Updated: 23 February 2020
- Definition of Personal Data
- Collection of your Personal Data
We collect your personal data through different ways depending on how you use the Services. Here are a few examples on how we collect your personal data. We collect your personal data you provide us with, including, without limitation, when you:
- visit, browse, and use our Website;
- contact us with any enquiries and in relation to the Services that we provide;
- provide full name, passport details, address and other requested information during identity verification;
- subscribe to our newsletters;
- interact with us on our social media pages;
- communicate with our partners and vendors selling our Services;
- send us an email with personal data;
- order any Service of Heaven24;
- communicate with us, our staff through the Website, via email or phone;
- voluntarily submit your personal data to Heaven24 for any reason.
Heaven24 may receive the following personal data:
- information provided by the user during identity verification, including, user name, full name, passport data, phone number, date of birth, postal address and email address;
- your ID/passport and details containing in these documents, proof of address;
- financial information when you pay for our Services, including, without limitation, credit card number, bank account details, etc;
- contact details when you fill in our contact form, including, without limitation, skype account name, whatsapp number, email;
- information that you provide to Heaven24 when Heaven24 reasonably requests in order to provide you with consulting and other services;
- any other personal data which you directly provide to Heaven24.
Our Website can be visited anonymously. The Website processes anonymous metadata through cookies such as the URL of the requested file, the amount of data transferred, the date and time of the request from the user, Internet browser information, operating system type, the IP address of the used device, the Internet service provider, reference links such as user clicks on certain links. This metadata cannot be used by the Website to obtain personally identifiable information. This information is only used for general purposes, such as technical improvements, statistical and marketing analysis.
When you visit our Website and use our Services, we may automatically receive some information that identifies, for each page accessed:
- the type of browser and operating system you have used;
- the IP (Internet Protocol) address of the device which has accessed it (example PC, tablet);
- the date and time of your visit to the Website;
- the pages accessed and documents downloaded;
- your top-level domain name (for example .com, .io, .eu, etc.);
- the address of your server;
- the previous website visited;
- the average duration of page view;
- the navigation behaviour and preferences of the user.
- Google Analytics
Heaven24 collects and processes personal data about users and customers only if Heaven24 has lawful basis. Lawful basis includes:
- consent (where you have given consent);
- contractual obligations (when the processing is necessary to perform our obligations under a contract);
- legitimate interests;
- compliance with applicable law (when we follow applicable personal data law in order to be complied with).
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.
The legitimate interests are:
- analysing and understanding your behaviour on the Website;
- providing you with the Services related to company incorporation, obtaining licenses or other permits, other services as we mutually agreed on;
- conducting an identity verification in accordance with anti-money laundering legislation (if applicable);
- making improvements to the Services;
- enabling us to enhance, customise or modify our Services and communications;
- improving data security;
- representing you before legal, financial and regulatory authorities if you directly instructed us (e.g. in case of company incorporation, opening a bank account, obtaining licenses);
- determining whether marketing campaigns are effective.
If you have any questions about the lawful basis upon which we collect and use your personal data, please contact us at firstname.lastname@example.org.
Heaven24 does not knowingly provide Services and collect personal information from anyone under 18 years of age. Our Services are available only to the users over 18 years old. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
Sharing your Personal Data
Heaven24 may share your information with:
- service providers we work with to deliver some Services;
- legal and regulatory authorities, as required by applicable laws and regulations;
- legal, financial and regulatory authorities if you directly instructed us to provide you with the Services;
- our employees;
- our auditors, lawyers, accountants, consultants and other professional advisors, where it is reasonably necessary for obtaining advice, professional services, or managing legal disputes.
We do not collect or request your sensitive data (including, but not limited to, information about your religious or political beliefs, opinions). Where you have provided it to us voluntarily, you shall be solely responsible for security of any sensitive data, and we do not intend to use this data for any purpose, nor share this data with any third parties. Please do not post or add sensitive and other personal data that you would not want to be publicly available.
Use of Personal Data
Personal data will be collected, held, used and disclosed for the following purposes jointly and/or severally:
- to provide you with Website and Services requested;
- to identify you;
- to verify your identity;
- to provide you with newsletters you subscribed to;
- to process any requests;
- to perform marketing analysis and to conduct market research;
- to the extent permissible or necessary by law, for any other purpose as may be deemed reasonably necessary by Heaven24 in the circumstances;
Users’ Rights in relation to its Personal Data
You may access your personal data held by us to correct, update and remove inaccurate or incorrect data. You have the following rights:
- delete some or all personal data that we held about you;
- change or correct your personal data that we held about you;
- object to, or limit or restrict, use of your personal data;
- right to access and/or take your personal data: you can ask us for a copy of your personal information in machine readable form;
- ask not to use your personal data for marketing purposes;
- access information we hold about you.
If you want your personal data to be corrected, updated or removed, please contact us at email@example.com.
Security of Personal Data
We use certain technologies to ensure the confidentiality of your personal data. While we strive to use commercially acceptable means to protect your personal data, no method of transmission over the Internet, or method of electronic storage, is completely secure, and we cannot guarantee absolute security of your personal data.
Data Transfer and Retention
We retain your personal data primarily in Estonia. We may retain your personal data in other countries of the European Union.
Countries where we process information may have laws which are different, and potentially not as protective, as the laws of your own country, though we will always comply with the applicable laws in doing so.
We retain your personal data for as long as we need it to fulfil the purposes for which we originally collect it or as needed to provide you with the services, except if required otherwise by law.
In some cases we may determine the period of data retention based on the period we need to access the data for the provision of services, receiving payment, resolving your customer support issues or for any other auditing or legal purposes.
Retention periods may be changed from time to time based on regulatory requirements.
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