Last updated [23.06.2022]
It is of utmost importance to read the Policy provided herein in tandem with our Terms of Service to better grasp the key terms provided and explained therein.
This document contains a section dedicated to Brazilian Users and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.
1. Data Controller
Metavest Limited is a data controller (“Controller”) for any and all data processing that occurs through accessing the Application
1.1 Further Contact Details
Should you have any questions, or should you wish to claim your rights in one of the named cases, please get in touch with us. Our contact details are as follows,
|Name of the company||Metavest Limited|
|Postal address of the company||Trinity Chambers, Road Town, Tortola British Virgin Islands|
|DPO Officer and/or EU Representative||Resat Ugur Ulu|
2.1 Personal Information
Any information that makes it possible for any other person to identify an individual to whom the data relates to.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
2.3 Data Subject
A natural person who can be identified or rendered identifiable through the personal data related to.
2.4 Data Controller
The natural or legal person, who determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application.
2.5 Data Processor
The General Data Protection Regulation, signed into law on May 25, 2018, by the European Union.
The California Consumer Privacy Act of 2018, signed into law on June 28, 2018 by the State of California
2.8 This Application
The means by which the Personal Data of the User is collected and processed.
2.9 Third Party
Any other natural or legal person that is not part of Metavest.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
2.11 European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker indicates any technology - e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
2.14 Personal Information Breach
A breach of security whether accidental or on purpose, resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.
3. Your Personal Information
3.1 Personal Information You Provide to Us
The Personal Information (e.g., email address, phone number, bank account and/or payment card details, first name, last name, any and all details about payments from you and other related details thereto, account password) may be collected when you create an account, use our App, provide us with your feedback, purchase our services, contact us or request technical support services.
3.2 Personal Information Collected by Us
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. Among the types of Personal Data that this Application collects, by itself or through third parties, there are: User Feedback, Log and Usage Information, Technical Information, Profile Information. In cases where a Third Party uses our cookies, we may also receive Personal Information therefrom. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
The Types of Personal Information we collect includes:
- - User Feedback. Feedback when prompted automatically by the Application.
- - Log and Usage Information. Log and usage information is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, language preferences and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
- - Technical Information: We collect technical information such as device and browser type you use to access the Services, time zone settings, and version, operating system, and platform (collectively “Cookie Information”). Depending on the device used, this device data may include information such as your Internet Protocol (IP) address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
- - Profile Information. Password preferences and how you contact our User Services.
Personal Information may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
3.3 How Your Personal Information is Processed
Your Personal Information either given to or collected by us shall only be processed, when necessary, to do so we may refer to reasons (“Processing Reasons”) and a limited number of legal reasons (“Legal Basis”) associated therewith.
The Controller may process your Personal Information for the following Processing Reasons:
- - Creation and account (First Name, Last Name, Email Address, Password)
- - Processing the payment (Payment Card Details)
- - In the event of dispute (First Name, Last Name, Email Address, Payment History, IP Address)
- - Accessing the App (IP Address)
- - Improvement of the App (User Feedback, Password, Use of the App, IP Address, Cookie Information)
The Controller may process your Personal Information if one of the following Legal Basis applies:
- - to form the contract that we are entering or perform the contract that have entered with you,
- - to comply with legal and/or regulatory obligations when required by the law, and
- - when it is necessary for our legitimate interests given that your fundamental rights and interests are not violated.
We rely on your informed consent to contact our Users regarding Promotions based on a number of data including without limitation, Technical Information, Usage Information, User Feedback and Transaction Information.
We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings. Withdrawing your consent to opt-in (“opt-out”) to our marketing and promotions services and third-party marketing services shall mean your exclusion from our personalized content and that of third-party marketing services.
In any case, the Controller will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
3.4 Third Party Services
The Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. On the other hand, we may share your Personal Information only when your explicit and informed consent is acquired to do so. Your Personal Information that may be disclosed or under the circumstances during which your Personal Information may be disclosed without your explicit consent.
The Personal Information 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 Controller, in some cases, the Personal Information 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 the Controller. We may share information in specific situations described in this section and/or with the following third parties. We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Law Enforcement and other Judiciary Authorities. We may be compelled to disclose your Personal Information when required by the law including without limitation legal claims, legal investigations, lawful requests or legal processes.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
Offer Wall. Our Application(s) may display a third-party hosted 'offer wall'. Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to Users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.
3.6 Additional Information for EU or UK Users
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. Any and all references to Personal Information in this Policy shall be read as “Personal Data” under GDPR.
3.7 Legal Bases
As such, we may rely on the following legal bases to process your personal information:
- - Consent. We may process your information if you have given us permission (i.e., consent) to use your Personal Data in accordance with our Processing Reasons via an opt-in mechanism. You can withdraw your consent at any time.
- - Entering into a contract. We may process your Personal Data such that we can enter into a contract to provide you access to our App, i.e., signing up for an account.
- - Performance of a Contract. We may process your Personal Data such that we can honor our obligations arising out of the contract between you and us, i.e. providing you with a Persona.
- - Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your Personal Data for the security concerns or development of the App, i.e., your transaction history
- - Legal Obligations. We may process your Personal Data because of our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
3.8 Data Transfers
The Data is processed at the Controller's operating offices and in any other places where the parties involved in the processing are located. We shall always protect your Personal Information regardless of where processing takes place.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Controller to safeguard their Data.
If we transfer your Personal Information out of the European Economic Area, we shall ensure the safety and security of your Personal Information and in cases where we are required to comply with different sets of regulations concerning your Personal Information, we shall do so.
3.9 Retention Time
.Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. In determining retention time, we consider the nature, amount, the potential risks associated with in case of Personal Data Breach, our processing reasons and whether or not such reasons can be achieved in a different manner.
We keep your Personal Data for different amounts of time and by exercising your right to access, you can learn in detail our data retention policy
The Controller may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
4.1 What Are Cookies
Cookies set by the website Controller (in this case, Metavest) are called "first party cookies". Cookies set by parties other than the website Controller are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g., like advertising, interactive content, and analytics).
Cookies are small text, image, data files which asks permission to be placed on your device by websites that you visit or access. We use first- and third-party cookies for a variety of reasons detailed below. They are widely used to make websites work and function with greater efficiency, provide customization and improve website performance. Some Cookies stay on your device only for the duration of your web session and expire when you exit your browser; other Cookies remain longer than your web session, including after you exit your browser, for example, to remember you when you return to the website.
The table below explains the categories of Cookies that Metavest and our third-party partners use. Depending on your jurisdiction, we get permission before we set certain cookies, and you can always prevent Metavest from setting cookies that are not necessary for the performance of the Metavest service.
4.3 How to Control Cookies
Except for strictly necessary cookies, you can accept or decline categories or individual cookies at any time by visiting our cookie management tool at the footer of this site.
You can also control cookies by adjusting the settings within your internet browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
4.4 The Cookies We Set
- - Account related cookies
- - Login related cookies
- - Forms related cookies
- - When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
4.5 Third Party Cookies
- This site uses Google Analytics which is one of the most widespread and
trusted analytics solution on the web for helping us to understand how you
use the site and ways that we can improve your experience. These cookies may
track things such as how long you spend on the site and the pages that you
visit so we can continue to produce engaging content.
For more information on Google Analytics cookies, see the official Google Analytics page.
- - Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.
- - As we sell products it's important for us to understand statistics about how many of the visitors to our site actually make a purchase and as such this is the kind of data that these cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible price.
- - Several partners advertise on our behalf and affiliate tracking cookies simply allow us to see if our customers have come to the site through one of our partner sites so that we can credit them appropriately and where applicable allow our affiliate partners to provide any bonus that they may provide you for making a purchase.
4.6 More Information
Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren't sure whether you need or not it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.
However, if you are still looking for more information then you can contact us through one of our preferred contact methods:
- - Email: firstname.lastname@example.org
5. Rights of Users
Users may exercise certain rights regarding their Personal Information processed by the Controller.
5.1 Additional Information for European Union Users
The rights under the GDPR for our Users who are European Union Citizens are listed below,
- - Right to be informed. Providing you with clear and concise information about company, personal data of Data Subject collected by or given to Data Controller
- - Right of access. Data Subject’s request to learn their Personal Data collected by or given to Data Controller (“subject access”)
- - Right of rectification. Data Subject request to rectify or complete, if incomplete, your Personal Data in relation with Art. 5 (1)(d) of GDPR
- - Right to erasure. Your request to have your Personal Data erased (“the right to be forgotten”)
- - Right to restrict processing. Your request to limit the way your Personal Data is used
- - Right to data portability. Your request to receive your Personal Data in a machine-readable format and/or request us to transfer your Personal Data to another Controller
- - Right to objects. Your request for us to stop processing your Personal Data
- - Rights in relation to automated decision making. In the cases where we process your Personal Data via automated decision making (where no human is involved, i.e., sending you personalized marketing offers based on your Transaction Information), you may request us to stop doing so.
Unless extenuating circumstances apply, we shall respond to your requests in one calendar month after your request has reached us, and we shall do so free of charge notwithstanding extraordinary efforts on our part. In cases where we take longer due to the number of requests, we shall notify you and keep you updated of the process.
We may also need identity-proving documentation on your part such that we can verify the identity of the requester, we may also contact you about your request in order for us to hasten the process.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.
5.2 How to exercise these rights
Any requests to exercise User rights can be directed to the Controller through the contact details provided in this document. You may send us your request using your above-mentioned rights, together with documents providing your identity and the scope of your request. These requests can be exercised free of charge and will be addressed by the Controller as early as possible and always within one month.
6. Information for Users residing in Brazil
This part of the document uses the term “personal information“as it is defined in the Lei Geral de Proteção de Dados (LGPD).
6.1 The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- - your consent to the relevant processing activities;
- - compliance with a legal or regulatory obligation that lies with us;
- - the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- - studies conducted by research entities, preferably carried out on anonymized personal information;
- - the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- - the exercising of our rights in judicial, administrative or arbitration procedures;
- - protection or physical safety of yourself or a third party;
- - the protection of health – in procedures carried out by health entities or professionals;
- - our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- - credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
6.2 Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
6.3 Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests.
6.4 Your Brazilian privacy rights
You have the right to:
- - obtain confirmation of the existence of processing activities on your personal information;
- - access to your personal information;
- - have incomplete, inaccurate or outdated personal information rectified;
- - obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- - obtain information on the possibility to provide or deny your consent and the consequences thereof;
- - obtain information about the third parties with whom we share your personal information;
- - obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- - obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- - revoke your consent at any time;
- - lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- - oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- - request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- - request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
6.5 How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
6.6 How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.
6.7 Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- - when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- - when the transfer is necessary to protect your life or physical security or those of a third party;
- - when the transfer is authorized by the ANPD;
- - when the transfer results from a commitment undertaken in an international cooperation agreement;
- - when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- - when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.