Privacy policy

EFFECTIVE DATE: March 1st, 2023

LAST UPDATE: September 18th, 2024

Definitions

The term "personal data" means any information by which a natural person can be identified, directly or indirectly.

The term "data controller" means the natural or legal person which, alone or jointly with others, determines the purposes and means of the data processing and is responsible for processing such data in a manner consistent with the applicable legislation.

The term "data processor" means the natural or legal person which processes personal data on behalf of a data controller.

Calimero Network Group companies, hereinafter “we” or Calimero, (Calimero Limited and Calimero Trading Limited, Kalimera Consulting d.o.o.) are joint data controllers of your personal data based on joint controllership agreement between affiliated companies.

Information Sharing and Usage

When you use our online services (our website and platform available on: https://www.calimero.network/ and its associated subdomains), you will share some information with us. We want to be transparent with the data we collect, how we use it, whom we share it with, and the controls we give you to access, update, and delete your information.

Categories Explained

When you interact with our services, we collect information that you provide to us. For example, most of our services require you to set up an account, so we might need to collect a few important details about you, such as your IP address, from which we may conclude information about your usage of services. This however is not a general practice, but might be required from specific users for testing purposes. We may also request to ask your personal or business address to ensure the timely and effective provision of our services.

Other services, such as commerce products, may require you to provide us with a debit or credit card number and its associated account information, such as IP address of your device, purchases, phone number and billing/delivery address.

When you contact customer support or communicate with us in any other way, we’ll collect whatever information you provide or that we need to resolve your question/issue.

Information We Get When You Use Our Services

When you use our services, we collect information about which of those services you’ve used and how you’ve used them.

We collect information about your activity through our services. For example, we may collect information about how you interact with our services, such as number of console users and number of transactions and overall performance analytics.

While the online services are running, we might use following information for monitoring purposes:

• information about your hardware and software, such as the hardware model, operating system version, device memory, browser type, language, battery level, and time zone;
• information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address, and signal strength.

This information is not collected or stored on our servers.

Log Information

We also might collect log information when you use our website, such as:

• details about how you’ve used our services;
• device information, such as your web browser type, operating system and language;
• access times;
• pages viewed;
• IP address;
• identifiers associated with cookies or other technologies that may uniquely identify your device or browser; and pages you visited before or after navigating to our website.

How We Use Information

What do we do with the information we collect:

• Develop, operate, improve, deliver, maintain, and protect our products and services.
• Send you communications, including by email. For example, we may use email to respond to support inquiries or to share information about our products, services, and promotional offers that we think may interest you.
• We process data regarding opening e-mails, bounce rate, clicks, subscription, news segments. We may segment our clients according to previously used online services, and country.
• If you contact us through webforms on our website, through an e-mail, phone, or social network profile we will process data from contact form and a message based on our legitimate interest to connect and communicate with potential customers.
• We process data about our contacts on social networks and about likes, comments, profile information, picture, video, voice, and about similar communication with our customers and potential customers.
• Monitor and analyze trends and usage.
• Personalize our services.
• Enhance the safety and security of our products and services.
• Verify your identity and prevent fraud or other unauthorized or illegal activity.
• Use information we’ve collected from cookies and other technology to enhance our services and your experience with them.
• Enforce our Terms of Service and other usage policies and comply with legal requirements.
• Perform daily business activities, such as, planning, controlling, auditing, organizing business processes in all our affiliated companies and maintain compliance with applicable laws.

Cookies

Cookies are small text files that we place on your device (e.g. computer or mobile device) when you visit our website. We will always ask your consent to set cookies e.g., to remember your preferences or personalize content that is more relevant to you. However, we won’t ask your consent for cookies that are strictly necessary for specific functionalities of our services, i.e. without which you wouldn’t be able to undertake certain activities.

In addition, we also use temporary cookies that are stored on your end device for a specified period of time to optimize user-friendliness. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what entries and settings you have made so that you do not have to enter them again.

Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information. Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Managing Cookies

When you first visit our website, you will see our Cookie Declaration/Banner where you can accept all the cookies or manage your cookie settings. You can withdraw your consent at any time.

Information about procedure on how to enable, disable or remove cookies can be found on your Internet browser provider's website via your help screen. If you wish to learn more on this matter, we invite you to visit the following address: https://www.youronlinechoices.com.

Links to popular browsers are listed below for your convenience. Some of the listed browsers block third party cookies by default. For other browsers, please consult your browser settings for managing cookies.

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

We use third party cookies to optimize marketing performance and to measure the effectiveness of our advertising on other websites and social networks.

Pixel Tags/Web Beacons

A pixel tag (also known as a web beacon) is a piece of code embedded in our services that collects information about engagement on our services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

For more details regarding privacy and personal data protection on social networks, please read:

• TWITTER Manage Cookies with Your Ad Choices
• LINKEDIN Manage cookies with LinkedIn Ad Settings
• TELEGRAM Account settings

How We Share Information/Data

We may share information about you, your personal data, in the following ways:

With all Calimero users, our business partners, and the public

We share the following information with all Calimero user as well as with our business partners and the public:

• public information, for example your wallet public address or username.

With third parties:

• With affiliated companies for commercial and financial activities and on the basis of purposes that are in connection with the selection, entering into, handling and performance of trading or contractual relationships, for the administrative management of the agreements including for handling payments and invoices, for the receipt of goods and/or services, for handling litigation (if existing), for the purposes of internal group reporting, for internal audit purposes and for the management control purposes.
• We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the website in a shared location, and type of the device used to visit the website. They may aggregate information about our advertising and what you see on the website and then provide auditing, research and reporting for us and our advertisers.
• Calimero uses RevolutPeople, an application developed by Revolut Ltd. (in further text RevolutPeople), as part of our selection process. RevolutPeople, acting as a data processor, processes all personal data at our request and based on our instructions. Calimero and RevolutPeople have signed a Contract of personal data processing to secure and protect your right to data privacy. Calimero receives applications from job candidates, and for this purpose, the personal data of job candidates that the candidate voluntarily provided in the application and CV (name, surname, date of birth, contact information, previous work experience, professional qualifications, education, photo, IP address, web browser information, cookies that help us track how you use the RevolutPeople web) are processed. Depending on the workplace, Calimero also conducts professional and psychological tests and interviews for the selection of job candidates. The data is kept until the final end of the selection process, and no longer than two years from the end of the selection process, and consent is requested from candidates whose data we want to keep for another selection process. Participation in the selection process is voluntary, and candidate data is processed as pre-contractual actions that precede the conclusion of an employment contract. If an individual candidate has given his consent for the data to be stored even after the selection process is over, the data is stored for a maximum of two years. Candidates who have voluntarily provided their information for future selection processes can withdraw their consent at any time without negative consequences. Withdrawal of consent does not affect the legality of the processing until the moment of withdrawal. The collected data will be used solely for the selection process. This process may include the following: verification of the entered data, reference checks, assessment of the qualifications and skills needed to perform the job you are applying for, communication concerning the process (e-mails, phone calls, SMS messages, WhatsApp), filling out questionnaires and tests, fulfilling legal regulations, to consider your application in respect of a role for which you have applied, to consider your application in respect of other roles and to help RevolutPeople improve their services. The data is stored within the European Union, and access to it is secured with the highest level of technical standards and practices. Only authorized persons have access to job candidate data.

We share information about you for legal, safety, and security reasons

We may share information about you if we reasonably believe that disclosing the information is needed to:

• investigate, remedy, or enforce potential terms of service violations.
• protect the rights, property, or safety of us, our users, or others.
• detect and resolve any fraud or security concerns.

We may share information about you as part of a merger or acquisition

If Calimero companies get involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.

We may also share with third parties that provide services to us or perform business purposes for us aggregated, non-personally identifiable, or de-identified information.

We process personal data for marketing purposes

When you subscribe to our newsletter, or you purchase our products. For this purpose, we process data, such as, name, surname, country, email address and we send our newsletter by using Sendgrid services.

Data Retention

We store your basic account information—like your wallet identification number. Keep in mind that, while our systems are designed to carry out our deletion practices automatically, we cannot promise that deletion will occur within a specific timeframe. We will keep your profile information for several months after the deletion, as a deactivated account. There may be legal requirements to store your data for a longer period and we may need to suspend those deletion practices if we receive valid legal process asking us to preserve content, if we receive reports of abuse or other terms of service violations, or if your account or content created by you is flagged by our automated systems for abuse or other terms of service violations. After these timeframes, your personal data will be deleted or anonymised.

In any case you can object to direct marketing activities, and you may unsubscribe from our newsletter by clicking the link in our email or responding to us with your claim. In such case we will stop with marketing activities and store your data in an unsubscribed list for three years from the day of unsubscribing, based on our legitimate interest to prove facts on compliance steps we need to take.

Finally, we may also retain certain information in backup for a limited period or as required by law and for security reasons.

Control Over Your Information/Data

We want you to be in control of your information, so we provide you with the following tools:

Access, Correction, and Portability

Because your privacy is important to us, we will ask you to verify your identity or provide additional information before we let you access or update your personal information. We may also reject your request to access or update your personal information for several reasons, including, for example, if the request risks the privacy of other users or is unlawful.

Revoking permissions

In most cases, if you let us use your information, you can simply revoke your permission by changing the settings. Of course, if you do that, certain services may lose full functionality.

Deletion

While we hope you will remain a Calimero user, if for some reason you ever want to delete your account, it is possible to do so through the website. In any case you can object to our direct marketing activities, and you may unsubscribe from our newsletter by clicking the link in our email or responding to us with your claim. In such case we will stop with marketing activities and store your data in an unsubscribed list for three years from the day of unsubscribing, based on our legitimate interest to prove facts on compliance steps we need to take.

You can request us to confirm whether personal data concerning you is being processed by us at any moment, as well as request from us to clarify the purposes for which the personal data are processed; the categories of personal data being processed; the recipients or categories of recipients to whom the personal data concerning you have been or are still being disclosed; any available information on the origin of the data if the personal data are not collected from you as the data subject.

Security

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. While processing personal data, we conduct necessary technical and organizational measures. We engage appropriate data processors, and we analyze risk in case of a data breach. If a data breach results in high risk, we will notify relevant data protection authority and data subject. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

While this Website may include links to third-party websites, plug-ins and applications, linking to a third-party site does not necessarily mean that we endorse the site, any products or services described on the site, or any other material contained in a third-party site. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites' content, any use of the sites, or the privacy practices of the sites. 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 Policy, so please review the Privacy Policy on those other websites to see how they handle your information.

Supplemental Notice for California Residents

The California Consumer Privacy Act (“CCPA”), which is effective as of January 1, 2020, regulates how we handle personal data of California residents and gives California residents certain rights with respect to their personal data. This supplemental privacy policy shall apply only to residents of California and may be subject to change.

The general Privacy Policy shall continue to apply to the extent that it applies to you as a resident of California. If you are a resident of California, we are required to disclose certain uses and disclosures in a certain format, as well as to inform you of certain rights you may have. Any term used in this supplemental privacy policy shall have the same meaning as in the general privacy policy.

The CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail above, the categories of personal information that we have collected – as described by the CCPA – are:

• Identifiers, including name, email address, IP address, and an ID or number assigned to your account.
• Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)) and overlaps with other categories listed here.
• Demographics, such as your age or gender, or, where you have provided such information to voluntarily. This category includes data that may qualify as protected classifications under other California or federal laws.
• Commercial information, including purchases and engagement with our services.
• Internet activity, including your interactions with our services.
• Inferences, including information about orders, interests, preferences, and favorites.

We collect and use these categories of personal information for our business and commercial purposes that are previously described, including planning and organizing business activities between affiliated companies, providing and improving our services, maintaining the safety and security of our services, processing purchase and sale transactions, and for advertising and marketing services. We share personal data as described above under Sharing data with third parties.

Category of Personal Information

Purpose of Sub-processing:

• Identifiers - A name, alias, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
  • Affiliated companies
  • Advertising networks
  • Communication service providers
  • Data analytics providers
  • Service providers
  • Social networks
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) - A name, signature, contact information, bank account number, public address/wallet or any other financial information
  • Affiliated companies
  • Service providers
• Protected classification characteristics under California or federal law - A name, contact (email)
  • Service providers
• Internet or other electronic network activity - Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
  • Advertising networks
  • Data analytics providers
  • Affiliated companies
  • Service providers
  • Social networks
• Geolocation data - Physical location (over IP) or movements.
  • Affiliated companies
  • Advertising networks
  • Data analytics providers
• Inferences drawn from other personal information to create a profile about a consumer - Profile reflecting a consumer's preferences, behavior on website
  • Affiliated companies
  • Advertising networks
  • Data analytics providers
  • Service providers
  • Social networks

We may access, preserve, and disclose each of the categories listed above to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

“Sales” of Personal Information under the CCPA

For the purposes of the CCPA, we do not "sell" personal information, nor do we "sell" personal information of minors.

To opt-out of receiving interest-based advertising, you can exercise your choice by using your privacy settings.

Additional Privacy Rights for California Residents

Non-Discrimination: California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent: Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us.

Verification: To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include contact information. We will only ask for the minimum data and only what is relevant in the given context.

Rights of Access, Deletion, Correction, and Portability

You can exercise your rights of access, deletion, correction, and portability as described in the Control Over Your Information section above. You also have the right to object to data processing and right not to be subject to a decision, which may include a measure, evaluating personal aspects relating to you which is based solely on automated processing, and which produces legal effects concerning you.

You also have the right to lodge an appeal to your data protection authority.

Bases for Processing Personal Data

We process your personal data when certain conditions apply. These conditions are called "legal bases" and we typically rely on one of four:

Contract

One reason we might use your personal data is because you've entered into an agreement with us. For example, when you buy our service and accept our terms of service, we need to use some of your personal data to collect payment and provide the service. If you do not wish to provide your personal data, we will not be able to enter into an agreement with you.

Legitimate Interest

Another reason we might use your information is because we have—or a third party has—a legitimate interest in doing so. For example, we need to use your personal data to provide and improve our services, including protecting your account, communicate with you electronically, and providing customer support. An important point to understand about legitimate interest is that our interests do not outweigh your right to data protection and privacy, so we only rely on legitimate interest when we think the way we are using your data does not significantly impact your right to personal data protection and right to privacy or would be expected by you, or there is a compelling reason to do so.

Consent

In some cases, we will ask for consent to use your personal data for specific purposes, for example we ask for the consent for sending our newsletter.

If we ask for the consent, we will make sure you can revoke your consent in our services or through your device permissions. Even if we are not relying on consent to use your personal data, we may ask you for permission to access data like contacts and location.

Legal Obligation

We may be required to use your personal data to comply with the law, like when we respond to valid legal process or need to take action to protect our users. For example, when we issue an invoice or place a cookie banner on our website, we do that because we are legally obliged to do so.

Your Right to Object

You have the right to object to our processing of your personal data. With many types of personal data, we have provided you with the ability to simply delete it if you do not want us processing it anymore. For example, you always have the right to object to our legitimate interest for performing direct marketing activities and you always have the right to withdraw your consent.

For other types of data, we have given you the ability to stop the use of your data by disabling the feature altogether. If there are other types of personal data you don’t agree with us processing, you can contact us.

You also have the right to lodge a complaint to supervisory data protection authority (in the UK the Information Commissioner's Office (ICO)).

If you have exercised your right to have us correct, delete or limit the processing, we are obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction on processing, unless this proves impossible or involves a disproportionate effort.

You have a right of rectification and/or completion if the personal data processed concerning you are incorrect or incomplete. We shall make the correction promptly.

International Transfers

We may collect your personal data from, transfer it to, and store and process it in other countries outside of where you live.

We are based in the UK. Therefore, we process and store information on servers in the UK and servers located in the EU. We may also store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. These data transfers allow us to provide our services to you. By accessing or using our services or otherwise providing information to us, you understand that your information will be processed, transferred, and stored in the UK and other countries, where different data protection standards may apply.

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and the UK’s Information Commissioner's Office (ICO). In case data is stored on servers located in the EEA, when transferring data outside the EEA, we use standard contract clauses and additional technical and organizational measures. We rely on the European Commission's adequacy decisions about certain countries, as applicable, or other legally compliant mechanisms or conditions for such data transfer. You consent to the transfer of your information, including personal information, to countries outside the EEA as set forth in this Privacy Policy by visiting our website or using our service.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate guarantees in connection with the transmission.

Children

Our services are not intended for—and we do not direct them to—anyone under 18 years old. And that's why we do not knowingly collect personal data from anyone under 18. If we need to rely on consent as a legal basis for processing your personal data and your country requires consent from a parent or a guardian, we may require your parent's or guardian's consent before we collect and use such data. In the event that we learn that we have collected personal information from a child under age 13 without consent, we will delete that information as quickly as possible.

For this purpose, we use efforts to verify the age of the users of our services.

Revisions to the Privacy Policy

We may change this Privacy Policy from time to time. But when we do, we'll let you know one way or another. Sometimes, we'll let you know by revising the date at the top of the Privacy Policy that's available on our website and mobile application. Other times, we may provide you with additional notice (such as adding a statement to our websites' homepages or providing you with an in-app notification).

We inform registered customers about the new version of Privacy Policy, if the changes are substantial and are not only connected with the grammar, style, corrections etc. Your continued use of any portion of our sites following the updated Privacy Policy will constitute your acknowledgment of the changes.

If you have any questions about this Privacy Policy, the personal data/information we hold from you, or you would like to exercise one of your privacy and data protection rights, please do not hesitate to contact us at info@calimero.network.