Privacy Policy

Data Controller and Owner

This Application collects some Personal Data from its Users.

Elumina trades under eSparkle OÜ,
Lõõtsa tn 5-11,
11415, Tallinn, Estonia.


Types of
Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookie, Usage data, Email address, Password, First Name, Last Name and Email.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.

The Personal Data may be freely provided by the User, or collected automatically when using this Application.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.

Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.


Mode and place of
processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take 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 the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (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 the Owner. The updated list of these parties may be requested from the Data Controller at any time.

PLACE

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

RETENTION TIME

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics, Contacting the User, Interaction with external social networks and platforms, Registration and authentication, Access to third party services’ accounts, Handling payments, Interaction with support and feedback platforms, Infrastructure monitoring, Traffic optimization and distribution, Interaction with live chat platforms, Remarketing and Behavioral Targeting, Managing contacts and sending messages, Displaying content from external platforms, Commercial affiliation and Heat mapping.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.


THE USE OF THE
COLLECTED DATA

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics, Contacting the User, Interaction with external social networks and platforms, Registration and authentication, Access to third party services’ accounts, Handling payments, Interaction with support and feedback platforms, Infrastructure monitoring, Traffic optimization and distribution, Interaction with live chat platforms, Remarketing and Behavioral Targeting, Managing contacts and sending messages, Displaying content from external platforms, Commercial affiliation and Heat mapping.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Comments & Reviews

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.
Place of processing: USA – Privacy PolicyOpt Out

Google AdWords conversion tracking (Google)

Google AdWords conversion tracking is an analytics service provided by Google, Inc. that connects data from the Google AdWords advertising network with actions performed on this Application.

Personal Data collected: Cookie and Usage data.
Place of processing : USA – Privacy Policy

Contacting the User

Contact forms (This Application)

When visitors send a message using any contact form on the site we collect the data shown in the contact form, and also the visitor’s IP address and browser user agent string to help spam detection. We will also use the your data to communicate with you in the context of your message.

Personal Data collected: email address and name.

Mailing List or Newsletter (Sendinblue)

Sendinblue is an email address management and message sending service provided by Sendinblue SAS. By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

Personal Data collected: Cookie and Email address.
Place of processing: France – Privacy Policy

Displaying content from external platforms

These services allow you to view content hosted on external platforms directly from the pages of this Application and interact with them.
If a service of this kind is installed, it may still collect web traffic data for the pages where the service is installed, even when users do not use it.

Youtube video widget (Google)

Youtube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data collected: Cookie and Usage data.
Place of processing : USA – Privacy Policy

Handling payments

Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments using their PayPal credentials. Personal Data collected: Various types of Data as specified in the privacy policy of the service. Privacy Policy

Stripe (Stripe, Inc.)

Stripe is a payment service provided by Stripe, Inc., which allows Users to make online payments using their credentials. Personal Data collected: Various types of Data as specified in the privacy policy of the service. Privacy Policy

Interaction with live chat platforms

These services allow Users to interact with third party live chat platforms directly from the pages of this Application, for contacting and being contacted by this Application support service.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Managing contacts and sending messages

These services make it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.


Additional information about
Data collection and processing

We don’t sell or rent Users’ Data to any third parties for any purpose. The only uses of Data are those highlighted in this policy. Users are the only owner of their Data and can request modification or deletion at any time.

Legal action

The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System Logs and Maintenance

For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System Logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above. This Application does not support “Do Not Track” requests.

To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller removes the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.


Definitions and
legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application ), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.

Cookie

Small piece of data stored in the User’s device.

Email

Provides access to the user’s primary email address


Legal information

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

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


Latest update: Feb 20, 2020