Privacy Policy

Updated: 01.06.2018

Sarafan respects your privacy and protects your personal data in the best possible way. In all our operations we ensure that your personal data are processed in the safest manner both within our company and in the operations of our subcontractors. In this privacy policy, we describe what data we collect and how they are used.

The main grounds for processing personal data are our relationships or consent of the data subject or legitimate interests of the data controller.

1. DATA CONTROLLER

Sarafan Technology, Inc. (“Sarafan”, “we”, “us”, “our”, “Company”)

Address: 838 6 Ave., 6 Fl., New York, NY 10001

Phone: +1 347 480 44 26

E-mail: info@sarafan.tech

2. NAME OF THE REGISTER

Sarafan Technology: partner and client register.

3. PERSONAL DATA

Personal data means any information relating to an identified or identifiable individual. Identification could be made directly or indirectly, 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 person. “Non-personal data” means any information that cannot be related to your identity and therefore cannot be classified as personal data, like e.g. information on browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.

4. COLLECTION AND PROCESSING OF INFORMATION

We collect, process your personal data. “Processing” means any operation or set of operations which is performed on data such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

The scope of how we collect and process personal and non-personal data on you or other information depends on the way you get in touch with us or our technologies and services:

  • as a visitor of sarafan.tech;
  • as a publisher or an advertiser of the Sarafan affiliate network;
  • as a user of our publishers’ and advertisers’ websites.

With this Privacy Policy, we want to keep you informed which information we receive and use on every stage.

We use personal data only for administering and providing our technologies and services. We store personal and any other kind of data strictly in compliance with applicable data protection and privacy legislation and our contractual duties and will prevent unauthorized access to data to the best of our abilities.

4.1. If you are a visitor of sarafan.tech

If you visit Sarafan website, no personal data is collected and recorded unless you provided it voluntarily, e.g. as part of a survey. However, we log the following non-personal data to facilitate the use of our website and to ensure its security and stability our web servers:

  • the IP address of the requesting device;
  • the date and time of your visit;
  • the data specifications of your browser and operating system;
  • the website you were referred from to our website (so-called Referrer URL).
  • This information is stored in a log file until it is automatically deleted.

We use cookies to improve and optimize the usability of our website. Cookies do not cause damage to your device, do not contain viruses, trojans or other malicious software. The cookie stores information, which is linked to a respective device used. This does not mean, however, that we store personal information about you or are aware of your identity. Visiting and surfing on our website is possible without cookies. Most browsers accept cookies automatically. You may alter the security settings of your web browser to stop your device receiving and storing cookies, to allow receiving and storing cookies from selected websites only, or to be notified before receiving cookies. Please note, however, that these settings may have negative effects on the usability and user guidance of websites and other online services. You may delete cookies stored in your browser at any time. Information stored in such cookies will be removed from your device.

4.2. IF YOU ARE A PUBLISHER OF ADVERTISER

To obtain access to our technologies and services, you need to register in our network. After that in addition to the data described in section 4.1 we collect and process:

  • Your first and last name
  • Email address,
  • Mailing address,
  • Phone number,
  • Payment information.

Publishers and advertisers voluntary provide to us provide the information while:

  • Registration for our Service during which you provide us your name, phone number, e-mail address for instance,
  • Fill into the contact form;
  • Contacting us via e-mail or phone number;
  • Participating in influencer program;
  • Signing into your Account,
  • Signing into your Account and using our Services by using other accounts, such as your e-mail, social media or payments accounts.
  • This processing of personal data is necessary for the performance of a contract, Art. 6 sec. 1 lit. b GDPR. We do not collect or use any further personal data other than voluntarily provided by you.

4.3. If you are a user of our publishers’ and advertisers’ websites

We store cookies on devices of users who are visiting websites and using online services of our publishers and advertisers. These cookies store the information on:

  • when and on what device a click on an advertisement occurred;
  • the advertiser’s affiliate program;
  • the publisher;
  • the specific time of the user’s action.

While tracking we may also collect information on the device that is used to perform a conversion such as a device’s operating system and browser.

The purpose of this data processing is to track conversions (leads and sales such as installing an application or placing an order in an online shop) and to allocate them to proper publishers. It is necessary for the performance of a contract with third parties (our advertisers’ and publishers) that make use of our services, Art. 6 sec. 1 lit b) GDPR.

If you do not want Sarafan to collect and store your data, please inform us about this. Please note, that it may affect the functionality of the websites that Sarafan works with. Please note that although we choose our business partners and clients carefully, we are not responsible for the privacy practices of websites and mobile applications operated by such third parties. You should check the applicable privacy policies of such websites and mobile applications you visit for more information on what kind of data they are processing with the help of our services and technologies and how they handle any data they collect from you as well as the legal base(s) for that processing.

Sarafan does not conduct behavioral advertising and does not collect data for these purposes. However, our publishers may use cookies for purposes of behavioral advertising.

For this reason, we would like to draw your attention to the possibilities to object against the collection of data for purposes targeted advertising on the following websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/en/ (for the European area).

5. PURPOSE FOR INFORMATION COLLECTING

Your information helps us more effectively respond to your needs as our website and Services user. The information is needed for delivery to you our Services. The information you provide us couldn’t be used for any other purpose than delivering you the requested Services or improving them.

6. THE INFORMATION WE COLLECT COULD BE USED IN THE FOLLOWING WAYS

The information and feedback we are getting help us constantly improve our website and our Services so they meet current and future visitors’ needs. We also use the information to improve our client and partner services.

We are happy to send you periodical email updates because it helps to be in touch with you. By subscribing to our newsletter, you agree to the receipt of the newsletter and the procedures described.

We send out newsletters, e-mails and other electronic notifications with promotional information (hereinafter "Newsletter") subject to the consent of the recipient or a legal permission.

The registration for our newsletter is handled through a so-called double opt-in procedure, which means you will receive an e-mail after your registration, in which you will be asked to confirm your registration once again. The registrations for the newsletter are recorded to prove the accurate registration process according to legal requirements. This includes storing the time of login and confirmation. The newsletters can be sent by Sarafan itself or by means of a third-party service.

At any time, you can unsubscribe from receiving emails, by going to unsubscribe page via the link located at the bottom of every email. We may use your personal information for informing you about any changes at website and Services, such as sending you technical notices, updates, general information or legal and regulatory provisions or warnings about different types of risks.

7. TERMS OF PERSONAL DATA STORAGE

Your personal data are stored in the register only if it is essential for the purposes set out in this data protection policy and for compliance with a legal obligation to store data. It is possible that due to a legal obligation Sarafan can be required to store data longer than the above mentioned envisaged period.

Any outdated and unnecessary data are erased in an appropriate manner. Data are entered in the register in the form used by the data subject to give them and they can be updated by the data subject personally or by Sarafan on request of the data subject.

8. DISCLOSER OF INFORMATIONM

Under no circumstances we couldn’t sell or share your personal information with the third parties, except to the following extents:

  • a. Third party vendors operating our Services, including legal services, payment processing, billing, IT support, research, analytics, data storage, validation, security, fraud prevention and payment processing.
  • b. Our group companies to provide you constant level of services.
  • c. Third parties in the event of any merger, sale, joint venture, transfer or other such disposition of any portion of Sarafan’s assets.

The access to the information could be done only under appropriate organizational and technical conditions which would ensure the protectiveness of the information. We take all reasonable steps to ensure confidentiality and privacy obligations. The disclosure of your personal data to third parties to the extent required by law, court order or a decision rendered by a competent public authority and for law enforcement.

9. DATA TRANSFER

Personal data collected by Sarafan may be stored and processed in your region, in the United States for example, or in any other country where Sarafan, its affiliates, subsidiaries or service providers are located or maintain facilities. Sarafan has put in place adequate mechanisms to protect personal information when it is transferred internationally.

10. RIGHTS APPLICABLE TO EU/EEA USERS

If you are based in European Union (“EU/EEA”) or in any other region where the laws governing data collection and you that may differ from EU/EEA or US law, please note that note that you may be transferring your Personal Information to the Sarafan in the United States and in other countries around the world for the purposes described under our Privacy Policy. We will use all adequate mechanisms to protect your Personal information when it is transferred internationally. Your personal data could be transferred to the authorities only if required or for purposes stipulated by law.

If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. For the European Economic Area, there are different legal bases that we rely on to use your Personal Information for consent, the performance of a contract and legitimate interests.

If you subject to EU you may access, correct, update or request deletion of your information, object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information, withdraw your consent at any time, complain to a data protection authority about our collection and use of your Personal Information, to exercise any of these rights at any time by contacting us at e-mail shown above. In order to delete your account and all Personal information please contact us at info@sarafan.tech.

Please note that if you are not subject to EU law, these rights do not apply to you.

11. COOKIES

Sarafan website uses cookies. To ensure the best possible functioning of the website you need to allow the use of cookies in your browser. Cookies are used to collect technical information and data about the way the website is used. These data are utilized to develop the website in order to make it match the demands of our clients even better. We use the following types of cookies:

  • Strictly necessary cookies. These cookies are essential for you to browse our website and use its features. Without these cookies, some online services cannot be provided.
  • Functional cookies. These cookies allow our websites to remember choices you make while browsing and personalize your experience. We may store your geographic location in a cookie, for instance, to ensure that we show you the website relevant to your area.

You can block the use of cookies in your browser settings, if necessary. When the function is blocked some of the website functions may get slower or access to some parts of the website can be blocked completely.

12. SECURITY

We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. No method of transmission over the internet or electronic storage is completely secure, so Sarafan cannot guarantee its absolute security.

13. CHANGES TO DATA PROTECTION POLICY

Sarafan is constantly improving its operations and therefore we reserve the right to change our data protection policy, to be announced through our website. The changes can be related to changes in legislation. We recommend you review the contents of data protection policy regularly.

14. USE BY CHILDREN

Sarafan does not target and is not intended to attract children. Accordingly, our services are not directed at and should not be accessed by individuals under the age of sixteen (16 years), and we request that such individuals do not provide any personal data to Sarafan. Minors must obtain express consent from parents or legal guardians prior to accessing or providing any personal data. If notified by a parent or guardian or discovered by other means, that a child under age of sixteen has provided his or her personal data to Sarafan, we will delete the child’s personal data in our possession.

15. CONTACT US

If you have any questions regarding this Privacy Policy, please contact us by email at info@sarafan.tech.

 
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+1 347 480 44 26

Лондон:

+44 203 808 54 11

 
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