Privacy policy of Fortunatos.io

This Website collects some Personal Data from its Users. This document can be printed for reference by using the print command in the settings of any browser.

 

Owner and Data Controller

LTD “LISSON”, Recordna st. 34/8, Zaporozhye, 69035
Owner contact email: hello@fortunatos.io

 

Types of Data collected

This Website collects various types of Personal Data, including Cookies, Usage Data, email address, phone number, first name, last name, company name, and country. Detailed information about each type of Personal Data can be found in the specific sections of this privacy policy or in explanatory texts displayed prior to Data collection.

Users may freely provide Personal Data, and in the case of Usage Data, it is collected automatically when using this Website. Unless otherwise specified, all Data requested by this Website is mandatory. Failure to provide such Data may result in the inability to access or use the services provided by this Website. If the Website indicates that certain Data is not mandatory, Users are free to choose not to provide it without any impact on the availability or functioning of the Service.

If Users have any questions about which Personal Data is mandatory, they can reach out to the Owner. The use of Cookies or other tracking tools on this Website is solely for the purpose of providing the required Service to Users, in addition to any other purposes mentioned in this document and the Cookie Policy, if available.

Users are responsible for obtaining the necessary consent from third parties for any Personal Data obtained, published, or shared through this Website and confirm their compliance with the third party’s consent requirements before providing the Data to the Owner.

 

Mode and place of processing the Data

Methods of processing

The Owner implements appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of the Data. Data processing is conducted using computers and/or IT tools, following organizational procedures and methods strictly related to the stated purposes. In addition to the Owner, certain personnel (such as administrators, sales and marketing teams, legal and system administrators) and external parties (such as third-party technical service providers, hosting providers, IT companies, communication agencies, and mail carriers) may have access to the Data as necessary for the operation of this Website. If required, these external parties may be appointed as Data Processors by the Owner. For an updated list of such parties, feel free to request the information from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data of Users if one of the following conditions is met:

  1. Users have provided their consent for one or more specific purposes. Please note that under certain legislations, the Owner may process Personal Data until the User objects to such processing (“opt-out”), without relying on consent or other legal bases. However, this exception does not apply when the processing of Personal Data is subject to European data protection law.
  2. The provision of Data is necessary for the performance of a contract with the User and/or for any pre-contractual obligations.
  3. The processing is required to comply with a legal obligation to which the Owner is subject.
  4. The processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner.
  5. The processing is necessary for the legitimate interests pursued by the Owner or a third party.

In any case, the Owner is available to provide further clarification regarding the specific legal basis for the processing of Personal Data, including whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the operational offices of the Owner and in other locations where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve the transfer of User’s Data to a country different from their own. To obtain more information about the processing location of such transferred Data, Users can refer to the section that provides details about the processing of Personal Data.

Users have the right to be informed about the legal basis for Data transfers to a country outside the European Union or to any international organization governed by public international law or established by two or more countries, such as the UN. Users are also entitled to learn about the security measures implemented by the Owner to protect their Data.

If any such transfer occurs, Users can find further information by reviewing the relevant sections of this document or by contacting the Owner using the contact details provided.

Retention time

Personal Data will be processed and stored for as long as necessary to fulfill the purpose for which it was collected.

Accordingly:

  • Personal Data collected for the performance of a contract between the Owner and the User will be retained until the contract is fully executed.
  • Personal Data collected for the Owner’s legitimate interests will be retained for as long as necessary to fulfill those interests. Users can obtain specific information about the Owner’s legitimate interests in the relevant sections of this document or by contacting the Owner.
  • If the User has provided consent for processing Personal Data, the Owner may retain it for a longer period, as long as consent is not withdrawn. Additionally, the Owner may be required to retain Personal Data for a longer period to comply with legal obligations or orders from authorities.

Once the retention period expires, Personal Data will be deleted. Therefore, after the retention period, the right of access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced.

 

The purposes of processing

The User’s Data is collected to enable the Owner to provide its Service, fulfill its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect malicious or fraudulent activity, and perform the following activities: Remarketing and behavioral targeting, Analytics, User database management, Managing contacts and sending messages, Advertising, Displaying content from external platforms, Tag Management, Heat mapping and session recording, and Content performance and features testing (A/B testing).

For detailed information regarding the Personal Data used for each purpose, Users may refer to the “Detailed information on the processing of Personal Data” section.

 

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Advertising

This service allows User Data to be used for advertising communication purposes. These communications are displayed as banners and other advertisements on this Website, potentially based on User interests.
However, not all Personal Data is used for this purpose. Detailed information and usage conditions can be found below.
Some of the listed services may use Trackers to identify Users or employ behavioral retargeting, which involves displaying ads tailored to the User’s interests and behavior, including those observed outside this Website. For more information, please refer to the privacy policies of the relevant services.
Typically, services of this nature offer the option to opt out of such tracking. Users can also find general instructions on opting out of interest-based advertising in the dedicated section “How to opt-out of interest-based advertising” within this document.

Google Ad Manager (Google Inc.)

Google Ad Manager is an advertising service provided by Google LLC that enables the Owner to run advertising campaigns in collaboration with external advertising networks. Unless stated otherwise in this document, the Owner does not have a direct relationship with these external networks. Users who wish to opt out of being tracked by various advertising networks can utilize Youronlinechoices. For a better understanding of how Google uses data, please refer to Google’s partner policy.

This service utilizes the “DoubleClick” Cookie to track the usage of this Website and User behavior regarding ads, products, and services offered. Users have the option to disable all DoubleClick Cookies by clicking on the following link: www.google.com/settings/ads/onweb/optout?hl=en.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Analytics

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

HubSpot Analytics (HubSpot, Inc.)

HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). It uses the collected data to track and analyze the usage of this Website, generate activity reports, and share them with other Google services. Google may also use the collected data to tailor and personalize advertisements within its advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.

Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

Facebook Ads conversion tracking, also known as the Facebook pixel, is an analytics service provided by Facebook, Inc. It connects data from the Facebook advertising network with actions taken on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram, and Audience Network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.

WordPress Stats (Automattic Inc.)

WordPress Stats is an analytics service provided by Automattic Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.

Heat mapping and session recording

Heat mapping services are utilized to visually display the areas of this Website where Users interact most frequently. This provides insights into the points of interest. These services enable the monitoring and analysis of web traffic, as well as tracking User behavior. Some of these services may also record sessions for later visual playback.

Managing contacts and sending messages

This service enables the management of a database containing email contacts, phone contacts, or other contact information to facilitate communication with the User. These services may also collect data regarding the date and time the message was viewed by the User, as well as any interactions made by the User, such as clicking on included links.

HubSpot Email (HubSpot, Inc.)

HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.
Personal Data processed: email address; Usage Data.
Place of processing: United States – Privacy Policy.

Remarketing and behavioral targeting

This service enables the Website and its partners to deliver targeted advertising based on the User’s previous use of the Website. It involves tracking Usage Data and utilizing Trackers to collect information, which is then shared with partners responsible for remarketing and behavioral targeting. Some services also provide remarketing options utilizing email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data processed: Cookies; email address.
Place of processing: United States – Privacy Policy – Opt Out.

Tag Management

This service assists the Owner in centrally managing the tags or scripts required on this Website. As a result, Users’ Data may pass through these services, which could potentially lead to the retention of this Data.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.

User database management

This service enables the Owner to create user profiles using information provided by the User, such as email addresses or personal names, and track User activities through analytics features. The Personal Data collected may be combined with publicly available information, such as social network profiles, to create private profiles that the Owner can use to enhance this Website. Additionally, some of these services may allow the sending of timed messages to the User, such as emails triggered by specific actions taken on this Website.

HubSpot CRM (HubSpot, Inc.)

HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

HubSpot Lead Management (HubSpot, Inc.)

HubSpot Lead Management is a User database management service provided by HubSpot, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

 

Information on opting out of interest-based advertising

Apart from the opt-out options offered by the services mentioned in this document, Users can find more information on how to opt out of interest-based advertising in the dedicated section of the Cookie Policy.

 

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:

  • Revoke their consent at any time. Users have the right to withdraw their consent if they have previously given consent to the processing of their Personal Data.
  • Object to the processing of their Data. Users have the right to object to the processing of their Data if the processing is conducted on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to know if their Data is being processed by the Owner, obtain information regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
  • Verify and request rectification. Users have the right to verify the accuracy of their Data and request it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In such cases, the Owner will only store the Data without processing it for any other purpose.
  • Have their Personal Data erased or deleted. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and transfer it to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format, and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract to which the User is a party, or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to lodge a complaint with their competent data protection authority.

Details about the right to object to processing

If Personal Data is processed for a public interest, in the exercise of official authority vested in the Owner, or for the legitimate interests pursued by the Owner, Users have the right to object to such processing by providing a reason related to their specific situation to justify the objection.

However, Users should be aware that if their Personal Data is processed for direct marketing purposes, they can object to such processing at any time without having to provide any justification. To determine if the Owner is processing Personal Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to exercise these rights

Users can direct any requests to exercise their rights to the Owner using the contact details provided in this document. These requests can be made free of charge and will be handled by the Owner as promptly as possible and always within one month.

 

Cookie Policy

This Website uses Trackers. To learn more, the User may consult the Cookie Policy.

 

Additional information about Data collection and processing

Legal action

The Owner may use the User’s Personal Data for legal purposes, including in court or in the stages leading to potential legal action resulting from the improper use of this Website or the related services. The User acknowledges that the Owner may be obligated to disclose personal data in response to requests from public authorities.

Additional information about User’s Personal Data

Along with the details presented in this privacy policy, this Website may offer the User supplementary and contextual information related to specific services or the gathering and handling of Personal Data upon request.

System logs and maintenance

For the purpose of operating and maintaining this Website, as well as any third-party services involved, files may be collected that record interactions with this Website (system logs) and may use other Personal Data (such as IP addresses).

Information not contained in this policy

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

Changes to this privacy policy

The Owner retains the right to modify this privacy policy at any time by notifying Users on this page and potentially within this Website and/or, if technically and legally possible, by sending a notice to Users through any contact information available to the Owner. It is highly advisable to regularly review this page, taking note of the last modification date indicated at the bottom.

If the changes have an impact on processing activities that are based on the User’s consent, the Owner will obtain new consent from the User, if necessary.

 

Definitions and legal references

Personal Data (or Data)

Personal information refers to any data that, either directly, indirectly, or in conjunction with other information, enables the identification or possibility of identifying a specific individual. This includes information that may include a personal identification number.

Usage Data

This Website collects information automatically (or through third-party services used in this Website), which may include the following: IP addresses or domain names of the computers used by Users visiting this Website, URI addresses (Uniform Resource Identifier), time of the request, method used to submit the request to the server, size of the file received in response, numerical code indicating the server’s response status (successful, error, etc.), country of origin, browser and operating system features used by the User, various time details per visit (such as time spent on each page within the Application), details about the path followed within the Application, including the sequence of visited pages, and other parameters relating to the User’s device operating system and/or IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

 

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Website, if not stated otherwise within this document.
Latest update: June 20, 2023