Privacy & Legal Policy

Language is Important: This Website and its related Terms of Use and Privacy Policy are provided in the language(s) in which our website(s) are provided and our services are intended for use by those who are proficient in such language(s). By agreeing to our Policy and using our site(s) you are agreeing to its terms.

This Privacy Policy ("Policy") covers our collection, use, and sharing of "Personal Data" (defined below) and applies to all websites, products, services, as well as any mobile applications (collectively, "Services") provided by PEWEO SÀRL or any member of its corporate family. Terms such as "we" and "our" refer to PEWEO SÀRL and each of its affiliates.

This Policy explains what kind of Personal Data we collect from you as well as the purpose of our collecting and using the data, how long it is retained, with whom we share it, and your rights concerning the data.

This Policy applies if you are an individual actual or prospective customer, regardless of your nationality or residence. It does not apply to companies/organizations (although it may apply as to specific individuals within such companies/organizations). Nor does it cover how you or other users may use or share data that they collect using our Services.

Please read this Policy carefully. By accessing or using Services, you are agreeing to this Policy so if you do not agree to be bound by its terms you should not use our Services. By accepting the Policy you are also certifying that you are of the legal age of majority in the jurisdiction where you reside. If you have not yet reached the age of majority you may not use our Services.

This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

This policy applies to Personal Data that we collect:

• On our website(s).
• In e-mail, text and other electronic messages exchanged between us and/or through our website(s).
• When you interact with advertising and applications of third-party websites and services appearing on our website(s). However, it does not cover any aspect of your interaction with a third party site (even if accessed via our website) or any data collection or use by such third parties.

Not all data is "Personal Data". For the purposes of this Policy the term "Personal Data" means information that, acting alone or together with other data elements that we have, is sufficient to identify you as a specific natural person. Examples of Personal Data elements may include: a name, an identification number, location data, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity as a particular natural person.

This section describes the general categories of Personal Data we may process, the purposes, legal bases and legitimate interests for processing, and the duration of Personal Data.

We generally use information we collect about you (or that you provide), including Personal Data, to:

• Present our website(s) and its contents to you.
• Allow you to participate in interactive features on our website(s).
• Provide you with information or Services that you request from us.
• Provide you with notices about your account, including expiration and renewal notices.
• Carry out our obligations and enforce our rights arising from contracts with you, including for billing and collection.
• Notify you about changes to our website(s) or any Services we offer or provide through it.
• Fulfill any other purpose for which you provide it.
• In any other way we may describe when you provide the information to us.
• For any other purpose consistent with your consent.

We may collect and process the following categories of information, some or all of which may include Personal Data:

We may disclose your Personal Data to third parties insofar as reasonably necessary for the relevant purposes and on the relevant legal basis set out in this Policy. This includes the following:

• To any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries);
• To our resellers or third party suppliers insofar as reasonably necessary for the purposes described regarding "Account data", "Sales data" and "Affiliation data" in order to provide the Services you have requested;
• To contractors, service providers and other third parties to the extent reasonably necessary for the maintenance, security, and proper operation of our website(s) and our provision of Services;
• To our insurers and/or professional advisers to the extent reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, prevention or investigation of security breaches and fraud, obtaining professional advice, or the establishment, exercise or defense of legal or equitable claims, whether in court proceedings or in an administrative or out-of-court procedure;
• To a potential buyer or other successor (and/or their advisors) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our website(s) users is among the assets transferred;
• To our payment services providers to the extent necessary for the purposes of processing or refunding payments or addressing complaints and queries relating to such payments or refunds;
• To the extent reasonably necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of a third person;
• To third party service providers to the extent reasonably necessary to fulfill, provide and ship Services you have purchased through our website(s);
• Consistent with the purpose for which you agreed to provide it; and/or,
• With your consent.

Generally, we may transfer your Personal Data between different jurisdictions. However, in doing so we will comply with the European Data Protection Directive 95/46/EC ("GDPR") and other applicable laws regulating the protection for the transfer of personal information between jurisdictions. This means that we may transfer your data to the United States, the EU, or other countries subject to conditions. If you are a European resident, we will endeavor to confirm that either the European Commission has determined that the receiving jurisdiction provides adequate protection of Personal Data or that other appropriate safeguards are in place, namely the use of relevant standard data protection clauses adopted or approved by the European Commission. Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.

Please note that if you access our services through a tool that hides your location, such as a VPN, or if you access our Services through a location other than where you reside, you may not receive our request for permission because we were not able to identify you as being located in a jurisdiction where your permission is required.

We may share your Personal Data with other members of our corporate family so that they can contact you with services (or offers) that may be of interest to you and/or so that they can provide you with Services or assistance regarding Services provided by one or more members of our family. Any such use or processing will be pursuant to the terms of this Policy. If you are located in a jurisdiction where such sharing requires your permission, we will only do so with your consent.

When we share personal information with certain third-party affiliates, including marketing and advertising partners, that information may include your name, email address and other information so that our partner may assist you in using our products and services, contact you with offers, services or products that may be of interest to you, and/or provide you with their products or services.

We rely on others to provide some of the support and services we provide to you. We form contracts with these vendors and service providers for this purpose (for example providing banking, payment processing/gateway, IT, and storage services including back-ups or to aid us in our security measures or marketing activities).

If you purchase a product or service from a third party through one of our websites, we will pass your personal information to such third party in order for them to fulfill your order.

From time to time our website(s) may portray advertisements or links to third party websites and sources. If you activate such link you will be interacting with such third party and we will retain a record of your having responded to the advertising or link. We may provide such third party with general non-Personal Data necessary to identify our website(s) as the source of any interaction you may have with such third party.

However, each such third party will act as a data controller/processer in relation to data that they obtain or receive and when you interact with such third party you will be subject to their Policy, which will govern any of your Personal Data that you provide to them. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

If we are involved in a merger, acquisition, a sale of any part of our business, we may be required to disclose information to the counter-party.

Anyone that you (or if you are a company/organization, your company) authorizes to have access to your account or any Services, may be able to view Personal Data stored in connection the account or any subaccount to which they may have access.

If we are, or in good faith believe disclosure is reasonably necessary to comply with our legal obligations in any relevant jurisdiction, we may disclose information about you, including Personal Data, to courts of law, people acting under color of law, law enforcement authorities and other relevant third parties, such as internet service providers, attorneys or investigators, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or, in our good faith belief, may be:

• violating our terms and conditions of use;
• causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or
• violating federal, state, local, or other applicable law.

Disclosures can include transferring your information to the U.S. and other countries outside the European Economic Area. To the extent we are legally permitted to do so, it is our policy to notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena. For transfers of Personal Data to third parties, such transfers will either (i) be under the European Commission's model contracts for the transfer of Personal Data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU; or (ii) rely on the EU-US Privacy Shield Framework.

Some of our Services provide links to other websites. We do not control the information policies or practices of these third party sites and you should carefully review their privacy policies to learn about how they collect, use and share your personal information.

From time to time we may permit you to log into your account and access our Services using single-sign-in services such as Facebook. These services will authenticate your identity to us and may allow you to control what information these services share with us, thus providing you with options regarding sharing certain personal information with us (e.g. your name and email address to pre-populate our sign up form). Using certain social media features, such as "like", "share", "widgets" or interactive mini-programs that may run on our website(s) may result in the applicable social networking sites collecting Personal Data and other data regarding you and your activities, including your IP address, which page you are visiting on our websites, and may set a cookie to enable it to function properly. You should carefully review the applicable privacy policies of such third party services to learn about how they collect, use and share your personal information.

The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take good faith measures to safeguard your personal information within our systems against loss, theft and unauthorized use, access or modification.