Privacy Policy

Policy describes the information that Anarrono Ltd (“we” or “us”) gathers on or

through the Service, how we use and disclose such information, and the steps we

take to protect such information. By visiting the Site, or by purchasing or using any

Services, you consent to the privacy practices described in this Policy.

Definitions

“Client” means a customer of ours.

“Client Data“ means personal data, reports, addresses, and other files, folders or

documents in electronic form that a User of any of our Services stores within the

Service.

“Personal Data” means information that specifically identifies an individual or that is

linked to information that identifies a specific individual.

“Public Area” means the area of the Site that can be accessed both by Users and

Visitors, without needing to use a login ID and a password.

“Restricted Area” means the area of the Site that can be accessed only by Users, and

where access requires the use of a login ID and a password.

“User” means a Client or an employee, agent, or representative of a Client, who

primarily uses the restricted areas of the Site for the purpose of accessing the Service

in such capacity.

“Visitor” means an individual other than a User, who uses the public area, but has no

access to the restricted areas of the Site or Service.

The Information We Collect on the Service:

We collect different types of information from or through the Service:

User-provided Information. When you use the Service, as a User or as a Visitor, you

may provide, and we may collect Personal Data. Examples of Personal Data include

name, email address, mailing address, mobile phone number, and credit card or

other billing information. Personal Data also includes other information, such as

geographic area or preferences, when any such information is linked to information

that identifies a specific individual. You may provide us with Personal Data in various

ways on the Service. For example, when you register for an Account, use the Service,

post Client Data, interact with other users of the Service through communication or

messaging capabilities, or send us customer service -related requests.

“Automatically Collected" Information. When a User or Visitor uses the Service, we

may automatically record certain information from the User’s or Visitor’s device by

using various types of technology, including cookies, “clear gifs" or “web beacons.”

This “automatically collected" information may include IP address or other device

address or ID, web browser and/or device type, the web pages or sites visited just

before or just after using the Service, the pages or other content the User or Visitor

views or interacts with on the Service, and the dates and times of the visit, access, or

use of the Service. We also may use these technologies to collect information

regarding a Visitor or User’s interaction with email messages, such as whether the

Visitor or User opens, clicks on, or forwards a message. This information is gathered

from all Users and Visitors.

Integrated Services. You may be given the option to access or register for the Service

through the use of your user name and passwords for certain services provided by

third parties (each, an “Integrated Service”), such as through the use of your Google

account, or otherwise have the option to authorise an Integrated Service to provide

Personal Data or other information to us. By authorising us to connect with an

Integrated Service, you authorise us to access and store your name, email

address(es), date of birth, gender, current city, profile picture URL, and other

information that the Integrated Service makes available to us, and to use and disclose

it in accordance with this Policy. You should check your privacy settings on each

Integrated Service to understand what information that Integrated Service makes

available to us, and make changes as appropriate. Please review each Integrated

Service’s terms of use and privacy policies carefully before using their services and

connecting to our Service.

Information from Other Sources.

We may obtain information, including Personal Data, from third parties and sources

other than the Service, such as [our partners, advertisers, credit rating agencies, and

Integrated Services]. If we combine or associate information from other sources with

Personal Data that we collect through the Service, we will treat the combined

information as Personal Data in accordance with this Policy.

How We Use the Information We Collect

We use the information that we collect in a variety of ways in providing the Service

and operating our business, including the following:

Operations

We use the information – other than Client Data - to operate, maintain, enhance and

provide all features of the Service, to provide the services and information that you

request, to respond to comments and questions and to provide support to users of

the Service. We process Client Data solely in accordance with the directions provided

by the applicable Client or User.

Improvements

We use the information – other than Client Data - to understand and analyze the

usage trends and preferences of our Visitors and Users, to improve the Service, and

to develop new products, services, features, and functionality.

Communications

We may use a Visitor’s or User’s email address or other information – other than

Client Data – to contact that Visitor or User (i) for administrative purposes such as

customer service, to address intellectual property infringement, right of privacy

violations or other issues related to the Client Data or Personal Data posted on the

Service or (ii) with updates on promotions and events, relating to services offered by

us and by third parties we work with. You have the ability to opt-out of receiving any

promotional communications as described below under “Your Choices.”

Cookies and Tracking Technologies

“Cookies” are text-only pieces of information that a website transfers to an

individual’s hard drive or other website-browsing equipment for record-keeping

purposes. Cookies allow the Site to remember important information that will make

your use of the Site more convenient.

To Whom We Disclose Information

Except as described in this Policy, we will not intentionally disclose the Personal Data

or Client Data that we collect or store on the Service to third parties without the

consent of the applicable Visitor, User or Client. We may disclose information to third

parties if you consent to us doing so, as well as in the following circumstances:

Unrestricted Information

Any information that you voluntarily choose to include in a Public Area of the Service,

such as on a chat forum or blog will be available to any Visitor or User who has

access to that content.

Service Providers

We work with third party service providers who provide website, application

development, hosting, maintenance, and other services for us. These third parties

may have access to, or process Personal Data or Client Data as part of providing

those services for us. We limit the information provided to these service providers to

that which is reasonably necessary for them to perform their functions, and our

contracts with them require them to maintain the confidentiality of such information.

Non Personally Identifiable Information

We may make certain automatically-collected, aggregated, or otherwise

non-personally-identifiable information available to third parties for various

purposes, including (i) compliance with various reporting obligations; (ii) for business

or marketing purposes; or (iii) to assist such parties in understanding our Clients’,

Users’ and Visitors’ interests, habits, and usage patterns for certain programs,

content, services, and/or functionality available through the Service.

Law Enforcement, Legal Process and Compliance

We may disclose Personal Data or other information if required to do so by law or in

the good-faith belief that such action is necessary to comply with applicable laws, in

response to a court order, judicial or other government subpoena or warrant, or to

otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose Personal Data or other information that we

believe, in good faith, is appropriate or necessary to (i) take precautions against

liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or

activity, (iii) investigate and defend ourselves against any third-party claims or

allegations, (iv) protect the security or integrity of the Service and any facilities or

equipment used to make the Service available, or (v) protect our property or other

legal rights, enforce our contracts, or protect the rights, property, or safety of others.

Transfer of Ownership

Information about Users and Visitors, including Personal Data, may be disclosed and

otherwise transferred to an acquirer, successor or assignee as part of any merger,

acquisition, debt financing, sale of assets, or similar transaction, as well as in the

event of an insolvency, bankruptcy, or receivership in which information is

transferred to one or more third parties as one of our business assets and only if the

recipient of the User or Visitor Data commits to a Privacy Policy that has terms

substantially consistent with this Privacy Policy.

Client Data may be physically or electronically transferred to an acquirer, or successor

or assignee as part of any merger, acquisition, debt financing, sale of assets, or

similar transaction, as well as in the event of an insolvency, bankruptcy, or

receivership in which information is transferred to one or more third parties as one

of our business assets, for the sole purpose of continuing the operation of the

Service, and only if the recipient of the Client Data commits to a Privacy Policy that

has terms substantially consistent with this Privacy Policy.

Your Options

Access, Correction, Deletion

We respect your privacy rights and provide you with reasonable access to the

Personal Data that you may have provided through your use of the Services. If you

wish to access or amend any other Personal Data we hold about you, or to request

that we delete any information about you that we have obtained from an Integrated

Service, you may contact us as set forth in the “How to Contact Us” section. At your

request, we will have any reference to you deleted or blocked in our database.

You may update, correct, or delete your Account and or Account information and

preferences at any time by contacting us at hello@anarrono.com.

Please note that while any changes you make will be reflected in active user

databases instantly or within a reasonable period of time, we may retain all

information you submit for backups, archiving, prevention of fraud and abuse,

analytics, satisfaction of legal obligations, or where we otherwise reasonably believe

that we have a legitimate reason to do so.

You may decline to share certain Personal Data with us, in which case we may not be

able to provide to you some of the features and functionality of the Service.

At any time, you may object to the processing of your Personal Data, on legitimate

grounds, except if otherwise permitted by applicable law.

This provision does not apply to Personal Data that is part of Client Data. In this case,

the management of the Client Data is subject to the Client’s own Privacy Policy, and

any request for access, correction or deletion should be made to the Client

responsible for the uploading and storage of such data into the Service.

Navigation Information

You may opt out from the collection of navigation information about your visit to the

Site by Google Analytics by using the Google Analytics Opt-out feature.

Opting out from Commercial Communications

If you receive commercial emails from us, you may unsubscribe at any time by

following the instructions contained within the email or by sending an email to the

address provided in the “How to Contact Us” section.

Users are able to view and modify settings relating to the nature and frequency of

promotional communications that they receive from us by [contacting us using the

unsubscribe option link contained within the email].

Please be aware that if you opt-out of receiving commercial emails from us or

otherwise modify the nature or frequency of promotional communications you

receive from us, it may take up to ten (10) business days for us to process your

request. Additionally, even after you opt-out from receiving commercial messages

from us, you will continue to receive administrative messages from us regarding the

Service.

If a Client requests us to remove any data, we will respond to its request within

[fifteen (15) days. We will delete, amend or block access to any Personal Data that

we are storing only if we receive a written request to do so from the Client who is

responsible for such Personal Data, unless we have a legal right to retain such

Personal Data. We reserve the right to retain a copy of such data for archiving

purposes, or to defend our rights in litigation. Any such request regarding Client Data

should be addressed as indicated in the “How to Contact Us” section, and include

sufficient information for us to identify the Client and the information to delete or

amend.

Third-Party Services

The Services we provide may contain features or links to websites and services

provided by third parties. Any information you provide on third-party sites or

services is provided directly to the operators of such services and is subject to those

operators’ policies, if any, governing privacy, and security, even if accessed through

the Service. We are not responsible for the content or privacy and security practices

and policies of third-party sites or services to which links or access are provided

through the Service. We encourage you to learn about third parties’ privacy and

security policies before providing them with information.

Your Privacy Rights

We will not share any Personal Data with third-parties for their direct marketing

purposes to the extent prohibited by law. If our practices change, we will do so in

accordance with applicable laws and will notify you in advance.

Interest Based Advertising

Interest based advertising is the collection of data from different sources and across

different platforms in order to predict an individual’s preferences or interest and to

deliver to that individual, or his/her computer, smart phone or tablet, advertising

based on his/her assumed preference or interest inferred from the collection of data

pertaining to that individual or others who may have a similar profile or similar

interests.

We may work with a variety of third parties to attempt to understand the profiles of

the individuals who are most likely to be interested in our Services so that we can

send them promotional emails or serve our advertisements to them on the websites

and mobile apps of other entities.

These third parties include: (a) advertising networks, which collect information about

a person’s interests when that person views or interacts with one of their

advertisements; (b) attribution partners, which measure the effectiveness of certain

advertisements; and (c) business partners which collect information when a person

views or interacts with one of their advertisements.

In collaboration with these third parties, we may collect information about our

customers, prospects, and other individuals over time and across different platforms

when they use these platforms or interact with them. Individuals may submit

information directly on our Sites or on platforms run by third parties, or by

interacting with us, our advertisements, or emails they receive from us or from third

parties. We may use special tools that are commonly used for this purpose, such as

cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar

technologies. We may have access to databases of information collected by our

business partners.

The information we or third party collect enables us to learn what purchases the

person made, what ads or content the person sees, on which ads or links the person

clicks, and other actions that the person takes on our Sites, or in response to our

emails, or when visiting or using third parties’ platforms.

We, or the third parties with which we work, use the information collected as

described above to understand the various activities and behaviors of our customers,

Site visitors and others. We, or these third parties, do this for many reasons,

including: to recognise new or past visitors to our Sites; to present more personalised

content; to provide more useful and relevant ads - for example, if we know what ads

you are shown we can try not to show you the same ones repeatedly; to identify

visitors across devices, third party websites and sites, or to display or send

personalized or targeted ads and other custom content that is more focused on a

person’s perceived interest in products or services similar to those that we offer.

Our interest-based ads may be served to you in emails or on third-party platforms.

We may serve these ads about our products or services or send commercial

communications directly ourselves or through these third parties.

Third Party Cookies

We are legally required to disclose whether other third parties may collect personally

identifiable information about an individual's online activities from our Site or

Service. Please see our Cookie Policy for more information.

The information gathered by these third parties is used to make predictions about

your interests or preferences so that they can display advertisements or promotional

material on this Site and on other sites across the Internet tailored to your apparent

interests.

The business partners and advertising networks that serve interest-based

advertisements on the Services have limited access to a small amount of information

about your profile and your device, which is necessary to serve you advertisements

that are tailored to your apparent interests. It is possible that they may reuse this

small amount of information on other sites or services.

We do not share with these third parties any information that would readily identify

you (such as email address); however, these third parties may have access to

information about your device (such as IP or MAC address). We do not have access

to, or control over, the technologies that these third parties may use to collect

information about your interests, and the information practices of these third parties

are not covered by this Privacy Policy. Other than as discussed in this document, we

have no control over these third parties.

Minors’ Privacy

Protecting the privacy of minors is especially important. Our Service is not directed to minors under

the age of 16, and we do not knowingly collect Personal Data from persons under the age of 16

without obtaining parental consent. If you are under 18 years of age, then please do not use or access

the Service at any time or in any manner. If we learn that Personal Data has been collected on the

Service from persons under 16 years of age and without verifiable parental consent, then we will take

the appropriate steps to delete this information. If you are a parent or guardian and discover that

your child under 18 years of age has obtained an Account on the Service, then you may alert us at

hello@anarrono.com and request that we delete that child’s Personal Data from our systems.

The Service is not intended to be used by minors, and is not intended to be used to post content to

share publicly or with friends. To the extent that a minor has posted such content on the Service, the

minor has the right to have this content deleted or removed using the deletion or removal options

detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as

indicated in the “How to Contact Us” section. Please be aware that, although we offer this deletion

capability, the removal of content may not ensure complete or comprehensive removal of

that content or information.

Data Security

We follow generally accepted industry standards to protect the information

submitted to us, both during transmission and once we receive it. We use ISO

certified cloud services and applications. We maintain appropriate administrative,

technical and physical safeguards to protect Personal Data against accidental or

unlawful destruction, accidental loss, unauthorised alteration, unauthorised

disclosure or access, misuse, and any other unlawful form of processing of the

Personal Data in our possession. This includes, for example, firewalls, password

protection and other access and authentication controls. We use TLS technology to

encrypt data during transmission through public internet and ISO certified cloud

services and applications, [and we also employ application-layer security features to

further anonymise Personal Data.]

However, no method of transmission over the Internet, or method of electronic

storage, is 100% secure. We cannot ensure or warrant the security of any information

you transmit to us or store on the Service, and you do so at your own risk. We also

cannot guarantee that such information may not be accessed, disclosed, altered, or

destroyed by breach of any of our physical, technical, or managerial safeguards. If

you believe your Personal Data has been compromised, please contact us as set forth

in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you of the occurrence of the

breach in accordance with applicable law.

Data Retention

We only retain the Personal Data collected from a User for as long as the User’s

account is active or otherwise for a limited period of time as long as we need it to

fulfill the purposes for which we have initially collected it, unless otherwise required

by law. We will only retain and use information as necessary to comply with our legal

obligations, resolve disputes, and enforce our agreements.

Privacy Settings

Although we may allow you to adjust your privacy settings to limit access to certain

Personal Data, please be aware that no security measures are perfect or

impenetrable. We are not responsible for circumvention of any privacy settings or

security measures on the Service. Additionally, we cannot control the actions of

other users with whom you may choose to share your information. Further, even

after information posted on the Service is removed, caching and archiving services

may have saved that information, and other users or third parties may have copied or

stored the information available on the Service. We cannot and do not guarantee

that information you post on or transmit to the Service will not be viewed by

unauthorised persons.

Data Transfer

International transfers

The Company will not transfer personal information outside the European Economic

Area (EEA), which comprises the countries in the European Union and

Iceland, Liechtenstein and Norway.

Training

The Company will ensure that staff are adequately trained regarding their data

protection responsibilities. Individuals whose roles require regular access to personal

information, or who are responsible for implementing this policy or responding to

subject access requests under this policy, will receive additional training to help them

understand their duties and how to comply with them.

.

Foreign Visitors

The Service is hosted in the UK. If you choose to use the Service from regions of the

world with laws governing data collection and use that may differ from EU and UK

law, then please note that you are transferring your Client Data and Personal Data

outside of those regions to the UK for storage and processing. Also, we may transfer

your data to other countries or regions in connection with storage and processing of

data, fulfilling your requests, and operating the Service. By providing any

information, including Client Data and Personal Data, on or to the Service, you

consent to such transfer, storage, and processing.

Data Controller and Data Processor

We do not own, control or direct the use of any of the Client Data stored or

processed by a Client or User via the Service. Only the Client or Users are entitled to

access, retrieve and direct the use of such Client Data. We are largely unaware of

what Client Data is actually being stored or made available by a Client or User to the

Service and do not directly access such Client Data except as authorised by the

Client, or as necessary to provide Services to the Client and its Users.

Because we do not collect or determine the use of any Personal Data contained in

the Client Data and because it does not determine the purposes for which such

Personal Data is collected, the means of collecting such Personal Data, or the uses of

such Personal Data, we are not acting in the capacity of data controller in terms of

the European Union’s Directive 95/46/EC on data privacy or the European Data

Protection Regulation (“GDPR”) and do not have the associated responsibilities under

GDPR.

We should be considered only as a processor on behalf of our Clients and Users as to

any Client Data containing Personal Data that is subject to the requirements of GDPR.

Except as provided in this Privacy Policy, We do not independently cause Client Data

containing Personal Data stored in connection with the Services to be transferred or

otherwise made available to third parties, except to third party subcontractors who

may process such data on our behalf in connection with our provision of Services to

Clients. Such actions are performed or authorised only by the applicable Client or

User.

The Client or the User is the data controller under the Directive for any Client Data

containing Personal Data, meaning that such party controls the manner such

Personal Data is collected and used as well as the determination of the purposes and

means of the processing of such Personal Data.

We are not responsible for the content of the Personal Data contained in the Client

Data or other information stored on our servers (or our subcontractors’ servers) at

the discretion of the Client or User nor are we responsible for the manner in which

the Client or User collects, handles disclosure, distributes or otherwise processes

such information.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which

we may update from time to time. If we modify the Policy, we will make it available

through the Service, and indicate the date of the latest revision, and will comply with

applicable law. Your continued use of the Service after the revised Policy has become

effective indicates that you have read, understood and agreed to the current version

of the Policy.

How to Contact Us

Please contact us with any questions or comments about this Policy, your Personal

Data, our use and disclosure practices, or your consent choices by email at

hello@anarrono.comChanges to this privacy policy

This privacy policy was first published on 13/09/2023.