We respect your privacy rights, care about Your Personal Data, and do Our best endeavors to protect it.

So we provide this Privacy Policy (can also be referred to as Policy) to explain You how we collect, manage, use and protect your Personal Data.

Please read carefully this Policy together with the Terms of Use and Cookie Policy.

Unless otherwise defined all of the terms in this Privacy Policy have the same meaning as in the Terms of Use.

About us

Operator of this service and responsible person in the sense of the General Data Protection Regulation (GDPR) is ASocks company (referred to as the “ASocks” as well as “we”, “us” etc.)

ASocks is acting as a controller of the ASocks Individual Users’ Personal Data.

For the purpose of this clause the term “Individual User” shall mean any natural person, who visits our Site and/or uses Our Services.

If You have any questions related to your privacy, please contact us:

Core principles

With this Privacy Policy we would like to inform you how we process personal data while providing you with the service. The protection of your privacy is of the utmost importance to us, which is why it goes without saying that we comply with the statutory provisions on data protection.

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING AS DESCRIBED IN THIS PRIVACY POLICY AND OUR TERMS OF USE.

Users of the Services and the Application should note that all data processing and storage, including registration, is hosted on servers in the European Union.

By agreeing to using our Services and providing information to us, you consent to the transfer to and processing of the information to us and, unless otherwise stated in this Privacy Policy, we use this consent as the legal ground for that data transfer. When collecting your Personal Data, you may be asked for your explicit consent to this data transfer as part of account creation.

Please read this Privacy Policy carefully, as your access to and use of the Services signifies that you have read, understand and agree to all terms within this Privacy Policy. If you do not agree with any part of this Privacy Policy or our Terms of Use, please do not access or continue to use any of the Services or otherwise submit your Personal Data.

What Data is Being Logged by Default

To ensure the technical functionality and presentation of our System and our Service, to clarify security incidents and to monitor technical malfunctions or attacks, we collect the standard data necessary for this. You can use all areas of our Website and the System that do not require access authorization without having to disclose any personal data.

When you visit our Website, so-called log files (activity logs) are automatically transmitted to our servers. As a general rule, this is not personal data and this information is not mixed with other data processed by us.

Log Files

  • Time and date of the page visit

  • Information about user activity and transferred data volume

  • Server Logs

We may create de-identified or anonymous data from Personal Data by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you, through anonymization or through other means. Our use of anonymized and de-identified data is not subject to this Privacy Policy.

Data Provision Stipulated or Required

The provision of Personal Data is necessary and obligatory. Without the transmission of technically necessary information the presentation and functionality of our System and Services is not guaranteed.

Additional Information

Our Services are not specifically aimed at children and teenagers under the age of 18. A transfer of personal data to us should not take place without the consent of parents. ​If we become aware that a child has submitted information to ASocks, we delete this information immediately. We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.

Our Web site or system may contain links to other websites or applications for whose content, function and compliance we are not responsible. Please inform yourself about the data protection regulations of the respective web pages with the respective operators.

Data Retention

We will retain your Personal Data for as long as you maintain an Account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

When we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.

Where permissible, we will also delete your Personal Data upon your written request to the Support Service email [email protected].

If you have questions about our data retention practices, please contact us through our Support Service.

Security

We implement appropriate technical and organizational measures to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

Legal Basis for Data Processing

The General Data Protection Regulation (GDPR) provides various legal bases on which personal data can be legally processed. We base the processing of your data on the following legal principles:

  • Your consent, if you have given us such consent (Art. 6 para. 1 lit. a) GDPR)

  • the initiation or execution of a contract with you (Art. 6 para. 1 lit. b) GDPR)

  • the fulfilment of a legal obligation (Art. 6 para. 1 lit. c) GDPR)

Storage Period of the Collected Data

We store your data,

  • if you have consented to the processing at most until you revoke your consent;

  • if we need the data for the execution of a contract, at the most as long as the contractual relationship with you exists or legal retention periods run;

  • if we use the data on the basis of a justified interest, at the most as long as your interest in deletion or anonymization does not prevail;

  • if legal (e.g. commercial code, tax code) exist, until the end of these storage obligations.

Data Sources

Along with data received from you, they will come from the following sources, which may partly be publicly accessible:

  • from your Devices

  • from Third Parties

The list of the data received:

For the User: name, surname, date of birth, phone number, email, address, date of registration in the System, first visit date, discharge date, sessions time and date, applicable language, total active System time, agreement for the newsletter receipt.

The data consisting of name, surname, and email – are the required fields mandatory for provision of the Service, the rest of the fields are optional.

Your Rights as a Data Subject

As a data subject within the meaning of the General Data Protection Regulation (GDPR), you have the right to do so:

  • to request free information about the processing of your data and to receive a copy of your personal data. You may request information on, among other things, the purposes of the processing, the categories of personal data to be processed, the recipients of the data (if disclosed), the duration of the retention or the criteria for determining the duration;

  • to correct your data. If your personal data are incomplete, you have the right to complete them, taking into account the purposes for which they are processed;

  • delete or block your data. Reasons for the existence of a cancellation/blocking claim can include, among others: a) the revocation of the consent on which the processing is based, b) the data subject objects to the processing, c) the personal data have been processed unlawfully;

  • to restrict the processing;

  • to object to the processing of your data;

  • to revoke your consent to the processing of your data for the future and

  • to complain to the competent supervisory authority about unauthorized data processing.

In Which Cases Your Data Will Be Forwarded

For the operation of our online presence, our System and our Service we cooperate with various service providers. In addition, your data will be passed on to parties that are unavoidable for the fulfilment of contractual obligations or where there is a legal obligation to pass them on.

We do not sell any Personal Data.

Services for the operation of our Application and Platform:

  • Data Storage and Server Provider

  • Service provider for development services

  • Customer support software provider

  • Email provider

Other services:

  • Payment processing tools

  • Tools for order processing

  • Receivables management

  • Call center service provider

  • Newsletter providers

  • Proofreading and translation service providers

  • Telecommunications provider

  • Postal, delivery and forwarding services

  • Service provider for bookkeeping and invoicing

  • Lawyers, auditors and tax consultants

Transfer to recipients outside the European Economic Area

Data is being transferred to countries outside the European Economic Area (EEA). We only transfer personal data to third countries where the EU Commission has confirmed an adequate level of protection or where we can ensure the careful handling of personal data through contractual agreements or other appropriate guarantees, such as certification or proven compliance with international security standards.

For the purposes of applicable data protection laws, ASocks is the controller of the Personal Data you provide to us (“Data Controller”). As a Data Controller, we process the Personal Data we maintain about you in accordance with this Privacy Policy. If you have any questions or concerns regarding the processing of your Personal Data, or if you have questions regarding this Privacy Policy, please see contact information.

For all questions regarding data protection

Should you have any questions regarding our data protection measures, the processing of your data or the protection of your rights, please contact our data protection officer as follows:

E-mail address: [email protected]

If you have a particularly sensitive concern, please contact our data protection officer by post, as communication by e-mail can always be subject to security gaps.

Consent as a Basis for Processing

In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when (i) providing us with your Personal Data through our Services; or (ii) registering or creating an account with us. Due to different countries’ laws governing consent for the collection and use of Personal Data, the requirements for consent may differ across regions.

You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding the data collection by the application and the platform, your communication settings, and app preferences. Collection and use of Personal Data are required for the Services to work properly.


Email Hosting

We use mailing service of company Intercom R&D Unlimited Company to send emails to Users and communication with Customer Support

ADDRESS: 2nd Floor, Stephen Court, 18-21 Saint Stephen’s Green, Dublin 2

PURPOSES OF USE AND DATA PROCESSING internal communications may include personal data

LINK TO THE PRIVACY POLICY OF THE SERVICE PROVIDER – https://www.intercom.com/legal/privacy

We use email hosting of company ​Mailgun Technologies Inc. to send emails to Users

ADDRESS: 548 Market Street Suite 43099 San Francisco, CA 94101 United States

PURPOSES OF USE AND DATA PROCESSING: sending letters about updating the application, informing about changes in instructions, congratulations on international holidays .

LINK TO THE PRIVACY POLICY OF THE SERVICE PROVIDER – https://www.mailgun.com/privacy-policy/

A WAY TO OBJECT PROCESSING if you would like to delete your account, you can do this by contacting us, however in such case we cannot grant further service.

Making contact

We may provide email addresses or forms to which visitors can send us questions or comments, or which visitors can use to request customer support. In the process of receiving and responding to such requests, we may collect personal information about you, such as your e-mail address or any other personal data contained in the body of your email message. By allowing you to send us these requests, we are not attempting to solicit personal information from you.

We only use the information for the purpose of responding to your questions and/or comments or to provide customer support. Copies of your requests may be kept on file for our records, for quality control purposes, or to provide ongoing support services you have requested. If we have actual knowledge that the person with whom we’re communicating is a child under the age of sixteen (or older, if applicable law provides for different protections), we delete the child’s e-mail address and message immediately after responding.

Subscription to the Newsletter


We use the service Messenger of company ​Telegram Messenger LLP​, to communicate within the clients. ADDRESS: ​71-75 Shelton Street Covent Garden London United Kingdom

PURPOSES OF USE AND DATA PROCESSING internal text and voice communications that do not include any personal data

LINK TO THE PRIVACY POLICY OF THE SERVICE PROVIDER ​https://telegram.org/privacy

A WAY TO OBJECT PROCESSING if you would like to delete your account, you can do this on the ​deactivation page​. Deleting your account removes all messages, media, contacts and every other piece of data you store in the Telegram cloud. This action must be confirmed via your Telegram account and cannot be undone.

We use service Messenger of company ​Intercom R&D Unlimited Company to provide the Users with the possibility of communication with Customer Support

ADDRESS: 2nd Floor, Stephen Court, 18-21 Saint Stephen’s Green, Dublin 2

PURPOSES OF USE AND DATA PROCESSING internal communications may include personal data

LINK TO THE PRIVACY POLICY OF THE SERVICE PROVIDER – https://www.intercom.com/legal/privacy

We use service for Product Intelligence of company ​Amplitude, Inc. to provide the Users with the possibility of communication with Customer Support

ADDRESS: 631 Howard Street, Floor 5San Francisco, CA 94105

PURPOSES OF USE AND DATA PROCESSING internal communications may include personal data

LINK TO THE PRIVACY POLICY OF THE SERVICE PROVIDER – https://amplitude.com/privacy

CHANGES TO THIS PRIVACY POLICY

This data protection declaration provides information on data protection in our company. If our processes change, we will adjust the information accordingly so that you can always be informed about the processing of your data.

How to exercise your rights

ASocks takes steps to keep your Personal Data accurate and up to date. If you reside in the European Economic Area, you have certain rights to the Personal Data that we have collected about you. To exercise your rights to your Personal Data, please contact us through our Support Service. We will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

You have the following rights:

Right of access to your Personal Data (Art. 15 GDPR): You have the right to ask us for confirmation on whether we are processing your Personal Data, and access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved).

Right to correction (Art. 16 GDPR): You have the right to have your Personal Data corrected, as permitted by law.

Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Personal Data, as permitted by law. This right may be exercised among other things: (i) when your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; (ii) when you withdraw consent on which processing is based according to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR and where there is no other legal ground for processing; (iii) when you object to processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or when you object to the processing pursuant to Art. 21 (2) GDPR; or, (iv) when your Personal Data has been unlawfully processed.

Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances, including: when the accuracy of your Personal Data is contested; when the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of the use of your Personal Data instead; or when you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of the Raccoon override your grounds.

Right to data portability (Art. 20 GDPR): You have the right to receive the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.

Right to object (Art. 21 GDPR): You have the right to object to our processing of your Personal Data, as permitted by law. This right is limited to processing based on Art. 6 (1) (e) or (f) GDPR, and includes profiling based on those provisions, and processing for direct marketing purposes. After which, we will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

How we may disclose your Personal Data

The GDPR and national laws of European Union member states implementing the Regulation permit the sharing of Personal Data relating to users who are residents of the European Economic Area with third parties only under certain circumstances. If you reside in the European Economic Area, we will only share your Personal Data as described in our Privacy Policy under the cl. 2.5 if we are permitted to do so under applicable European and national data protection laws and regulations.

Marketing communications

Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials or information. When required by local law, when marketing consent is obtained, we use the double-opt-in method (confirmation of your email address by email before sending you promotional messages) in order to verify your consent. You may revoke your consent at any time (this will not affect the processing of your Personal Data undertaken until the revocation). If you want to stop receiving promotional materials, etc., you can do so at any time as outlined in this Privacy Policy.

Additional use of Personal Data

Additional use of your Personal Data that is not described in this Privacy Policy will only take place as required by statute or when we have obtained your consent.

Legal Basis for Processing under the GDPR

In this section we provide information on the legal basis for our processing of your Personal Data as required by Art. 13 and 14 of the GDPR:

When you register for an account or interact with our Services, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.

With regard to other non-sensitive Personal Data, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to enhance our Services.

When you communicate with us or sign up for promotional materials, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with our promotional messages. Where we are required under applicable local law to obtain your consent for sending you marketing information, the legal basis is your consent, Art. 6(1)(a) GDPR.

With regard to other Personal Data, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to enhance your experience and to improve our Services.

When you connect with us through social media:

Where we collect your consent in such case, for instance for marketing purposes, we process such data on the basis of your prior consent, Art. 6 (1) (a) GDPR.

Where we do not collect your consent in such case, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is providing you with better Services and to enable you to use the full range of our Services (Art. 6 (1) (f) GDPR).

When we collect data from third parties or publicly-available sources:

For Personal Data which we need in order to perform the Services (e.g. for email verification purposes), such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.

With regard to other Personal Data, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is providing you with better Services and to enable you to use our Services more efficiently.

When we leverage and/or collect cookies, device IDs, Location Data, data from the environment, and other tracking technologies, we process such data on the basis of your consent, Art. 6 (1) (a) GDPR, and based on our legitimate interest, Art. 6 (1) (f) GDPR, where we do not obtain your consent and our legitimate interest is to provide you with better Services or marketing.

When we aggregate or centralize data, such processing is either necessary for the performance of our Services, Art. 6 (1) (b) GDPR, or we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with better or customized Services and marketing.

When we disclose Personal Data to our affiliates and partners, and to our service providers and vendors:

Where we collect your consent in such a case, we process such data on the basis of your prior consent, Art. 6 (1) (a) GDPR

Where we do not collect your consent in such cases, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR, or we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with better Services and marketing.

When we process or share Personal Data in the event of an actual or contemplated sale, we process such data for our legitimate interest in offering, maintaining, providing, and improving our Services, Art. 6 (1) (f) GDPR).

When we conduct analytics, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to enhance your experience and to develop and improve our Services.

When we investigate suspected illegal or wrongful activity, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to ensure compliance with legal requirements and law enforcement requests and for public safety purposes.

Right to lodge a complaint before the Data Protection Authority

We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Data relating to you infringes applicable data protection laws.

CHANGES TO THIS POLICY

We may update this Privacy Policy in future, if needed to provide the compliance with data protection laws and regulations. In such cases, We will send You a letter of notification on Your email prior to the change becoming effective. We will always use Your Personal Data in accordance with GDPR requirements and in a manner consistent with the Privacy Policy in effect at the time You submitted the information, unless You consent to the new or revised policy.

Contact Us

If You have any questions related to your privacy, please contact us:

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