Company (hereinafter referred to as the "Company" - means relevant legal entity, specified in Client License) undertakes to protect privacy and positive experience of using our Website and Personal account (hereinafter – the "Personal account") and other products and options offered by the Company (collectively - the "Products"). This policy applies to the website, mobile apps and desktop clients in all countries all over the world.

Present policy regulates our practices of collecting and using personal data provided by you to our Company in electronic and paper format.

Terms used in this Policy

Personal data – any information about a particular person that can be used for identification purposes, as well as any information that can be used to identify you and may include, without limitation, your name, email address, mobile phone number, postal or other physical address, credit or debit card number, job title, and other personally identifying data.

Personal data party (Subject) - the person to whom the relevant personal data relates. Owner of the Personal account.

Personal data holder (Holder) – FIMOLVIA HOLDINGS LTD.

Actions (operations) of the holder with personal data - collection, storage, clarification, transfer, blocking, depersonalization and destruction of personal data.

Collection of personal data - the procedure for obtaining personal data by the Holder from the Subjects of this data.

Personal data processing - any action (operation) or set of actions (operations) performed with or without the use of automation tools with Personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal data.

Personal data processing - any action (operation) or set of actions (operations) performed with or without the use of automation tools with Personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal data.

Transfer of personal data - provision of personal data by the Holder to third parties in accordance with the law and International agreements.

Cross-border transfer of personal data - the transfer of personal data by the Holder of this data to holders who are under the jurisdiction of another state.

Clarification of personal data - prompt changes to Personal data in accordance with the procedures established by national legislation.

Blocking of personal data -temporary termination of the Transfer, Clarification and Destruction of Personal data.

Destruction of personal data - actions of the Holder of personal data to bring the latter into a state that does not allow to restore their content.

Depersonalization of personal data - the removal of the part of Personal data that allows you to identify them with a specific person.

A personal data base is an ordered array of Personal data, independent of the type of material data carrier and the means of processing it used.

Confidentiality of personal data is a set of rules that define restrictions on access, transfer and storage of Personal data.


If you live in the territory of the European Union (EU), United Kingdom, Liechtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data as defined below. These rights may include rights in accordance with the EU's General Data Protection Regulations (GDPR) if you are an EU, UK, Liechtenstein, Norway or Icelandic resident.

The Company acts as a controller of your Personal Data, the provision, collection and/or processing of which is carried out in accordance with present Privacy Policy, except in the cases below, in which otherwise expressly stated. If you have any questions about whether the above provisions apply to you, please contact us using the information provided in the "Contact Information" section below.

This policy can be periodically updated for reasons related to work practices or regulatory changes, and therefore we recommend you to read the Privacy Policy when you visit our website again.

Collection of your Personal Data

We collect the following categories of Personal Data when you use or otherwise interact with our Products:

• First name

• E-mail address

• Mobile phone

• Postal address or other actual address

• Credit or debit card details

• IP addresses and other passively collected data, discussed in details in the "Passive collection" section below

• We collect and/or process your Personal Data in connection with the following operations related to our Products:

• Registration of an account

• Use of certain Product's functions

• Preparation of report based on data collected when using our Products

• Service request and request of support of our Products and provision of the support

• Placement of transactions or orders

• Invoicing and collection of payments for our Products

• Personalization of displayed advertisement and its content


Processing Your Personal Data

We use your Personal Data only in accordance with our Privacy Policy. If you do not want us to use your Personal Data in this way, you can request a deactivation of the account by contacting us, as indicated in the "Contact Information" section.

We process your Personal Data only in case of a legitimate reason. The legal grounds for processing include consent, contractual necessity (i.e. the processing necessary to perform a contract made with you, such as your user agreement made with us that allows us to provide you Products) and our "legitimate interests" or legal interests of others (for example, our users), such as:

• Personalization, improvement or management of our Products and activities

• Better understanding of your needs and interests

• Fulfillment of your requests towards the Products

• Providing you with information and suggestions from our side or from third parties

• Compliance with our legal obligations, resolving disputes with users, ensuring performance of obligations

• Protection, investigation and prevention of fraudulent, dangerous, unauthorized or unlawful actions

• We process Personal Data for such purposes as:

• Processing of your orders and delivering of ordered Products

• Report preparation on the basis of data collected while using our Products

• Providing the latest product notifications, software updates, system extensions, special offers and other information

• Providing support and assistance for our Products

• Providing the ability to create personal profiles and view protected content

• Providing the possibility of contacting you and sending you shipping information and payment information

• Providing feedback and client support

• In case you agree to participate, conduction of questionnaires and surveys to provide better products and services to our clients and end users

• Personalization of marketing mailings and website content based on your preferences, for example, in response to your request for specific data on products and services that may be of interest

• Contacting the persons recommended by you and identifying you as a referral source in accordance with the "Referral" section below

• Fulfillment of contractual or legal obligations



If you choose our referral service to recommend our products to a friend, you confirm your friend's consent to receive present information from you. Without permission from your friend, we will not use his name and email address for any purpose.



The final decision to provide Personal Data to the Company belongs to you, but we draw your attention to the fact that without the provision of Personal Data certain functions, offers and services will not be available to you. You can register by giving your consent to receive emails or newsletters from us. If you want to refuse to receive newsletters, you can update your preferences by clicking on the "Unsubscribe" link in such emails, using the personal profile settings or by contacting us using the information given in the "Contact Information" section of present policy.


Rights of data Parties (Subjects)

You have certain rights with respect to your Personal Data set out below. Please note that under any circumstances, we may not be able to fully fulfill your requests, or we may ask you for more additional information in connection with your request, which may be Personal Data, for example, if you need to confirm your identity or the nature of the request. However, in such situations, we will certainly inform you of our decision. The additional Personal data obtained in this way, along with other.

Personal data, will not be stored for longer than the purpose for which it is collected, and will be subject to destruction when this purpose is achieved or when it is no longer necessary.

For additional inquiries, please contact us using the contact details in the "Contact Information" section of present policy.

Access: You can request additional information about your Personal data that we store. You can also request a copy of your Personal Data. Correction: If you think that any of your Personal Data at our disposal is inaccurate or incomplete, you may request that such data be corrected or supplemented. . You can also correct some of this data personally by logging into your service account. Contact us as soon as possible after detecting such inaccuracy or incompleteness.

Objection: You can contact us to inform that you object to the collection of your Personal Data for certain purposes.

Deletion: You can request the partial or complete removal of your Personal Data from our system.

Restriction processing: you can request a limit for further processing of your Personal Data.

Portability: You have a right to request a copy of your Personal Data in a machine-readable format. You can also request the transfer of data to another organization if you have the technical capacity to do so.

Cancellation of consent: If we process your Personal Data on the basis of your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. However, please note that in exercising of this right, you may in the future be required to provide express consent in each case to use or disclose certain Personal Data if such use or disclosure is necessary to use some or all of our Products.

The right to file a complaint: You have the right to file a complaint about the practices of the Company with respect to your Personal Data to the supervisory authority of your country or a member state of the EU.


Data storage

The period of storage of your Personal Data depends on the type of data and the purpose for which the data is processed.

The protection of personal data of a deceased person may be performed by other persons, including heirs, in accordance with the procedure provided for by national legislation on the protection of honor, dignity, business reputation, personal and family secrets.



We collect your location data when using our Products. We use this data for such purposes as optimization of your connection with our data center and offering personalization of using our Products (e.g., language settings). We share this data with parties such as our data center provider and our advertising partners. If you do not wish to provide us with your data in this manner, please send your refusal to email


Sharing your personal data

We do not sell or transfer your Personal Data to third parties for marketing purposes without primary obtaining permission from you.

We provide access to your Personal Data within the Company and its subsidiaries, as well as to third-party service providers for the processing or storage of data.

We also provide access to your Personal Data for business partners, service sellers and/or authorized independent agents and contractors for the provision of Products or on-demand transactions, including order processing, credit card transaction processing. We provide the above third parties with Personal Data for the implementation/use of the requested Product or transaction.

In some cases, we can buy or sell assets. For transactions of this type, user data is usually related to the transferred business assets. In addition, in the case of the acquisition of our Company or essentially all of our assets or the liquidation or bankruptcy of our Company, user data is one of the assets to be transferred or acquired by a third party. You confirm the possibility of such transmissions and that any buyer of our Company or our assets can continue to use your Personal Data in accordance with present policy.

In accordance with the requirements of the law, we can respond to subpoenas, court orders or similar court orders by disclosing your Personal Data and other related information when necessary. We can also use Personal Data and other related information to establish or enforce our legal rights or defend against claims.

We collect and provide access to Personal Data and any other additional data available to us to investigate, prevent or take action against illegal activities, alleged fraud, situations involving potential threats to the physical security of any person, breach of the Company's services or in any other cases arising from the requirements of the law.

When navigating the Company's website or selecting Products, you can get links to the content or functionality provided by a third-party vendor. Collection of data exclusively on behalf of the Company is carried out with reference to the Company's privacy policy, which regulates the use of your data. In respect of websites and services provided by third-party companies, there is a privacy policy of the owner of this website/service. Before using them, you should familiarize yourself with the privacy and security policies of such a third-party vendor.


Security of your Personal Account

The Company undertakes to protect the Personal Data you provide. We use a combination of industry-standard security technologies, procedures and organizational measures to protect your Personal Data from unauthorized access, use or disclosure. When transferring credit card data through the Internet, we protect them using Secure Sockets Layer (SSL) encryption technology.

We recommend you to take all precautions when protecting your Personal Account while you are accessing the Internet. For example, often change passwords, use combinations of letters and numbers when creating passwords and use a safe browser. If you have any questions about the security of your Personal Account, please contact the email address listed in Contacts.


Links to third-party websites and services

Our websites and services can provide links to websites and services of outside organizations that are beyond our control and are not covered by present policy. We recommend you to read the privacy policies published on these (and generally all) websites you visit or for the services you use.


Transfer and storage of Personal data

Our Products are hosted and managed in the Republic of Cyprus by FIMOLVIA HOLDINGS LTD and its service providers. We may transfer your Personal Data within the Republic of Cyprus, to any FIMOLVIA HOLDINGS LTD affiliates worldwide or to third Parties acting on our behalf for processing or storage purposes. By using any of our Products or by providing any Personal Data for any of the above purposes, you agree to the transfer and storage of your Personal Data provided by you or received through a third party in the Republic of Cyprus in the manner provided herein, including the posting of such Personal Data on servers in the countries of the European Union and the Russian Federation.

In some cases, our sharing of data with Company affiliates may be considered a "sale" of Your personal information, as defined in the California Consumer Privacy Act of 2018 ("CCPA"), and the opt-out we offer to California consumers in a special section below will prohibit our affiliates from collecting and using your information, except when necessary to confirm and provide cashback or provide services.

The Company is responsible for processing the received Personal Data in accordance with the privacy protection program and the subsequent transfer to a third party acting as its representative.

Under certain conditions, which are described in more details on the privacy protection program website, you may request mandatory arbitration if other dispute resolution procedures have failed.

In some cases, the Company transfers Personal Data from the EU in accordance with the standard contractual terms approved by the European Commission, a copy of which can be obtained at


Special notice for California Residents

This section applies only to California Residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), if you are a California resident, you have certain rights in relation to your personal information, subject to certain exceptions.


Right to Know and Access:

You have the right to know the personal information we collected, used, disclosed for a business purpose, and sold about you during the preceding 12 months, including the categories of sources from which we acquired your information and the categories of third parties to whom we disclosed your information for a business purpose.

For information we collected that is specific to you, you have the right to request in writing from us a copy of the:

  • Categories of information we have collected about you over the preceding 12 months
  • The specific pieces of personal information we have collected about you (note that we will not provide any sensitive personal information we may hold in response to this type of request)
  • The categories of sources from which we collected that information
  • For what purpose or use we collected that information about you
  • The categories of third parties with whom we shared your personal information, including


Right to Request Deletion:

You have the right to request that the Company delete any personal information we have collected from you or maintain about you, subject to certain exceptions. If you request that we delete your personal information, we will do so except to the extent we determine that we need the information for a business purpose and have a legal right to maintain it, in which case we will inform you of that legal exception.

Right to Opt-out of Sale of Your Personal Information:

To the extent that we receive monetary or other valuable consideration for sharing or providing access to information about you with our merchant partners, third parties or affiliates in order to provide you rewards and benefits and for our targeted marketing purposes, the CCPA may deem this a “sale” of your personal information. You have a right under California law to opt-out of our “sale” of your information in this way. If you would like to exercise your right to opt-out of having your personal information shared in this way, please contact us.

In addition, to the limited extent that you are a California resident and we target direct marketing to you or personalize the offers you see in your Merchant profile based on the profile data we collect from your behavior tracked through our apps, for the direct benefit of a particular merchant, this marketing or personalization may be considered as a "sale" of your personal information under the CCPA. In this case, the opt-out that we provide to California residents in this section will also cover this type of targeted marketing and personalization.

Please note that to the extent that you refuse to "sell" your information in this way, we will not be able to offer you some of our services that require such exchange.

Right to Non-Discrimination:

We will not discriminate against you for exercising any of your CCPA rights.

Unless otherwise permitted by the CCPA, we will not do any of the following because you request to know, access, or delete your information or opt out of its sale:

  • deny you goods or services
  • charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
  • provide you a different level or quality of goods or services


How to exercise your CCPA rights to Know, Access and Request Deletion:

To confirm your CCPA privacy rights, please log into your Personal account and contact Support service.

If we cannot verify your identity based on the information we have, we may request additional information from you, which we will only use to verify your identity, as well as for security or fraud prevention purposes.



Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. For any agent making a request on your behalf, we may require you to provide proof that you authorized this agent to submit a request on your behalf or that he or she has power of attorney in connection with your request to know, access or delete your personal information, and we may require you to independently verify your identity or log in to your account to provide the access code.

Please note that we are not required to respond more than twice per calendar year to requests to know/access your personal information.


Contact details


Registration number: HE382636

Address: 5 Spyrou Kyprianou, 2nd floor, office 202, 4001 Limassol, Mesa Geitonia, Cyprus

To: Support service



If you live in the Russian Federation, EU, UK, Liechtenstein, Norway or Iceland, you can also contact our specialist in the Personal Data Protection Support Service.


For US citizens/permanent residents:


EIN: 85-2230230

Address: 901 North Pitt Street, Suite 170, Alexandria, VA 22314, USA

To: Support service