when you browse our Website or use our Internet Products. This aggregated information does not allow us to identify you personally, but we use it to administer the Website, analyze trends, monitor usage, and improve the general functionality and user experience of the Website. The legal basis for processing this Personal Data is our legitimate interests (Art. 6(1)(f) GDPR), which include customizing the content of our services to meet user preferences and continuously improving our Internet Products. Please note that providing Personal Data to us is not legally required. However, without it, we may not be able to offer you the full range of our Internet Products and services.

Contacting us

If you contact our customer service, we will use the information you provide to respond to your inquiries, manage your subscription, and deliver the services you have requested. We will communicate with you primarily via email, in accordance with the preferences you have set with us. This may include updates, service notifications, or responses to any questions or issues you raise.

Purpose for processing

The legal basis for processing your Personal Data in this context is **Article 6(1)(b) of the GDPR**, which allows processing when it is necessary for the performance of a contract. As a result, providing your Personal Data is contractually required for us to deliver our services, including customer service communications. Without this data, we will not be able to provide you with the necessary support or information related to our services.

COOKIES

Please read our Cookie Policy for additional information on how we use cookies.

HOW LONG AND WHERE WE STORE YOUR PERSONAL DATA

It looks like the data retention statement emphasizes that your personal data will only be kept for as long as necessary for the purpose of providing services, complying with laws, resolving disputes, and conducting business. It also suggests that you can contact them for specific retention periods related to your data. If you have any concerns or specific questions about how long your data will be retained, you can reach out to the company directly using the contact details they provide. Typically, companies will keep data for varying periods depending on the type of information and its purpose. If you need help with any part of this or have further questions, feel free to ask!

Your Personal Data is stored on the secure server at https://cloud.google.com/ and https://tilda.cc/.
The servers is located in the USA.

HOW WE DISCLOSE AND SHARE PERSONAL DATA

This section outlines the circumstances under which your personal data may be shared or disclosed to third parties:
  1. **Legal Requirement (Art. 6(1)(c) GDPR):** If required by law, your personal data may be shared with authorities or others.
  2. **Contractual Requirement (Art. 6(1)(b) GDPR):** Personal data may be shared to fulfill contractual obligations or services related to your agreement.
  3. **Data Processors (Art. 28 GDPR):** Personal data may be shared with third parties acting as data processors to help provide services on the company’s behalf.
  4. **Consent (Art. 6(1)(a) GDPR):** If you have given explicit consent for your data to be shared, it can be done so.

The key idea is that the sharing of your data is either required by law, needed to fulfill contractual obligations, done through trusted third-party processors, or allowed if you give your consent. If you have any concerns about how your data is shared, it’s always a good idea to review the company’s data sharing practices and reach out to them for clarification.

We use the following service providers:

We use their following services (Storage of your Personal Data, Analytical services):
https://cloud.google.com/
https://tilda.cc/

We contracted to the service providers via purchase of their services and via accepting their customers terms and conditions and privacy policies published on their websites:
https://policies.google.com/privacy?hl=en-US
https://tilda.cc/privacy/

We share your Personal Data with, as described above companies which are located outside of the European Economic Area. In particular, Tilda is located in the EU and Google is located in the USA.

This section explains how the company handles sharing your Personal Data with third parties outside the European Economic Area (EEA) and how it ensures that proper protections are in place:
  1. **Transfer to Third Parties Outside the EEA:**
    - Companies like **Tilda** (located in the EU) and **Google** (based in the USA) may process your data. - For such data transfers, **Google** uses **EU standard contractual clauses** to ensure compliance with GDPR and data protection standards. - **Amplitude** uses certifications under the **EU-US and Swiss-US Privacy Shield**.
  2. **Protection Mechanisms:**
    - The company ensures sufficient protection for your Personal Data by utilizing **EU standard contractual clauses** and certifications from relevant companies, as per the GDPR.
  3. **Data Sharing with Service Providers:**
    - Your Personal Data will be shared only with necessary third-party service providers, and this sharing will adhere to applicable data protection laws. - The sharing of data is regulated, and these companies are contractually bound to use the data only for the purposes described in the Privacy Policy. - The legal basis for sharing data is either **Art. 28(1) GDPR** (for data processors) or **legitimate interests** under **Art. 6(1)(f) GDPR**.
  4. **Legal Disclosures:**
    - In certain cases, such as **law enforcement or government requests**, the company may disclose your Personal Data to comply with legal obligations or protect their interests or the safety of individuals. - This disclosure is based on **Art. 6(1)(c)** and **Art. 6(1)(f) GDPR**.
  5. **Prior Consent for Data Sharing:** br - If required by applicable law, the company will seek your **prior consent** before sharing your Personal Data, and the legal basis for such sharing will be **Art. 6(1)(a) GDPR**.

This approach ensures that personal data is transferred securely and that you are informed about how your data is being used and protected across borders.

IS MY PERSONAL DATA USED FOR ANY OTHER PURPOSES?

We will only use your Personal Data for the purposes stated above or as otherwise disclosed when we collect the data from you, unless otherwise specified in this Privacy Policy. If your Personal Data is processed for any purposes beyond those mentioned in this Privacy Policy or for reasons other than those it was originally collected for, we will provide you with relevant information regarding those new purposes.

WHAT ARE MY RIGHTS?

You have the following rights:

You can exercise the rights mentioned above by reaching out to us using the contact details provided below.

Your consent and your right to withdraw your consent

You have the right to provide your consent, and you can withdraw it at any time. If you choose to withdraw your consent, it will not affect any processing that has already taken place prior to the withdrawal.

We will provide you with relevant information whenever we require additional consent for processing your personal data for purposes beyond what has been previously disclosed. If we need to process your personal data for a purpose you do not agree with (when required), or to meet our legal obligations, we will seek your consent before proceeding with any additional processing activities. Please note, you are not obligated to provide consent just because we ask for it.

You can also withdraw your consent at any time in the future by contacting us using the details provided below, if your personal data was processed based on your consent. However, withdrawing your consent will not affect any processing of your personal data that occurred prior to the withdrawal.

Objecting to data processing (your rights)

You can also request that we stop processing your personal data and remove you from our mailing list by contacting us using the details provided below. If your personal data was processed based on legitimate interest rather than consent, we will address your request accordingly. However, your request will not affect any processing of your personal data that occurred prior to the request.

If you request us to rectify, erase your personal data, or restrict the processing of your data (such as stopping processing or withdrawing your consent), we will inform you as soon as your request has been fulfilled.

Lodging a complaint (Your rights)

If your question is not resolved to your satisfaction or remains unresolved, you have the right to contact your local data protection authority. You can find the contact details of your local data protection authority below:
https://edpb.europa.eu/about-edpb/board/members_en

AUTOMATED INDIVIDUAL DECISION-MAKING

Decisions that have legal or similar effects on you are not made solely based on the automated processing of your Personal Data.

WHAT IF I HAVE ANY PRIVACY QUESTIONS? WHO DO I CONTACT?

If you have any questions about our Privacy Policy or believe that we are not complying with the terms of our Privacy Policy or applicable data protection laws, please contact our Data Protection Officer using the following information: [email protected]

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated occasionally. Any changes will be posted here. We recommend that you review this Privacy Policy regularly to stay informed about any updates.

Effective Date: August 8, 2022