Last Modified: August 25, 2023
Aylo Social Ltd (hereinafter “we”, “us”, or “our”) operates the website https://www.uviu.com/ (hereinafter “UVIU” or the “Website”) and is the controller of the information collected or provided via this Website.
If you have any questions about our privacy practices, please see “Contact Information” below for information on how to contact us.
- on this Website,
- in e-mail, text and other communications between you and this Website,
- through mobile applications you download from this Website (which we provide dedicated non-browser-based interaction between you and this Website for), or
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified by (“Personal Information”). It does not include data that has been anonymized or pseudonymized.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data. includes first name, last name, username, or similar identifier, title, date of birth and gender.
- Identifiers and Biometric Information. When registering for certain features of the Website we collect identifiers you submit to us, allowing us to verify your identity. We also collect biometric information in order to verify the authenticity of the identifiers you provide to us while registering for such services, as further explained in the section “Biometric Information” below.
- Contact Data. includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Payment (Transaction) and Commercial Information: If you make a purchase or receive payments from us, we collect payment card or account details and related information necessary to process payments. We also collect details about payments to and from you and details of products and services you have purchased or received from us.
- Technical Data. includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
- Profile Data. includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data. includes information about how you use our Website, products, and services.
- Marketing and Communications Data. includes your preferences in receiving marketing from us and our third parties and your communication preferences, as well as any other information which you voluntarily provide to us at your direction for a specific function.
- Information you provide through support channels. You may provide information or content to us through electronic correspondence when attempting to reach our support staff. When you engage with support staff, in addition to your account information, we may ask you to provide additional information about your issue/request, which may include, but not be limited to, information about your hardware/software, additional account information, or we may ask you to provide screenshots.
We may also collect, use, and share your data to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. We may also aggregate your usage data to calculate the percentage of users accessing a specific Website feature. For example, we may use your data to generate statistics about our users, to calculate the percentage of users accessing a specific Website feature, to calculate ad impressions served or clicked on, or to publish visitor demographics.
We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, or information about your health). However, depending on how you use our Website and services, your Personal Information may include biometric information, or information that allows drawing conclusions about your sex life or sexual orientation (“Sensitive Personal Information”). The collection, use and disclosure of such Sensitive Personal Information is necessary to provide some of our service to you.
We cooperate with third-party service providers to help verify your identity and age and to check the authenticity of any identification documents you provide using facial recognition technology. The facial recognition technology creates a mathematical representation of your face and detects facial features from the live scan of your face, your selfie, and the government-issued ID you submit or have previously submitted to us. This mathematical representation, which is considered biometric information/identifier/data under the laws of certain states and countries, is not shared by our service providers with us. Information derived from this mathematical representation, which may be considered biometric information/identifier/data under the laws of certain states and countries is shared by our service providers with us and is subsequently deleted by us, as further described below.
Your biometric information will be used to:
- verify you are a real, live person and to prevent the use of methods which would allow a user to identify as someone else.
- match your selfie with your government-issued ID which you will submit or have previously submitted to us to make sure that nobody is impersonating you.
- help confirm your age.
We may disclose your biometric information, face scan, selfie, and government-issued ID (including any government-issued ID or selfie you previously submitted to us) within members of our corporate group, and with third-party service providers. These entities may be located in jurisdictions that do not offer the same level of data protection as your jurisdiction. We, and any of these entities, may perform facial recognition and collect your biometric information from your face scan, selfie, and any government-issued ID, and use your biometric information for the above purposes.
Biometric information shared by our service providers with us will be stored for as long as you maintain an account on the Website. We will delete your biometric information within three (3) years of you deleting your account of the Website, or withdrawing your consent, subject to any legal obligations we may have.
You will be asked to provide your consent to biometric processing, which you may withdraw your consent to at any time by using the links below. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.
How is Your Personal Information Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. Information that you provide when carrying out search queries on our Website or by filling in forms on our Website, in particular at the time of registering to use our Website, subscribing to our service, posting material, taking part in surveys, entering a contest or promotion sponsored by us, when reporting a problem with our Website, or requesting further services.
- Third parties. We may receive personal data about you from various third parties, for example, other websites controlled by us or members of our corporate group, our business partners or other third parties.
We may provide areas on our Website where you can post information about yourself and others and communicate with others, upload content (e.g., pictures, videos, audio files, etc.), and post comments or reviews of content found on the Website. Such postings are governed by our Terms of Service. If you use a forum, blog, user commenting feature, community or other interactive sharing or social features that may be offered through our Website, you should be aware that any Personal Information you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction, except to the extent limited access features are available, if any. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. If you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your Personal Information. Once you have posted information, you may not be able to edit or delete such information. To request removal of your personal information from our blog, sharing service or community forum, for example, send us an e-mail at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Cookies and Automatic Data Collection Technologies
As you navigate through and interact with our Websites, we use automatic data collection technologies to collect website activity data.
We currently use the following types of cookies, which are set by the Websites’ domains, or by other domains we own or control:
- Strictly necessary cookies: These are cookies that are required for the operation of our Websites. These include, for example, cookies that enable a user to log in to our Websites and to check if a user is allowed access to a particular service or content.
- Functionality cookies: These cookies help us to personalize and enhance your online experience on our Websites. This type of cookies allows us to recognize you when you return to our Websites and to remember, for example, your choice of language.
- Analytics cookies: These cookies allow us to recognize and count the number of users and to see how users use and explore our Websites. These cookies help us to improve our Websites, for example by ensuring that all users are able to find what they are looking for easily. Additionally, we are using third party session recording technologies that helps us better understand our users’ experience, however, the recording data is pseudonymized.
- Targeting and Advertising cookies: These cookies record visits of a user on our Websites, the pages a user visits and the links a user follows in order to enable us to make our Websites more relevant to the user’s interests and to help us serve ads that might be of interest to the user. Targeting and advertising cookies are used for Unregistered Users and Registered Users.
Analytics, Functionality and Advertising / Targeting cookies can be switched off at any time by accessing the ‘Manage cookies’ option that is located at the footer of our website. However, if you decline to accept these cookies, some functionality on our Websites may be disabled and can interrupt your access to certain parts of our Website.
Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use the Websites, including, by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only for the purpose of providing Google Analytics services to us and will not use this information for any other purposes. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU. You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.
You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
We strive to provide you with choices regarding the personal information you provide to us.
- You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our Websites because such information may be required in order for you to register as a member; subscribe, purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our Websites.
The Cookie Banner can be utilized to customize your cookie preferences. The Cookie Banner will record when you have consented to our cookies. For logged in users, we will ask for consent once a year or when we have major changes to our cookies, to ensure you stay up to date with changes to our cookie and privacy policies. For non-logged in users, your Cookie Banner selection will be kept only for the specific session. The Cookie Banner specifically controls the Functionality, Analytics, and Advertising cookies set by using our website. Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from our website.
You can access the Cookie Banner anytime by clicking on the ‘Manage cookies’ option that is located at the footer of our website.
- You can opt out of receiving marketing emails from us using the opt-out link provided in our emails or by changing your preferences in your account settings. If you are a Registered User, we may continue to send you other types of important emails e.g., e-mails about your transactions, account, or orders.
- You may use your account settings to delete your user contributions and audio/video information.
- You may also delete and deactivate your account with us at any time unless required not to do so by law or by a court order. If you do so, your profile will no longer be accessible by you. If you later choose to have an account with us, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
How We Use Your Personal Data
We will only use your personal data when the applicable local law allows us to. Most commonly, we will use your personal data in the following circumstances:
- For purposes of providing the services, customer management and functionality and security as is necessary to perform the services provided to you under our terms and conditions and any other contract that you have with us.
- Biometric information and identifiers are processed based upon your consent for us to do so.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data.
Purposes for Which We Use Your Personal Information
In general, we use information that we collect about you or that you provide to us, including Personal Information, for following purposes:
- Provision of services: to present our Website and its contents to you, including any interactive features on our Website, and to provide you with information, products, or services that you request from us; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with contests and sweepstakes;
- Customer management: to manage a registered users’ account, to provide customer support and notices to the registered user about his account or subscription, including expiration and renewal notices, and notices about changes to our Website or any products or services we offer or provide through it; We also use biometric information and identifiers for the purposes of verifying your identity and the authenticity of the identifiers you provide or have provided to us while registering for certain services on the Website;
- Customization of content: to perform research and analysis about your use of, or interest in, our Website content, products, or services, in order to develop and display content and advertising tailored to your interests on our Website and other websites;
- Advertising: to communicate with you about products or services that may be of interest to you either from us, our affiliates or other third parties (For more information, see “Choices About How We Collect, Use and Disclose Your Personal Information”);
- Analytics: to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns;
- Functionality and security: to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
- Compliance: to enforce our terms and conditions and to comply with our legal obligations;
Disclosure of Your Personal Information
We do not disclose your Personal Information except in the limited circumstances described here.
- We may disclose your Personal Information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for the purposes of provision of services, customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.
- Service providers. To our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, identity and document authenticity verification including biometric processing, processing credit card payments, risk and fraud detection and mitigation, providing customer service, performing business and sales analysis, customization of content, analytics, security, supporting our Website functionality, and supporting contests, sweepstakes, surveys, and other features offered through our Website. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes.
We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms & conditions, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of our Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.
Transaction information (including Personal Information) that you have provided to us will only be shared with our third-party processors in order to initiate and complete any orders placed on or through your account. All credit card transactions and such are processed with industry-standard encryption through third party processors who only use your financial information and Personal Information for that purpose. All financial data and related Personal Information will not be shared by us with third parties except with your authorization or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions, and policies of a third party. All such information provided to a third party is subject to their terms and conditions.
Transfers of Your Personal Information to Other Countries
By using the Website, you understand and accept the transfer of information that we collect about you, including Personal Information, to any country in which we, members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) or our service providers are located.
Retention of Personal Information
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where permissible, we will also delete your personal data upon your request. Information on how to make a deletion request can be found under “Your Rights Related to Your Personal Information”.
If you have questions about our data retention practices, please send us an e-mail at firstname.lastname@example.org.
The period for which we keep your Personal Information that is necessary for compliance and legal enforcement purposes varies and depends on the nature of our legal obligations and claims in the individual case.
How We Protect the Security of Your Personal Information
We take appropriate security measures (including physical, electronic, and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of personal data.
You are responsible for always maintaining the secrecy of your unique password and account information. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
Your Rights Related to Your Personal Information
Subject to local law, you have certain rights regarding the Personal Information we collect, use, or disclose and that is related to you, including the right:
- to receive information concerning the Personal Information we hold about you and how such Personal Information is used (right to access);
- to rectify inaccurate Personal Information concerning you (right to data rectification);
- to delete/erase your Personal Information (right to erasure/deletion, “right to be forgotten”);
- to receive the Personal Information provided by you in a structured, commonly used, and machine-readable format and to transmit those Personal Information to another data controller (right to data portability)
- to object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object); and
- in some cases, to restrict our use of your Personal Information (right to restriction of processing);
- to withdraw your consent at any time where our processing is based on consent (right to withdrawal of consent).
If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of our Website and our services.
Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricably linked to the use of certain Personal Information (e.g., your e-mail address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.
California Rights and Choices/p>
The California Consumer Privacy Act (“CCPA”) provides you certain rights in relation to your personal information:
- Right to Know: You have the right to request that we disclose certain information about our processing of your personal information over the past 12 months, including the specific pieces of information we processed.
- Right to Request Deletion: You have the right to request that we delete any of your personal information we processed from you and retained, subject to certain exceptions set forth in the CCPA.
- Right to Non-Discrimination for the Exercise of Your Rights: We will not discriminate against you because you have exercised any of your rights under the CCPA.
To exercise the rights described above, please use the buttons at the bottom of this page or email us at email@example.com with the email subject line “CCPA Request.” In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.
You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.
We disclose certain categories of California residents’ personal information for our business purposes, as described in the section above titled “Disclosure of Your Personal Information”.
Resident’s Rights – Jurisdictions in the United States, Where Applicable
We do not sell, trade, or exchange your Personal Information with anyone for money.
Notice to Law Enforcement
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:
The document(s) is uploaded, and all required fields have been filed out adequately on our platform for Legal Service Process located at:
The document(s) you are serving is correctly issued by a valid court of law or equivalent legal or administrative authority to us (See Website’s footer to find our operating entity);
The document(s) is also sent by mail at the following address:
195-197 Old Nicosia-Limassol Road,
Block 1 Dali Industrial Zone, Cyprus 2540
We reserve the right to refuse online service through our Website, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
No Rights of Third Parties
Our Policy Towards Minors
Our Website is not directed to persons under the age of eighteen (18) or the applicable age of majority in the jurisdiction from which the Website is accessed and we do not knowingly collect Personal Information from minors. If you become aware that your child has provided us with Personal Information, please contact us at firstname.lastname@example.org or at email@example.com. If we become aware that a minor has provided us with Personal Information, we take steps to remove such information and terminate that person’s account.
No Error Free Performance
You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.
Our Data Protection Officer can be contacted at the following email address firstname.lastname@example.org.