Privacy Policy

1.GENERAL INFORMATION 

Multilogin Software OÜ (hereinafter “Multilogin”) respects the privacy of its users (hereinafter “user”, “you” “your”, “yours”) that use our website located at: https://www.multilogin.com, including other media forms, media channels, service, mobile website or applications related or connected thereto (collectively the “Website”). 

This privacy policy (hereinafter "Privacy Policy") describes how we collect and use the Personal Data that we receive about our users, as well as the rights of users in relation to that Personal Data, when a user visits our Website or uses our Services. It is designed to inform you as a user, about the types of information we may gather or collect about you. It is also intended to explain the conditions under which Multilogin uses and discloses that information, and your rights in relation to that information. 

Each time you use the Website, the current up-to-date version of this Privacy Policy will apply. Accordingly, each time you use our Website, you should check the date of this Privacy Policy (which appears at the end of this document) and review any changes since the last time you used our Website. 

Our Website is operated under the laws of the Republic of Estonia. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of highways of the Internet, including Personal Data collection, use and disclosure, different from our jurisdiction mentioned, may only use our Website in a manner lawful in their place of usage. If your use of our Website would be unlawful in your place of usage, please do not use our Website. 

BY USING OR ACCESSING OUR WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. 

This Website and its subdomains are operated by Multilogin. We take privacy very seriously and therefore provide our users important information about us, how and why we collect, store, use and share personal information, what are users’ rights in relation to personal information and how to contact us in the event that users need to or if we need to contact you. 

This Privacy Policy does not cover any information that we may receive about you through sources other than the use of our Website. Our Website may link out to other third-party websites or applications, but this Privacy Policy does not and will not apply to any of those third-party linked websites or applications operated by third parties. Unless one of our subdomains directly specifies having its own privacy policy, this document will apply to any of our subdomains. 

We are committed to the protection of your privacy while you use our Website. 

There are two types of information that we obtain from you online and then store and use: Personal Information and Non-Personal Information. 

By continuing to use our Website, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your information and the method of disclosure as described in this Privacy Policy. If you do not agree to our Privacy Policy, then you must immediately cease your use of our Website. Please check our Terms of Service and Cookie Policy as well in case of doubts. 

Depending on how you use our Website, you will be subject to different types of information collected and different manners of collection as described further in this document. 

1.1 WHO WE ARE AND OUR CONTACT 

 We are Multilogin. 

We collect, use and are responsible for storing certain information about you when using our Website. Our business address is registered at Supluse pst 1 - 201A, Tallinn, 11911, Republic of Estonia. You can contact us by e-mail: [email protected] 

Our Data Protection Officer is as follows: Pavel Gorohhovatski. The Data Protection Officer may be contacted at: [email protected] 

We take securing your data and preserving your privacy very seriously. We never post anything to your Facebook, Twitter, or other third-party accounts without your permission. 

2. PERSONAL INFORMATION WE COLLECT AND USE  

Personal Information is information which you can be identified from and does not include any anonymized forms of information. Personal information is the kind that you voluntarily provide to us or that is collected automatically. 

We primarily use your Personal Information to help us provide a better experience for you on our Website and to provide you our Services and/or information you may have requested, such as using some features of our Website. 

Personal Information that could be considered identifying a user may be used for the following: 

  • administering  your account; 

  • contacting you to communicate about your user account with us or regarding any question you make through the Service; 

  • improving your personal user experience; 

  • identifying you when you sign in to your account; 

  • fulfilling your subscriptions; 

  • providing you with the Services;  

  • providing customer support; 

  • advising you about updates to the Website, Software Application or related items; 

  • send you marketing communications and advertising we think you may find useful, but only in accordance with your preferences; 

  • analyzing the use of the Website, Service and the people visiting to improve our content; 

  • to check and compare a user against any imposed international, European Union or national sanctions; 

  • other purposes that we disclose to you when we request your information. 

2.1.1.Types of Personal Information 

 We may process some types of Personal Information in relation to you that is collected directly in the following circumstances: 

  • creating a user profile (information such as your full name, e-mail and postal addresses, telephone number and country of residence); 

  • your login and password details, in connection with the account sign-in process; 

  • subscribing to our Service, newsletters, uploading or submitting any material through Multilogin or requesting any information; 

  • contacting us using the chat service or other channels; 

  • e-mails or communications that you send to us (when you ask for support, report a problem, send us questions, comments, contributions to discussions, messages to other users); 

  • details of any requests or transactions you make through the Service and/or our Software Application; 

  • information about your activity on and interaction with our Website, such as your IP address and the type of device or browser you use; 

  • contact details such as billing information for subscriptions; 

  • payment method of choice for services rendered, including payment amounts, time, secure bank details such as credit card details (in order to subscribe to our Services on the Website, you will be asked to provide certain credit information, and possibly additional specific information so that you may be properly charged for the services rendered to you. This payment and billing information may be stored for the following period: 7 years. If so, it will be used exclusively to assist you with making future purchases with us and to uphold bookkeeping requirements). 

 

2.1.2.Personal Information Obtained By Use Of Cookies Or Automated Means 

We will sometimes obtain Personal Information by automated technology. This shall be by Cookies and other similar technologies.  

In brief, a cookie is a small text file which is placed onto your device when you access our Website. Similar technologies include web beacons, action tags, local shared objects and single-pixel gifs. 

On the first visit of our Website we will ask whether you consent to our use of cookies and other similar technologies. If you do not consent, Cookies and similar technologies will not be used unless they are necessary. We have to use necessary ones to keep our Website running with bare minimum functionality. You can choose to give us permission to use Cookies and similar  technologies based on consent or legitimate interest. Keep in mind that when Cookies and similar technologies are not allowed, your experience of the Website may be severely hindered and not all functions may be available or work as intended. You can set your browser to not accept Cookies. This is explained in our Cookie Policy with links to instructions of common browsers. However, be warned once more that some of our Website features may not function as a result. Please see our Cookie Policy for more information and list of Cookies with expiry dates. 

Thereafter later on you can opt-out or opt-in of using Cookies by entering “Cookie Settings” through the badge displayed on our Website. 

Personal Information that may be considered identifying may be used for improving your personal user experience; communicating with you about your use of our Service or contacting customer support; sending marketing and advertising to you, including via e-mail; fulfilling your subscriptions; providing customer support to you; advising you about updates to the Website, Service or related items. 

2.1.3.Personal Information Obtained From Third Parties 

We will sometimes obtain information about you from third party sources. These third parties may be our associates and partners and include credit and financial information from credit providers or payment authorities. Also verification of contact and identity information related to billing and usage of our Service, checks on publicly available databases for fraud prevention and money laundering detection purposes. 

We contractually prohibit our associates and affiliates from disclosing personal information received from us, other than in accordance with this policy. However, third parties are under no obligation to comply to this policy with respect to personal information that users provide directly to those third parties, or that those third parties collect themselves. These third parties include advertisers, providers of utilities, widgets and a variety of other third-party applications we may have made accessible through our Website. We neither own nor control the third-party websites and applications accessible through our Website. Thus, this policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party, or using third-party applications, whether by means of a link on our Website, directly through our Website or otherwise, and before providing any personal information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that Website or application, and should take those steps necessary to, in those users’ discretion to protect their privacy. 

 2.1.4.Personal Information for criminal, fraud and other prohibited uses prevention 

We may collect and process information in respect of any criminal offences in relation to you. Please see our Terms of Service for more details about Rules Of Conduct And Prohibited Uses. Criminal offence data which may be collected and processed in relation to you can include checks on publicly available databases to prevent possible fraud and detect money laundering, to verify your eligibility for usage of provided credit card or other payment method.  

We will use your information for fraud and money laundering prevention purposes if there is cause to believe unlawful activities on your behalf, or if there is information to suspect that unlawful activities take place by using our Website and Service. 

 Much of Personal Information related to such preventive measures is provided by users themselves when (if applicable): 

  • creating a user account/registering for our Service; 

  • logging in with social network credentials; 

  • participating in polls, contests, surveys or other features on our Website; 

  • responding to advertisements; 

  • communication with us; 

  • contributing to our blogs; 

  • signing up to receive news and offers from us. 

Such Personal Information that can be used as criminal prevention information may include user’s name, address, e-mail, phone, and if you transact business with us, financial information such as your payment method (e.g. valid credit card number, type, expiration date or other financial information). 

We also may request information about your interests and activities, your gender, age, date of birth, hometown or other demographic or relevant information as determined by us or if required to do so by laws. 

You are under no obligation to provide us with personal information of any kind, with the caveat that a user’s refusal to provide us with personal information may prevent the user from using certain features of our Website and Service. 

 Keep in mind that: 

BY USING OUR WEBSITE OR SERVICE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. 

3.NON-PERSONAL INFORMATION WE COLLECT AND USE  

Non-Personal Information is information that, without the aid of additional information, cannot be directly associated with a specific person. Like most website operators, Multilogin gathers from the users of our Website Non-Personal Information of the sort that browsers, depending on their settings, make available.  

Information that does not identify you personally, but that may assist in providing us broad overviews of our customer base, will be used for market research or marketing efforts. Such information may include, but is not limited to, interests based on your cookies. Please see our Cookie Policy for details and links to instructions about browser settings relating to our Cookies. 

 Type of information that is collected automatically from each visitor is as follows: 

  • your device operating system; 

  • time of visit; 

  • IP address of device used to visit; 

  • Cookie preferences set by user; 

  • browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. 

 This helps us determine statistical usage data and enables to non-personally understand how our Website is being used. By identifying patterns and trends of usage, we are able to better design our Website to improve users’ experience, both in terms of content and ease of use. We may release an anonymized report on the trends in the usage of our Website. 

We may share Non-Personal Information we have aggregated with third parties and our affiliates to develop and deliver targeted advertising on our Website and the websites of third parties. We may combine Non-Personal Information we collect with additional Non-Personal Information collected from other sources. We also may share aggregated information with third parties, including affiliates, advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Website and the most popular features accessed. This information does not contain any Personal Information and may be used to develop the Website content and our Service that we hope you and other users will find of interest and to target content and advertising. 

We may combine or aggregate some of your Non-Personal Information in order to better serve you and to better enhance and update our Website for your and other consumers' use. We may also share such aggregated information with our related entities as described previously. 

We will sometimes obtain Personal Information by automated technology. This shall be by Cookies and other similar technologies.  

In brief, a cookie is a small text file which is placed onto your device when you access our Website. Similar technologies include web beacons, action tags, local shared objects and single-pixel gifs. 

 On the first visit of our Website we will ask whether you consent to our use of cookies and other similar technologies. If you do not consent, Cookies and similar technologies will not be used unless they are necessary. We have to use necessary ones to keep our Website running with bare minimum functionality. You can choose to give us permission to use Cookies and similar  technologies based on consent or legitimate interest. Keep in mind that when Cookies and similar technologies are not allowed, your experience of the Website may be severely hindered and not all functions may be available or work as intended. You can set your browser to not accept Cookies. This is explained in our Cookie Policy with links to instructions of common browsers. However, be warned once more that some of our Website features may not function as a result. Please see our Cookie Policy for more information and list of Cookies with expiry dates. 

Thereafter later on you can opt-out or opt-in of using Cookies by entering “Cookie Settings” through the badge displayed on our Website. 

Personal Information that may be considered identifying may be used for improving your personal user experience; communicating with you about your use of our Service or contacting customer support; sending marketing and advertising to you, including via e-mail; fulfilling your subscriptions; providing customer support to you; advising you about updates to the Website, Service or related items. 

4.BASIS FOR PROCESSING YOUR PERSONAL INFORMATION 

The lawful basis upon which we are able to process your personal data are where: 

  • we have your consent or legitimate interests to use your data; 

  • it is necessary to enter into a legal contract with you; 

  • we must perform our duties and obligations under a legal contract with you; 

  •  it is necessary to enable us to comply with legal obligations; 

  • it is necessary to ensure our own legitimate interests or the legitimate interests of a third party, provided that your own interests and rights do not override those interests; 

  • we need to protect our own vital interests or the vital interests of another person, our partnering associate or affiliate; 

  • it is necessary for your vital interests; 

  • the processing is necessary for substantial public interest; 

  • it is necessary for employment, security or social protection and it is properly authorized by law; 

  • it is needed in the public interest or we are compelled by a clear basis; 

  • information is made publicly available by you; 

  • the processing is necessary for defending or establishing legal claims or court proceedings; 

  • the information in necessary for bookkeeping, statistical or archiving purposes. 

  •  

To sum up, in order to meet the purposes we have described above, we will process your Personal Information where it is necessary to protect our legitimate interests, and legitimate interests of others, but only where your own interests and rights do not override these interests. 

Bases applicable for criminal information are justified by lawful conditions and the processing is necessary to protect the vital interests of us and others who may have be subjected to identity theft, fraud, money-laundering and other unlawful acts. 

5.KEEPING YOUR INFORMATION SECURE 

We will ensure the proper safety and security of your Personal Information and have measures in place to do so. We use technological and organization measures to keep your information secure as we have procedures in place to deal with data processing, security breach and lawenforcement authorities. 

In order to meet those needs, we may transfer your personal information outside of the Republic of Estonia to other countries. The hosts in the recipient countries have been verified to have adequate protection in place so that the security of your Personal Information can be maintained. 

We will disclose Personal Information if required to do so by laws or to protect rights. When we believe disclosure is appropriate, we may disclose Personal Information: 

  • in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud, money-laundering or other wrongdoing; 

  • to protect and defend the rights, property or safety of us, our users, our employees and affiliates; 

  • to comply with applicable laws or with law enforcement; 

  • to enforce our Terms of Service or other agreements or policies; 

  • in response to a subpoena or investigative queries from law enforcement authorities or a court orders; 

  • to establish or exercise our legal rights; 

  • to defend against legal claims or as otherwise required by laws. 

 

In such cases, we may raise or waive any legal objection or right available to us. Our Terms of Service line out the Rules Of Conduct And Prohibited Uses

Please note, however, that no system involving the transmission of information via the highways of the Internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Information very seriously. We take all reasonable steps to protect your Personal Information. 

6.SECURITY 

We take the security of personal information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks that might emerge.  

We cannot guarantee that only authorized persons will view your Personal Information. We are not responsible for third-party circumvention of any privacy settings or security measures. We are dedicated to protect all information on our Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personal Information by keeping your password to the Software Application confidential. 

You should change your password immediately if you believe someone has gained unauthorized access to it. If you lose control of your password, you should notify customer support immediately at: [email protected] 

BY CONTINUING TO USE OUR WEBSITE IN ANY MANNER, USING OUR SOFTWARE APPLICATION AND/OR SERVICE, YOU MANIFEST YOUR CONTINUING ASSET TO THIS PRIVACY POLICY.  

YOU FURTHER ACKNOWLEDGE, AGREE AND ACCEPT THAT NO TRANSMISSION OF INFORMATION OR DATA VIA THE HIGHWAYS OF THE INTERNET IS NOT ALWAYS COMPLETELY SECURE, NO MATTER WHAT STEPS ARE TAKEN.  

YOU ACKNOWLEDGE, AGREE AND ACCEPT THAT WE DO NOT GUARANTEE OR WARRANT THE SECURITY OF ANY INFORMATION THAT YOU PROVIDE TO US, AND THAT YOU TRANSMIT SUCH INFORMATION AT YOUR OWN RISK. 

7.ENCRYPTION 

We value your personal privacy and the privacy of your business. When you access websites using the Multilogin Software Application, the Application encrypts sensitive data before sending it to our servers. Your account password is used as a private key in encryption algorithms. We encrypt the following data: 

  • session identificators stored in Cookie files; 

  • URLs of active browser tabs. 

We never store your account password on our servers. Only master password’s hash is stored on our server for login data validation purposes (this means we neither have nor can see the original password you have set). 

8.YOUR RIGHTS 

 You have number of important rights we wish you to be aware of. Those include rights to: 

  • fair processing of information and transparency over how we use your Personal Information; 

  • the right to be informed about the processing of your Personal Information as described herein; 

  • access to your Personal Information; 

  • require us to correct any mistakes in your information which we hold; 

  • require the erasure of Personal Information concerning you in certain situations; 

  • receive the Personal Information concerning you which you have provided to us; 

  • object at any time to processing of Personal Information concerning you of direct marketing; 

  • object in certain situations to our continued processing of your Personal Information or ask us to suspend the processing procedure in order for you to confirm its assurance or our reasoning for processing it; 

  • object to processing your Personal Information where we are doing so in reliance upon a legitimate interest of our own or of a third party and where you wish to rise an objection to this particular ground; 

  • in any circumstance where we rely upon your consent for processing Personal Information, you may withdraw this consent at any time. 

 For further information your rights and the circumstances in which they apply, see the Personal Data Protection Act available at: https://www.riigiteataja.ee/en/eli/523012019001/consolide and the EU General Data Protection Regulation (GDPR): Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), OJ 2016 L 119/1, available at: https://eur-lex.europa.eu/eli/reg/2016/679/oj 

If you would like to exercise any of your rights please contact our Data Protection Officer with the stated contact information in this Privacy Policy. 

If you have any queries concerning our use of your Personal Information, please e-mail our Data Protection Officer.  

Please also visit our Cookie Policy, which explains how we collect cookie related information, what we do with it and your rights in respect of it. Do not forget about our Terms of Service

In the event of a breach of your Personal Information, you will be notified in a reasonable time frame, but no later than two months from the time we become aware of such an event. We will follow all applicable laws regarding such breach. 

9.HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT 

Your Personal Information will be kept for the period of time which is necessary for us to fulfil the stated purposes in this Privacy Policy. Bookkeeping records about billing information need to be kept for seven years. 

10.CHANGING PERSONAL INFORMATION AND SUBSCRIPTION CANCELLATION 

If you wish to modify or delete any Personal Information we may have about you, or you wish to simply access any information we have about you, you may do so. You may at any time renew or change your Personal Information by e-mailing our Data Protection Officer at: [email protected] 

Upon your request, we will deactivate or delete your Personal Information, unless we have to keep it by law (e.g. bookkeeping records for Tax authorities). We may retain in our files some Personal Information to prevent fraud, money laundering, troubleshoot problems, assist investigations, enforce our Terms of Service and to comply with other legal requirements. 

For example, we may keep a history of changed information to investigate suspected fraud and money laundering. Such information will be deactivated or deleted as soon as practicable based on the information and in accordance with applicable laws. Therefore, you should not expect that all your Personal Information will be completely removed at once from our files in response to your request. 

Our Terms of Service gives information about Commencement, Renewal And Cancellation Of Subscription. You may cancel a paid subscription. When you cancel a subscription you will not be able to continue using our Service. The Application will remain without a subscription and your data will not be preserved forever (we will try, but not warrant, to preserve the data for three months after subscription termination). 

11.MONITORING 

We may monitor (record) communications between you and us, and in doing so we may obtain your Personal Information through this process. We will undertake monitoring in the circumstance you contact our customer service through chat or a pre-agreed call or you apply for an opening through our Candidate-applicant procurement system and have an interview with us. 

All monitoring will be done for safety and quality assurance, compliance, product development, and also for fraud prevention, detection of money laundering and training purposes for our staff. 

If you are a passive user of the Website and do not register for any subscriptions or use our Service, you may still be subject to certain passive data collection. Such passive data collection may include through Cookies, as described in our Cookie Policy, IP address information, location information, and certain browser data, such as history and/or session information. 

12.DIRECT MARKETING 

 We wish to make you aware that you have the right to object or opt-out of any direct marketing for which your data has been processed.  

We and our partnering associates may  send you direct marketing e-mails or messages by e-mail or through our Software Application. You of course can choose to opt out and we shall in such a case honor the request and not send you direct marketing e-mails or messages that you do not want. 

To opt out, use the provided unsubscribe link in a direct marketing e-mail or message or close it in the Software Application. 

Unless users opt-out from receiving such marketing materials, we may e-mail you about products and services we believe may be of interest to you. 

If you believe spam originated from us, you should report it to our customer support at: [email protected] 

13.THIRD PARTY ADVERTISERS 

We may use third party advertisers to serve ads when you visit our Website. These advertisers may use information (not including any Personal Information) about your visits to our Website and other websites that are contained in your device’s browser in order to provide advertisements about goods and services of interest to you. 

You may opt out of such advertising by changing your cookie preferences. 

We may allow advertisers to choose the characteristics of users who will see the advertisements, and we may us any of the Non-Personal Information we have collected to select the appropriate audience for those advertisements. 

We do not disclose Personal Information that would allow the advertiser to directly identify you, except e-mail. 

Unless users opt-out from receiving marketing information from third party advertisers, we may provide users’ e-mail information to third parties, so those third parties may contact you about additional services or products. 

To cease having your e-mail information provided to third parties, you may do so by contacting our Data Protection Officer at: [email protected] 

Even after opting-out, you may continue to receive marketing e-mails from third parties to whom e-mail information has been already provided. You will then have to contact such third parties directly to request cessation of further marketing e-mails. 

14.RELATED ENTITIES 

We may share your Personal Information, including that which identifies you personally, with any of our parent companies, subsidiary companies, affiliates or other trusted related entities. However, we only share your Personal Information with a trusted related entity if that entity agrees to our privacy standards as set out in this Privacy Policy and to treat your Personal Information in the same manner that we do. 

15.CONTENT INTERACTION 

Our Website may allow you to comment on the content that we provide or the content that other users provide, such as blogs, multimedia, or forum posts. If so, we may collect some Personal Information from you at that time, such as, but not limited to, username or e-mail address. 

16.WEB BEACONS 

We may use Web Beacons on our Website and e-mails to count users who have visited particular pages, viewed e-mails we send.  

Web Beacons are not used to access users’ Personal Information. They are a technique we may use to compile aggregated statistics about our Website usage. Web Beacons collect only limited set information, including information about Cookies, time and date of a page or e-mail view and a description of the page or e-mail on which the Web Beacon resides. 

You may not decline Web Beacons, but they can be rendered ineffective by declining all cookies or modifying your browser settings to notify you each time a Cookie is tendered, permitting you to accept or decline Cookies on an individual basis. More information can be obtained from our Cookie Policy

17.SOCIAL MEDIA 

We may use hyperlinks on our Website which will redirect you to a social network or third-party materials if you click on the respective link. Information about Cookies related to social media and which we use can be obtained from our Cookie Policy

When you click on a social plug-in, such as Facebook’s “LIKE” button, Twitter’s “TWEET” button or the Google+, that particular or other third-party social networks plug-in will be activated and your browser will directly connect to that provider’s servers. If you do not use such buttons, none of your data will be sent to the respective social network’s plug-in provider. 

So for example, if you see on our Website and click on the Facebook’s “LIKE” button, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of your device you have used to access our Website. Settings regarding privacy protection can be found on the websites of these or other third-party social networks and are not within our control. 

We may use plug-ins and/or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. Please note that if you browse while being logged into the social network, then you may have already consented to the use of cookies conveyed through that particular website at the time that you registered/visited with the particular social network.  

The collection and use of information obtained by means of plug-ins are governed by the respective privacy policies of these social networks, which for convenience can be found below: 

 18.COMPANY COMMUNICATIONS 

We may occasionally user your name and e-mail to send you notifications regarding new services offered by Multilogin that we think you may find interesting. 

We may also send you our Service related or general announcements from time to time by e-mail or our Software Application (if you are using the Software Application). 

You may opt out generally of such e-mails by a provided unsubscription link or close it in the Software Application. 

We reserve the right to send notices about your account, such as service announcements and administrative messages even if you opt out of all voluntary notifications if it is vitally important to deliver the message. 

By providing any Personal Information to us, or by using our Website in any manner, you have created a commercial relationship with us. As such, you agree that any e-mail sent from us or third-party affiliates, even unsolicited e-mail, shall specifically not be considered SPAM, as that term is legally defined. 

19.ANALYTICS 

We may use third parties, including Google, who use first-party cookies (e.g. Google Analytics cookie) and third-party cookies together to inform, optimize and serve ads based on your past activity on our Website. This includes Google Analytics for display advertising. The information collected may be used, among other things, to analyze and track data, determine the popularity of certain content and better understand online activity. 

If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your devices browser. Google Analytics Opt-out Browser Add-on provide users the ability to prevent their data from being used by Google Analytics. If you want to opt-out, download and install the add-on for your web browser. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Safari, Firefox and Microsoft Edge. In order to function, the opt-out add-on must be able to load and execute properly on your browser. You can learn more about Google Analytics Privacy at: https://support.google.com/analytics/answer/6004245?hl=en You can download and install Google Analytics opt-out add-on at: https://tools.google.com/dlpage/gaoptout/ 

To opt out from the Google Display Network, use the Google Ads settings at: https://adssettings.google.com/ to make your preferred choices. 

 20.LOG DATA 

 Our Website also makes use of log files that store automatic information collected during user visits. The different types of log data could be as follows: 

- internet protocol (IP) address; 

- type of browser and device parameters used to connect to the Website; 

- name of the Internet Service Provider (ISP); 

- date and time of visit; 

- webpage of origin of the user (referral) and exit; 

- possibly the number of clicks. 

 The aforementioned information is processed in an automated form and collected in an exclusively aggregated manner in order to verify the correct functioning of our Website, and for security reasons. This information will be processed according to our legitimate interests. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Information such as IP address, which could be used, in accordance with applicable laws, in order to block attempts at damage to our Website or damage to other users or websites, or in the case of harmful on unlawful activities or fraud/money laundering. 

 Such data is never used for the identification or profiling of the user, but only for the protection of the Website and our users. Such information will be treated according to our legitimate interests. 

21.BANKRUPTCY, MERGER OR BUSINESS TRANSFERS 

 We reserve the right to transfer all information (Personal and Non-Personal) in our possession to a successor organization in the event of a merger, division, acquisition, bankruptcy or other sale of all or a portion of our business and its assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred information will be subject to this Privacy Policy or to a new privacy policy if you are given notice of that new privacy policy and an opportunity to affirmatively opt-out of it. Personal Data submitted or collected after the business transfer in question, however, may be subject to a new privacy policy adopted by the successor organization. 

 22.DISCLOSURE OF PERSONAL DATA 

 Although our policy is to maintain the privacy of your Personal Data as described herein, we may disclose your Personal and any Non-Personal Information if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such cases may include, but are not limited to: 

  • satisfy any laws or regulations; 

  • respond to requests, such as criminal, civil or administrative process (court orders), or writs from law enforcement or other governmental or legal bodies acting under laws; 

  • bring about legal action against a user who has violated  laws or violated our Terms of Service

  • as may be necessary for the operation of our Website; 

  • generally cooperate with any lawful investigation about our users if fraud or money laundering is suspected; 

  • if we suspect any unlawful activity on our Website or if we have noticed any activity which may violate our terms or other applicable rules. 

 23.CREDIT CHECKING AND FRAUD PREVENTION 

 One of the purposes we use your Personal Information is in order to undertake credit checking on you to prevent possible frauds and money laundering. Other credit businesses may use your information to: 

  • make credit decisions about you and the people with whom you are financially associated; 

  • prevent and detect fraud and money laundering; 

  • ensure you are eligible for certain products and services; 

  • verify information you provide us with. 

We will undertake fraud and money laundering checks via use of your Personal Information. This will involve sharing and working with law enforcement authorities if necessary. We do so to protect our own commercial interests which are encompassed within our own legitimate interests as a business to uphold lawfulness. 

We may share your Personal Information (full name, e-mail and postal addresses, telephone number and country of residence, and credit card information) with our authorized service providers who process credit card or other types of payments we accept. These service providers may have access to your Personal Information needed to perform their functions but are not permitted to share or use such information for any other purpose. There is a good chance you have already provided you preferred credit providers with Personal Information yourself when engaging with their services. 

24.INTERNATIONAL, EUROPEAN UNION AND NATIONAL SANCTIONS 

Certain restrictive measures are imposed by the implementation of Resolutions adopted by the United Nations (UN) Security Council under Chapter VII of the UN Charter. However, it is understood that the European Union or a member state may decide to apply measures that are more restrictive in the form of sanctions to certain fields of business and individuals associated thereof. 

We have an obligation to follow international law and EU regulations and national laws regarding any imposed sanctions.  The measures used in a specific situation will vary depending on the objectives of the restrictive measures under particular circumstances, reflecting the targeted approach. Such measures may include, but are not limited to freezing of funds and economic resources, restrictions on admission, arms embargoes, embargoes on equipment that might be used for internal repression, other export restrictions, import restrictions, and flight bans. A ban on the provision of financial services, including in connection with bans on the export of certain products, has also been used as well as investment bans. In this context, sectoral bans or measures to prevent the misuse of equipment, technology or software for monitoring and interception of the Internet or of other forms of communication may be appropriate. 

Persons, entities or organizations targeted by sanctions are prohibited from using our Website and Service. We may refuse usage and Service anytime without any notice required. If we discover such an occurrence, we will discontinue providing our Service at once without any refunds.  

We may contact any such persons identified to ask stop using our Website and Service. 

We may use any Personal Data available to us about a user to check and compare against the official sanctions list publicly available, such as the Estonian Police and Boarder Guard Board Financial sanctions information search at: https://www.politsei.ee/en/money-laundering, EU Sanction Map at: https://sanctionsmap.eu/, and United Nations Security Council Consolidated List Search at: https://scsanctions.un.org/search/  

Any Personal Data Persons, entities or organizations targeted by sanctions may be transferred to law enforcement authorities if needed without any consent or notification to the involved Party. 

25.SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES 

On any occasion where any of your Personal Information is shared with any third party, we shall only permit them to process such information for our required purposes, under our specific instructions, and not for their own purposes. Such sharing is only by formal legal agreements and by third parties who are our authorized service providers or affiliates performing certain services of our behalf. These services may include fulfilling subscriptions, providing customer support, assistance, performing business and sales analysis, supporting the Websites functionality and supporting contests, sweepstakes, surveys and other features of similar nature offered through our Website. 

We will ask for your consent to share your Personal Information with third parties for marketing purposes, except for e-mail information. Any such third parties will be specifically identified by name at the time your consent is asked for. We will not share Your Personal information with any third parties for marketing purposes without your explicit consent, except for e-mail information as stated. 

 We will not knowingly share your Personal Information with any third parties other than in accordance with this Privacy Policy. 

 If your Personal Information might be provided to a third party in a manner that is other than as explained in this Privacy Policy, you will be notified. You will also have the opportunity to request that we not share that information. Please contact our Data Protection Officer at: [email protected], if so. Please be advised that you may lose access to certain services that we rely on third-party providers for. 

26.CHILDREN 

 Our Website and Services are not intended for children – anybody under the age of 18. 

 You need to be 18 or over. 

 We do not intend to collect Personal Data from children. Any person who provides Personal Information to us represents that he or she is 18 years of age or older. If we learn that Personal Information has been collected from users under 18 years of age, then we will take appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 18 years of age who has transferred Personal Information to us, please contact us using our contact information to have that child’s account terminated and information deleted. Refunds will be made according to our Terms of Service

27.PUBLIC INFORMATION 

 We may allow users to post their own content or information publicly on our Website. Such content or information may include, but is not limited to, photographs, status updates, blogs, articles, or other personal snippets. Please be aware that any such information or content that you may post, should be considered entirely public and that we do not purport to maintain the privacy of such public information. You are solely responsible for posting such information. 

28.DEFINITIONS 

 

Applicable Website: This Privacy Policy will refer to and be applicable to the Website listed herein and its subdomains, in some parts to our Software Application as well, which shall hereinafter be referred together as “Website”. 

 

Children: “Children” means persons of age under 18. 

 

Effective Date: “Effective Date” means the date this Privacy Policy comes into force and effect. 

 

Non-Personal Information: “Non-Personal Information” means any set of data which does not contain personally identifiable information. This in essence means that no individual can be identified directly by looking at such data. 

 

Parties: The parties to this Privacy Policy are the following data controller: Multilogin Software OÜ and you, as the user of our Website. Hereinafter, the parties will individually be referred to as “Party” and collectively as “Parties.” 

 

Personal Data: “Personal Data” means personal data and information that we obtain from you in connection with your use of our Website that is capable of identifying you in any manner. 

 

Personal Information: “Personal Information” means personal data we obtain from you in connection with your use of the Website that is directly capable of identifying you in any manner. 

 

Service(s): “Services or Service” means any service(s) that we make available through our Website which a user can subscribe to. 

 

Software Application: “Software Application” our proprietary software that is available for downloading on our Website and which users can subscribe to for the use of our Services. 

 

Web Beacon: “Web Beacon” is an object that is embedded in a website or e-mail that is usually invisible to the user and allows the operator of a website to check whether a user has viewed a particular website or an e-mail. 

 

You: Should you agree to this Privacy Policy and use our Website, you will be referred to herein as either “you”, “the user”, “visitor” or if any second-person pronouns are required and applicable, such pronouns as “your”, “yours”, etc

 

29.MODIFICATIONS, CHANGES AND REVISIONS 

 

We reserve the right from time to time to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner. If we do so, we will notify you.  

 

Any changes to the Privacy Policy will only impact the information collected on or after the date of the change. It is also your responsibility to periodically check this page for any such modification, revision or amendment. 

 

Effective Date: July 1st, 2022