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EDEN STAR GDPR - Regulation (EU) 2016/679

IT'S PROHIBITED ANY USE, PARTIAL OR WHOLE REPRODUCTION OF OUR GDPR LEGAL REGULATION. © 2018-2024 All Rights Reserved

This Privacy Policy describes the policies and procedures of Elite Art Projects a division of Eden STAR Communication LLC a US corporation headquartered in Manhattan - New York, USA, on the collection, use, and disclosure of your information.

For the sake of brevity, 'EDEN STAR Communication LLC' will be referred to as 'EDEN STAR' in this document.

This Privacy Policy does not apply to information our customers may process when using our services.

Privacy and security are of utmost importance to EDEN STAR and we strive to ensure that our technical and organizational measures in place respect your data protection rights.

EDEN STAR GDPR is subject to change on time to time basis. We will notify our clients and wire news subscribers about any change we will make via email. Last update: 1 January 2024.

This privacy policy applies to the processing and management of personal data for users in countries where additional applicant protections are required by the respective privacy authorities.

EU Resident | California Resident | Virginia Resident | Brazilian Resident

COLLECTION OF PERSONAL DATA

"Personal data" refers to any information relating to an identifiable individual or his or her identity.

Personal data is collected in the Elite Art Projects portal by EDEN STAR Communication LLC, a US corporation headquartered in Manhattan - New York, USA.

The personally identifiable information that EDEN STAR may collect from you when registering for an account includes:

Your registrant information will be needed for the following purposes:

Much of the data collected is aggregated or statistical data about how individuals use our Services and is not linked to any personal data, but to the extent it is itself personal data or is linked or linkable to personal data, we treat it accordingly.

EDEN STAR will NOT send you any unsolicited information, including emails, except as mentioned hereby.

New customers will receive a welcome email containing information about how to access the profile account that users can access:

EDEN STAR may also send internal notifications related to Elite Art Projects broadcasts, special coupons, and offers we can reserve for you on a time-to-time basis concerning EDEN STAR marketing, communication, advertising, and TV broadcast services.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

EDEN STAR will keep your personally identifiable information private and will NOT share it with any unauthorized third parties.

When you use our services, we may collect information about your engagement with and utilization of our services, such as processor and memory usage, storage capacity, navigation of our services, system-level resource metrics, and type of navigation instrument (desktop, smartphone, laptop, notebook, etc.). We use this data to operate the services, maintain and improve the performance and utilization of the services, develop new features, protect the security and safety of our services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business.

DETAILED INFORMATION FOR PROCESSING PERSONAL DATA

Contacting Wire and Flash News Subscribers and clients. Click below to have a look at each single personal data process.

LEGAL BASIS FOR PROCESSING OF PERSONAL DATA

Methods of processing

EDEN STAR takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to EDEN STAR, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by EDEN STAR. The updated list of these parties may be requested from EDEN STAR at any time. Legal basis of processing EDEN STAR may process Personal Data relating to Users if one of the following applies: Users have given their consent for one or more specific purposes. Note: Under some legislations, EDEN STAR may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases.

This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; processing is necessary for compliance with a legal obligation to which EDEN STAR is subject; processing is related to a task that is carried out in the public interest or the exercise of official authority vested in PERSEO; processing is necessary for the legitimate interests pursued by EDEN STAR or by a third party. In any case, EDEN STAR will gladly help to clarify the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

EDEN STAR of this Application takes appropriate security measures to safeguard against unauthorized access, disclosure, modification, or destruction of Personal Data. Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to PERSEO, the Data may be accessible to certain persons in charge of this Application, such as those involved in administration, sales, marketing, legal, and system administration. Additionally, external parties may have access to the Data if appointed by EDEN STAR as Data Processors, such as third-party technical service providers, mail carriers, hosting providers, IT companies, and communications agencies. EDEN STAR can provide an updated list of these parties upon request.

EDEN STAR may process Personal Data relating to Users if one of the following conditions is met:

EDEN STAR is available to clarify the specific legal basis that applies to the processing of Personal Data and to confirm whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

LOCATION OF DATA PROCESSING

The Data is processed at the operating offices of EDEN STAR and other locations where the parties involved in the processing are situated.

Depending on the User's location, data transfers may involve the transfer of the User's Data to a country other than their own. Users can find out more about the place of processing of such transferred Data by checking the section that contains details about the processing of Personal Data.

Users have the right to be informed about the legal basis of Data transfers to a country outside the European Union or any international organization governed by public international law or established by two or more countries, such as the UN, and about the security measures taken by EDEN STAR to safeguard their Data.
If such a transfer takes place, Users can obtain further information by referring to the relevant sections of this document or by contacting EDEN STAR using the information provided in the contact section.

RETENTION TIME OF YOUR DATA

Personal Data will be stored and processed only for the time necessary to achieve the purpose for which it was collected. In the case of Personal Data collected for the performance of a contract between EDEN STAR and the User, it will be retained until the contract has been fully performed. If Personal Data is collected for EDEN STAR’s legitimate interests, it will be retained for as long as necessary to fulfill such purposes. If the User has given consent for the processing of Personal Data, it may be retained for a longer period, as long as the consent is not withdrawn. EDEN STAR may also be required to retain Personal Data for a longer period to comply with legal obligations or orders from authorities. Once the retention period expires, Personal Data will be deleted. Therefore, the User cannot enforce their right to access, right to erasure, right to rectification, and right to data portability after the expiration of the retention period.

The purpose of processing

The purpose of collecting User Data is multifaceted and includes facilitating the provision of services by EDEN STAR, adhering to legal obligations, responding to enforcement requests, safeguarding the interests and rights of EDEN STAR, its Users, and third parties, and identifying any malicious or fraudulent activities. Additionally, such data may be utilized for purposes such as Analytics, Tag Management, SPAM protection, and Interaction with external social networks and platforms. A more detailed description of the Personal Data processed for each purpose is available in the section titled "Detailed information on the processing of Personal Data."

The rights of Users

Users are afforded certain rights concerning their Personal Data processed by EDEN STAR. These include:

Details about the right to object to processing

Users have the right to object to the processing of their Personal Data if it is carried out for the public interest, the exercise of official authority vested in EDEN STAR, or for the legitimate interests pursued by EDEN STAR. Users may object to such processing by providing reasons related to their particular situation to justify their objection.

It should be noted that where Personal Data is processed for direct marketing purposes, Users may object to such processing at any time without providing any justification. To determine whether EDEN STAR is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

To exercise their rights, Users may contact EDEN STAR using the contact details provided in this document. These requests can be made free of charge and will be addressed by EDEN STAR as early as possible and always within one month.

Additional information regarding Data collection and processing

Legal action

EDEN STAR may use the User's Personal Data for legal purposes, including in court or during pre-litigation phases arising from the improper use of this Application or related Services.

The User acknowledges that EDEN STAR may be required to disclose Personal Data upon request of public authorities.

Additional information on Personal Data

In addition to the information contained in this privacy policy, the User may request further information about the processing of Personal Data related to particular Services or aspects of this Application.

System logs and maintenance

For operational and maintenance purposes, this Application and the third-party services it uses may collect files that record interactions with this Application (System logs) or use other Personal Data (such as the IP Address).

Information not contained in this policy

The User may request additional information regarding the collection or processing of Personal Data from EDEN STAR at any time. Please see the contact information provided at the beginning of this document.

Handling of “Do Not Track” requests

This Application does not support “Do Not Track” requests.

To determine whether any third-party services this Application uses honor “Do Not Track” requests, please refer to their respective privacy policies.

Changes to this privacy policy

As EDEN STAR of this Application, we reserve the right to modify or amend this privacy policy at our discretion, at any time. We may notify Users of any updates by posting the new privacy policy on this page, and/or by other means as permitted by applicable law. We encourage Users to check this page frequently to stay up-to-date with any changes.

If any changes to this privacy policy require renewed consent from Users, we will collect new consent where required.

ACCESS TO YOUR DATA

You may access and update your Personal Information at any time by accessing your profile online. The access is reserved and protected with SSL-encrypted data protection. To manage your data and profile you will need to use the USER ID and password that you created when you open your profile.

In the event you may have lost your credential access, you can use our recovery tools that will send you automatically your USER ID and password to your registered email.

SECURITY OF YOUR DATA

EDEN STAR is committed to protecting the security of customers' collected personal information. To do so, we use technical security measures to prevent the loss, misuse, alteration, or unauthorized disclosure of information under our control. We use security measures including but not limited to physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, please keep in mind that the Internet cannot be guaranteed to be 100% secure.

If EDEN STAR learns of a security system breach, we may attempt to notify you and send you any available protective information to the email address that you have provided to us.

SHARING YOUR DATA WITH THIRD PARTIES

We may share the information we collect in various ways, including the following:

Service Providers
We may share information with third-party service providers that provide services on our behalf, such as helping to provide our services and to provide you with information relevant to you such as product announcements, service upgrades, special offers, or other information.

As Required By Law and Similar Disclosures
We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

THIRD-PARTY SERVICES

You may access other third-party services through our services, for example by clicking on links to those third-party services from within our services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.

PRIVACY OF YOUR PAYMENT DETAILS

We use third-party payment processing companies who collect and store financial information, such as your payment method (valid credit card number, type, expiration date, or other financial information), and their use and storage of that information are governed by the payment processor's applicable terms of service and privacy policy. Collected billing information is used for processing payments and fraud detection.

We do not store your financial account information on our systems; however, we have access to, and may retain, only subscriber information through our third-party payment processor.

All PayPal transactions are subject to the PayPal Privacy Policy. All Stripe transactions are subject to the Stripe Privacy Policy.

PRIVACY OF YOUR ACCOUNT

We consider your registration data and the content of all your messages private and confidential. The header of the messages that you send will contain your name, e-mail address, and Internet Protocol (IP) address. We will not intentionally monitor or disclose any of your e-mail content or registration data unless we are required to do so:

Since your password is essential for protecting your privacy, we encourage you to NOT share it with anyone and change it frequently. Additionally, you agree to respect the privacy and confidentiality of others.

AGE RESTRICTIONS

We offer services only to people who are 18 years old or older. Our services are not targeted to, intended to be consumed by, or designed to entice individuals under the age of 18. If we learn that we have collected the personal information of a child under the age of 18, we will take steps to delete that information as soon as possible.

If you know of or have reason to believe that anyone under the age of 18 has provided us with any personal data, please contact us.

LOG FILES

We use IP addresses to analyze trends, administer our site and servers, track access, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. Personal information about a customer may be included in the log files due to the normal functions of IP addresses and Web browsing.

COOKIES

We use different cookies on our website to make it as useful to you as possible. Cookies are small text files that we put on your computer or mobile device to tell us what you want to use on our site but they do not tell us who you are.

Here you can learn more about cookies and how to control or delete them.

Here are the cookies that we use on our site:

Essential or required cookies
We use a cookie to remember your login for you and what you’ve put in the shop cart. Also, we set a cookie to help you choose a preferred font size for using the site. These cookies we consider essential for the operation of our website.

External web services
We use an external live chat service (using cookies to remember your session name) to deliver real-time support to you should you want to.

Analytics
We use Google Analytics and Facebook cookies to monitor visitor activity on our website. No personally identifying data is included in this type of reporting. We do not share information about this analysis with any third parties.

Visitors can opt out of Google's advertising tracking cookie or install a browser plugin to opt out of all Google Analytics tracking software. More information about Facebook's analytics cookie is available here.

Targeting cookies or advertising cookie
Targeting cookies or advertising cookies are used to deliver adverts that are more relevant to you and your interests or to limit the number of times you see the same advert on a website. These types of cookies are also used to help measure the effectiveness of an advertising campaign. These cookies may be used to remember what you have looked at on a website.

We assume you are happy with the usage of cookies on this website. If you are not happy, then you should either not use this site, delete the cookies (you can check out how to do that according to your browser here), or browse the site using your browser’s anonymous usage setting (named “Incognito” in Chrome, “InPrivate” for Internet Explorer, "Private Browsing" in Firefox and Safari, etc.).

We currently do not alter our practices when we receive a "Do Not Track" signal from a visitor's browser.

Please remember that if you choose to delete the cookies or use the browser anonymously, you may find that certain sections of this website do not work properly.

You can review here our full cookie policy for complete information and acknowledgment.

YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have the following data protection rights:

Managing Your Information
You may access and update some of your information through the "Change Contact Details" section in your profile account. If you have chosen to connect your account to a third-party application like Facebook, Google, or Twitter, you can change your settings and remove permission for the app from the "Linked Social Accounts" section always in your Profile. You are responsible for keeping your personal information up to date.

Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct any inaccurate or incomplete personal information concerning you if you cannot update it yourself from within your account.

Data Access and Portability
In some jurisdictions, the applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

Opt-out of marketing communications
You have the right to opt out of the marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.

Modify marketing e-channel communications
EDEN STAR has never sent to its clients, followers, and subscribers any communication that is not really of interest. You have the right to modify which marketing e-channel communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "modify subscription" links that you will find always on the button of the marketing emails we send you.

Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the contracted services to you, you can request that we erase your personal information and close your account. Please note that if you request the erasure of your personal information:

We may retain some of your personal information to detect and prevent fraud and enhance safety. For example, if we suspend an account for security reasons, we may retain certain information from that account to prevent that customer from opening a new account in the future.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, and auditing purposes.

Because we maintain our platform to protect it from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited time.

In cases where fraudulent or otherwise illegal activity has been deemed to have occurred as determined by law enforcement or management, the information may remain in our database indefinitely to help facilitate the prevention of repeated abuse in the future from the offending party.

Withdrawing Consent and Restriction of Processing
If you have provided your consent to the processing of your personal information, you may withdraw it at any time by sending us a communication specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit how we use your personal information, in particular, where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and pending the verification whether the PERSEO's legitimate grounds override your own.

Objection to Processing
In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise, or defense of legal claims.

By default, customers receive any system updates, such as newsletters, invoices, and service email notifications. Customers cannot opt out of possibly receiving important system notifications since the latter are deemed necessary for the performance of our contractual obligations to you.

Lodging Complaints
If you want to make a complaint about the way we are processing your data, you can contact us using the contact details below.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights under applicable data protection laws.

INTERNATIONAL TRANSFERS OF INFORMATION WE COLLECT
We collect information globally and primarily store that information in the USA, UK, and Europe. We transfer, process, and store your information outside of your country of residence. Whenever we transfer your information, we take steps to protect it.

To facilitate our global operations, we transfer information to the United Kingdom and allow access to that information from countries where we and associated companies operate for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws, certainly not equivalent to the laws of many of the countries where our customers and users are based. When we share information about you, we make use of standard contractual data protection clauses, which have been approved by the European Commission.

A copy of your data will also be stored in the data center we have our servers that are always located in Europe. This is done so that EDEN STAR can deliver the contracted service in the location specified by the customer.

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
EDEN STAR cooperates with government and law enforcement officials to enforce and comply with the law. We will disclose any information about Users upon valid request by government or law officials as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including without limitation subpoenas), to protect your property and rights, or the property and rights of a third party, to protect the safety of the public or any person, or stop activity we consider illegal or unethical.

CHANGES TO PRIVACY POLICY
Any changes to our Privacy Policy will be placed here and will supersede this version of our Policy. We will take reasonable steps to draw your attention to any changes in our Policy. However, to be on the safe side, we suggest that you read this document each time you use the website to ensure that it still meets your approval.

Information for Californian consumers

This section supplements and integrates with the information contained in the privacy policy and is provided by the business operating this Application, and its parent, subsidiaries, and affiliates (collectively referred to as “we,” “us,” or “our”).

The provisions contained in this section apply to all users who are residents of California, United States of America, under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA) and other relevant regulations. For California residents, this section supersedes any conflicting provisions contained in the privacy policy.

In this section, the term “personal information” has the meaning given to it under the CCPA.

Notice at Collection Categories of Personal Information Collected, Used, Sold, or Disclosed

In this section, we provide a summary of the categories of personal information that we collect, use, sell, or disclose and the purposes for which we do so. Please refer to the section titled “Detailed Information on the Processing of Personal Data” in this document for more information about these activities.

Categories of Personal Information We Collect

We collect certain categories of personal information about you, including internet information and inferred information. We do not collect sensitive personal information.

We will not collect additional categories of personal information without providing you with notice of such collection or obtaining your consent where required by law.

Purposes for which we use your personal information

We collect your personal information to enable the operational functioning of this Application and its features ("business purposes"). When we process your personal information for such purposes, we ensure that it is done in a way that is necessary and proportionates to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

Additionally, we may use your personal information for commercial purposes, as explained in detail within the section titled “Detailed information on the processing of Personal Data” within this document. We may also use your personal information to comply with applicable laws and regulations and to defend our rights before the competent authorities where our rights and interests are threatened or we suffer actual damage.

We will not process your personal information for unexpected purposes or for purposes that are incompatible with the purposes originally disclosed, without your consent.

Retention of your personal information

Unless otherwise stated in the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) for which it was collected.

Sources of Personal Information We Collect

When you use this Application, we collect the categories of personal information mentioned above directly or indirectly.

Directly, you provide your personal information when you submit requests through any forms on this Application. Indirectly, personal information about you is automatically observed and collected when you navigate this Application.

Additionally, we may collect your personal information from third-party partners that work with us in connection with the Service or with the functioning of this Application and its features.

Sharing Your Personal Information with Third Parties for Business Purposes

For this section, "third party" refers to any person or entity that is not a service provider or contractor as defined by the CCPA.

We may share your personal information with third parties for business purposes as described in detail in the "Detailed Information on the Processing of Personal Data" section of this document. These third parties are classified and grouped according to the specific purposes for which they process your data.

Sale or sharing of your personal information

Under the CCPA, we define the term "sale" as any act of exchanging personal information with a third party for monetary or other valuable consideration. This includes situations where an application displays ads, conducts statistical analyses, or uses social network plugins. Similarly, we define "sharing" as the act of disclosing personal information to a third party for cross-context behavioral advertising, regardless of whether money or other valuable consideration is involved. However, it's important to note that sharing personal information with a service provider under a written contract that meets CCPA requirements is not considered a sale or sharing of personal information.

You have the right to opt out of the sale or sharing of your personal information with the third parties listed in the section titled "Detailed information on the processing of Personal Data" in this document. To exercise this right, you can freely contact us at any time using the contact details provided in this document, or by using the privacy choices link on this Application.

You can also submit opt-out requests through user-enabled global privacy controls, such as the Global Privacy Control ("GPC"). GPC is a browser setting or extension that allows websites to indicate support for the GPC signal. If you choose to use GPC, you can download and enable it via a participating browser or extension. For more information on downloading GPC, please visit their website.

Please note that we will use any personal information collected from you in connection with your opt-out request solely to comply with the request.

Once you have opted out, we are required to wait at least 12 months before asking if you have changed your mind.

You have the right to exercise your privacy rights under the California Consumer Privacy Act (CCPA). Specifically, you have the right to access your personal information and receive it in a portable format.

You can request us to disclose the categories of personal information that we collect, the sources from which it is collected, and the purposes for which it is used. You can also request information about whom we disclose your data and what personal information is sold or shared with third parties.

We will provide you with two separate lists: one for personal information sold or shared, and one for personal information disclosed for a business purpose. This information will only include the personal information collected or used within the past 12 months.

If we deliver our response electronically, we will provide the information in a format that can be easily used and transmitted to another entity, provided it is technically feasible.

Your right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, except where the law provides otherwise (such as, but not limited to, cases where the information is used to identify and correct errors on this Application, to detect and prevent security incidents, to exercise certain rights, etc.).

If no legal exception applies, we will delete your personal information upon receipt of your request and notify our service providers and any third parties we have shared or sold your personal information to do the same, provided that it is technically feasible and does not involve a disproportionate effort.

The right to correct inaccurate personal information:

However, if you refuse to provide us with your personal information or request that we delete or stop selling it, and that information or sale is necessary for us to provide you with goods or services, we may not be able to complete the transaction.

If allowed by law, we may offer promotions, discounts, and other incentives in exchange for collecting, keeping, or selling your personal information, as long as the incentive is reasonably related to the value of your information.

How to exercise your rights

To exercise your privacy rights, you need to make a verifiable request to us by contacting us using the details provided in this document.

We can only fulfill your request if we can verify your identity. Therefore, your request must include sufficient information to allow us to reasonably confirm that you are the person about whom we have collected personal information or an authorized representative. Additionally, your request must be described with enough detail to allow us to understand, evaluate, and respond to it.

If we are unable to verify your identity, we will be unable to process your request.

Creating an account with us is not required to make a verifiable consumer request. We will use any personal information collected in connection with verifying your request solely for verification, and will not retain or use it for unrelated purposes.

If you are unable to submit a request personally, you may authorize a person registered with the California Secretary of State to act on your behalf. If you are a parent or legal guardian, you may submit a request on behalf of a minor under your parental authority.

Please note that you may submit a maximum of two requests in 12 months.

How we will handle your request

Upon receipt of your verifiable request, we will acknowledge its receipt within 10 days and provide you with information on how we will process your request.

We will respond to your request within 45 days of receiving it. If we require more time, we will explain the reasons why and how much additional time we need, which can be up to 90 days.

Our disclosure(s) will cover the preceding 12-month period. If your personal information was collected on or after January 1, 2022, you have the right to request information beyond the 12 months. We will provide this information to you unless it is impossible or would involve a disproportionate effort.

If we deny your request, we will explain the reasons for our denial.

We do not charge a fee to process or respond to your verifiable request unless the request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or decline to act on the request, and we will explain our decision and the reasons behind it.

Information for Virginia consumers

For Virginia-based consumers, this section complements and expands upon the information provided in the rest of the privacy policy. The controller of this Application, as well as its parent, subsidiaries, and affiliates (collectively referred to as "we", "us", and "our"), provide the information below. As a consumer residing in the Commonwealth of Virginia, you are referred to as "you", "your", or "yours". These provisions override any conflicting provisions in the privacy policy and are governed by the "Virginia Consumer Data Protection Act" (VCDPA).

In this section, the term "personal data" is used as defined in the VCDPA. We outline the categories of personal data we process and the purposes for doing so. For a detailed account of these activities, please refer to the "Detailed information on the processing of Personal Data" section of this document.

Categories of personal data we collect

The personal data we collect falls into two categories: internet information and inferred information. We do not collect sensitive data, and we will always notify you if we intend to collect any additional categories of personal data.

We do not collect sensitive data.

To understand why we process your data, please refer to the "Detailed information on the processing of Personal Data" and "The purposes of processing" sections of this document. We will never process your information for unexpected purposes or purposes that conflict with the originally disclosed purposes without your consent.

You are free to give, deny, or withdraw your consent at any time using the contact details provided in this document.

How we use the data we collect: sharing of your data with third parties

We may share your data with third parties for the purposes outlined in the "Detailed information on the processing of Personal Data" section of this document. These third parties are categorized based on the specific purposes of the processing. For this policy, "third party" refers to any individual, organization, public authority, or body that is not the consumer, controller, processor, or affiliate of the controller or processor, as defined by the VCDPA.

Sale of your data

It is important to note that under the VCDPA, disclosing personal data to a processor that handles personal data on behalf of a controller does not constitute a sale. However, our use of your personal information may be considered a sale under the VCDPA, as specified in the "Detailed information on the processing of Personal Data" section of this document.

Your right to opt out of the sale of your data and how you can exercise it

You have the right to opt out of the sale of your data. We will honor your request and stop selling your data upon receiving your opt-out request. You can exercise this right at any time by contacting us using the contact details provided in this document. Please note that any personal data collected from you in connection with submitting your opt-out request will only be used to comply with the request.

Processing of your data for targeted advertising

We define "targeted advertising" as displaying ads to you based on personal data gathered from your activities across nonaffiliated websites or online applications to predict your preferences or interests, as defined by the VCDPA. To learn more about how we process your data for targeted advertising purposes, please refer to the "Detailed information on the processing of Personal Data" section of this document.

You have the right to opt out of the processing of your data for targeted advertising. This means that we will stop processing your data for this purpose upon receiving your request. To exercise this right, you can contact us at any time using the contact details provided in this document.

Please note that any personal data collected from you in connection with submitting your opt-out request will only be used to comply with your request.

As a consumer, you have certain rights under the Virginia Consumer Data Protection Act (VCDPA) regarding your data processed by us. These include:

You can exercise these rights by contacting us using the contact details provided in this document. We will not discriminate against you for exercising your privacy rights under the VCDPA. We may, however, be unable to provide you with goods or services if your data is necessary for such purposes and you have exercised your right to delete or opt out. For more information, you can read the section titled "Your privacy rights under the Virginia Consumer Data Protection Act" within this document.

How to exercise your rights

To exercise your rights, you must contact us using the contact details provided in this document. We require that you provide sufficient information to enable us to verify your identity and confirm that the personal data in our possession relates to you. If we are unable to verify your identity using commercially reasonable efforts, we may ask you to provide additional information to authenticate you and your request.

You are not required to create an account with us to make a request, but we may require you to use your existing account. We will only use any personal data collected from you in connection with your authentication request, without further disclosing the personal data, retaining it longer than necessary, or using it for unrelated purposes.

If you are an adult, you can request on behalf of a minor under your parental authority. We will respond to your request as required by law.

When and how we handle your request

We are committed to responding to your request promptly, within 45 days of receiving it. If we need more time to process your request, we will explain the reasons for the delay and the expected time frame. Please note that in some cases, we may need up to 90 days to respond to your request.

If we deny your request, we will provide a clear and concise explanation for the decision within 45 days of receiving the request. You have the right to appeal our decision by contacting us via the details provided in this document. We will respond to your appeal within 60 days of receipt, explaining any action taken or not taken, along with the reasons for our decision. If your appeal is denied, you have the right to file a complaint with the Attorney General.

We do not charge a fee to respond to your request, for up to two requests per year. However, if your request is deemed manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our decision and explain.

Information for Users residing in Brazil

This section of the document provides additional information for users residing in Brazil and supplements the information contained in the rest of the privacy policy. This information is provided by the entity that operates this Application, as well as its parent, subsidiaries, and affiliates (referred to collectively as "we", "us", and "our" in this section).

The provisions outlined in this section apply to all Users residing in Brazil, under the "Lei Geral de Proteção de Dados" (LGPD), and will supersede any other divergent or conflicting provisions contained in the privacy policy. For this section, users are referred to as "you" or "your".

In this section, the term "personal information" is used as defined in the LGPD.

The grounds on which we process your personal information

Our processing of your personal information is subject to certain legal grounds. These grounds are as follows:

1. Your consent to the processing activities.
2. Compliance with a legal or regulatory obligation that we are subject to.
3. Carrying out public policies provided in laws or regulations, or based on contracts, agreements, and similar legal instruments.
4. Conducting studies by research entities, preferably carried out on anonymized personal information.
5. Carrying out a contract and its preliminary procedures, in cases where you are a party to said contract.
6. Exercising our rights in judicial, administrative, or arbitration procedures.
7. Protection of physical safety of yourself or a third party.
8. Protection of health – in procedures carried out by health entities or professionals.
9. Pursuing our legitimate interests, provided that your fundamental rights and liberties do not override such interests.
10. Credit protection.

To learn more about these legal bases, you may contact us using the contact details provided in this document.

Categories of personal information processed

If you would like to know what categories of your personal information we process, you can refer to the "Detailed Information on the Processing of Personal Data" section in this document.

Why do we process your personal information?

We are committed to protecting your privacy rights as a user residing in Brazil. Your rights include:

We will respond to your requests without discrimination or any negative consequences. To learn more about your rights and how to file a request, please refer to the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

How to request and our response

If you wish to exercise your privacy rights, you may do so by contacting us using the contact details provided in this document or through your legal representative. There will be no charge for filing your express request at any time.

We will make every effort to respond promptly to your requests. However, if we are unable to do so, we will communicate the factual or legal reasons preventing us from complying with your request. If we are not processing your personal information, we will provide you with the name of the physical or legal person to whom you should address your request, if we are in a position to do so.

If you request access to or confirmation of your personal information, please specify whether you want it delivered in electronic or printed form. Additionally, you can indicate if you want a simplified response immediately or a complete disclosure within 15 days of your request. We will provide you with information on the origin of your personal information, the existence of records, processing criteria, and purposes while safeguarding our commercial and industrial secrets.

If you request rectification, deletion, anonymization, or blocking of personal information, we will communicate your request immediately to third parties with whom we have shared your information, unless it involves a disproportionate effort on our part or is proven impossible.

Permitted transfer of personal information outside of Brazil

There are certain circumstances in which we are allowed to transfer your personal information outside of Brazil. These include:

CONTACT US

If you have any questions about our Privacy Policy, or if you want to know what information we have collected about you, please use our specific GDPR contact form.

Postal Address:

EDEN STAR Communication LLC
99, Wall Street
Manhattan, New York City
10005 NY, USA

Pax: +1 212 7291352

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13 and 14 of the EU 2016/679 Regulation (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document.

IT'S PROHIBITED ANY USE, PARTIAL OR WHOLE REPRODUCTION OF OUR GDPR LEGAL REGULATION. © 2018-2024 All Rights Reserved