FOR FinMarket Development OÜ

Privacy notice

This Privacy Notice for Calorie products and services («Privacy Notice») outlines FinMarket Development OÜ («We,» «Our,» «Us,» or «the Company») practices concerning information collected from Users (also referred to as «You») who access our website at https://calorie.live/ register or participate in our token sale. This Privacy Notice is a part of the Terms of Use, Privacy Policy, and other relevant agreements.

Introduction

The FinMarket Development OÜ takes steps to protect your privacy. In our capacity as Data Controllers, we have created this Privacy Notice to inform you about why we collect and how we process your Personal Data. By continuing to use our website, you acknowledge that you have read, understood, and accepted the information described in this Privacy Notice.

By using this Privacy Notice, we wish to comply and act following our obligation to inform the Users from whom we use data, as is required under the General Data Protection Regulation («GDPR»).

We will only use your Personal Data as set out in this Privacy Notice. By using our website and filling out and approving the registration form on the said website for the purpose of using Calorie for buying NFT gaming items («the NFTs Sale»), you agree to use your Personal Data in accordance with this Privacy Notice.

If you have any questions about FinMarket Development OÜ processing of your Personal Data or you wish to exercise your rights, you are always welcome to contact us:

E-mail: [email protected]
Address: Parnu mnt 388b, Tallinn, 11612, Estonia

The Personal Data Protection Act constitutes an integrated framework to ensure the confidentiality of the information and protect the privacy of individuals in Estonia. If you are dissatisfied, you have the right to lodge a complaint with the supervisory authority for data protection issues — Estonian Data Protection Inspectorate. We would, however, appreciate the chance to deal with your concerns before you approach the Estonian Data Protection Inspectorate, so please get in touch with us in the first instance.

1. Personal Data we collect: types. legal basis and purposes of collecting

1.1.

Personal Data means any information relating to an identified or identifiable natural person («data subject»); an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.2.

An outline of the Personal Data that we require, accept, collect, and process, when we collect it, how we use it, and why we use it, is listed underneath:

	Non-personal data	Individually identifiable data
Data types	This information is un-identified and non-identifiable data about Users, which may be made available or gathered via your use of the website, even if you do not participate or register at the Platform: aggregated usage information; and technical information transmitted by your device, including specific software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time, etc.); information on your activity on the Site (e.g., pages viewed, online browsing, clicks, actions, etc.).	This information is individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual. Such information includes: registration information: full name; email or physical address, and other information, as further described in our registration form; device information: geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), and other information which relates to your activity through the website; payment information: your name, billing address, identity number, financial information (e.g., your credit card number, bank account, etc.), and any other information required to complete your participation in the Token Sale.
Purpose	We collect non-personal data to enhance the functionality of our website.	We collect identifiable data, which is provided voluntarily by you to us, to provide our services and to comply with KYC and AML regulations in relation to the NFT Market.

Non-personal data

Individually identifiable data

Data types

This information is un-identified and non-identifiable data about Users, which may be made available or gathered via your use of the website, even if you do not participate or register at the Platform:

aggregated usage information; and
technical information transmitted by your device, including specific software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time, etc.);
information on your activity on the Site (e.g., pages viewed, online browsing, clicks, actions, etc.).

This information is individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual. Such information includes:

registration information: full name; email or physical address, and other information, as further described in our registration form;
device information: geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), and other information which relates to your activity through the website;
payment information: your name, billing address, identity number, financial information (e.g., your credit card number, bank account, etc.), and any other information required to complete your participation in the Token Sale.

Purpose

We collect non-personal data to enhance the functionality of our website.

We collect identifiable data, which is provided voluntarily by you to us, to provide our services and to comply with KYC and AML regulations in relation to the NFT Market.

1.3.

The Company will process your abovementioned Personal data exclusively on the legal basis listed below:

1.3.1. given consent to the processing;
1.3.2. for the performance of a contract;
1.3.3. for compliance with a legal obligation to which the Company may be or is subject (ed); and
1.3.4. for the purposes of the legitimate interests pursued by the Company except where such interests are overridden by the interests or fundamental rights and freedoms of the User which require protection of Personal Data.
1.4. Please pay attention that your Personal data may be collected and processed by third-party companies to maintain KYC and AML policies.

2. Data subject rights
2.1.

You may request to:
1. 2.1.1. receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal data, together with supplementary information;
2. 2.1.2. receive a copy of Personal Data you directly volunteer to us in a structured, commonly used, and machine-readable format;
3. 2.1.3. request rectification of your Personal Data that is in our control;
4. 2.1.4. request erasure of your Personal Data;
5. 2.1.5. object to the processing of Personal Data by us;
6. 2.1.6. request to restrict the processing of your Personal Data by us;
7. 2.1.7. lodge a complaint with a supervisory authority.
2.2.

However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If you wish to exercise any of the rights mentioned above or receive more information, please get in touch with us at [email protected];
3. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

3.1.

The Company only shares your Personal Data with third parties as necessary to provide services with due observance of the aforementioned legal basis. Nevertheless, the Company may provide your Personal Data to a third party, such as service providers, a supervisor, or any other public authority, to the extent that there is a legal obligation to do so.

3.2.

If the Company contracts a third party to process your Personal Data on behalf of the Company, a processing agreement is concluded under which the designated third party is also obliged to comply with the GDPR. Third parties contracted by the Company who offer services as a Controller are also responsible for compliance with the GDPR for processing your Personal data.
4. THIRD-PARTY WEBSITES AND SOCIAL MEDIA

4.1.

On the Website, «buttons» and/or hyperlinks are included to promote or share web pages on social (media) networks or third-party websites such as, but not limited to, Twitter, Instagram, Telegram, or YouTube. The Company does not supervise these networks and websites and is therefore not responsible for processing your Personal Data by and through the parties behind those networks and websites. The use of these media is, therefore, at your own risk. Before using these third-party services, the Company recommends you read the privacy statements of those third parties.
5. STORAGE AND RETENTION OF PERSONAL DATA

All the (personal) data you provide to us is stored on secured servers. Where we have given you a password that enables you to access certain parts of our website and/or your personal account, you are responsible for keeping your own password confidential.

5.1.

We will take all the necessary steps to ensure that your data is treated securely following this Privacy Notice.

5.2.

The Personal Data we collect from you will be transferred to and stored at a secure server administered by the Company or a service provider designated by the Company. Your Personal Data will be processed by staff who work for us and/or by staff who work for one of our suppliers.

5.3.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to and through our website and your personal account (if applicable). Therefore, any transmission is done by you at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to prevent any unauthorized access.

5.4.

We will keep your Personal Data no longer than is necessary following the legal basis and purposes stated above and/or to meet legal and regulatory requirements.
6. CHANGES TO THE PRIVACY POLICY

6.1.

We reserve the right to modify or amend this Privacy Notice at our discretion. Any changes can be viewed in the «Last Updated» field above, so please check the section regularly.

6.2.

If we make any material changes, we will post the new Privacy Notice on the website with a new effective date.

6.3.

If the User does not accept a new edition of the Privacy Notice, they must stop using our website.

FOR FinMarket Development OÜ

Privacy notice

Introduction

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3.1.

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