Privacy Policy

1. Application of this Privacy Policy.

Readsy (“we” and “us” in any declension) respects the privacy of its users and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy governs your use of Readsy (“Service”) and describes the data we collect, how it is stored, how that data may be used, with whom it may be shared, and your choices about such uses and disclosures. Please be sure to carefully read the entirety of this Privacy Policy when using our Service.

Check the Readsy’s Terms of Use (“Terms”) for the meaning of defined words (those with capital letters) not explicitly defined in this Privacy Policy.

2. Who we are.

Brailion Ventures Limited, a legal entity incorporated under the laws of Cyprus under registration number HE 424776, having its registered office at Spyrou Kyprianou, 79, PROTOPAPAS BLDG 2nd floor, Flat/Office 201, 3076, Limassol, Cyprus will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Service.

If you have any questions about how we protect or use your data, please email us at: [email protected].

3. What kinds of data do we collect about you?

We collect data you make available to us voluntarily on the Readsy in various situations (e.g., when you send us an e-mail). We also collect data automatically (e.g., your IP address).

3.1. Data you give us

You may provide us data in different ways. For example, we collect and store data that you give us when you register user profile (“Profile”) or respond to Readsy’s e-mails or report a problem with the Service. The data that you give us includes:

Profile data. This includes your name, username, date of birth and e-mail address. You may optionally provide additional data on your Profile.

Because you control your Profile, these details are available to you at any time by accessing your “Profile” page, which gives you the chance to correct or update (other than name, date of birth and email address) your data at any time by logging in to Readsy. Please do not post or add personal data to your Profile that you would not want to be publicly available. We also do not recommend that you put email addresses, instant messaging details, phone numbers, credit card details, national identity numbers, drivers’ license details in your Profile which may make them open to abuse and misuse. Please be careful about posting sensitive details about yourself on your Profile such as religion, health details, sexual preferences or ethnic background. Where you choose provide us sensitive data about yourself, you are manifestly making this public to other users.

3.2. Data we collect about you

We collect data through a variety of sources. With regard to your use of our Services we may automatically collect the following data:

Navigation data. We collect data about how you navigate and use our Services, such as the types of content you view or engage with or the frequency and duration of your activities.

Device data. We collect data from or about the phones or other devices where you install or access our Service, depending on the permissions you’ve granted. In particular, we ask for access to your photos and camera of your device when you want to upload or make any photos for your Profile. We may associate the data we collect from your different devices, which helps us provide consistent Services across your devices. Device data may include data about your operating system, hardware version, type and model, geolocation, IP address, connection data such as ISP, language and time zone. We also receive the URL of both the site you came from and the one you go to next.

Data about payments. We collect data about your credit purchase amount, date of credit purchase and payment method.

Transaction data. When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

Advertising. We partner with a third-party ad network to manage our advertising on other sites. Our ad network partner uses cookies to collect non-personal data about your activities on web sites to provide you targeted advertising based upon your interests. For more information about advertising and tracking online, visit the Network Advertising Initiative or Digital Advertising Alliance. This website allows consumers to “opt out” of the behavioral advertising delivered by member companies.

3.3. Data about Children

We do not knowingly collect any data about children, minors or anyone under the age of 18. Nor do we knowingly market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit data to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that Profile and delete their personal data.

4. How we use the data we collect?

We and our service providers use personal data to: (i) provide the Service; (ii) detect and prevent fraud; (iii) promote, analyze and improve our Service.

In particular, we use your personal data in order:

• to provide you with the Services you use or request, for example, we use your data to authenticate you and authorize access to our Services, and identify you across the Service.
• to improve our Service by using data about your usage and interaction with our Service. We conduct surveys and research, test features in development. We analyze the data we have to evaluate our Service, and conduct audits and troubleshooting activities to improve our Service content and layouts.
• to personalize the Service for you, such as to select the payment processor available to you, we also may use your data to determine your eligibility for promotions, sweepstakes and contests and show you personalized advertisements, if you provided consent on it. In particular, we use identifiers such as GAID (Google Advertise ID) for Android and IDFA (Identifier for Advertisers) for iOS for making personalized advertisements for you.
• to process your payments and send notices about your transactions.
• to verify your identity, including during account verification.
• to prevent, detect, investigate, resolve disputes and/or remediate malicious activities, fraud, other cybercrimes, take legally-required actions or make sure you are a real person and want to avoid fake accounts being created.
• to contact you about our Service matters by email and other ways through our Services, including push notifications. We will send you messages about the availability of our Service, security, payment transactions, status of your orders, legal notices or other service-related information (Service messages). We also send messages about updates on the Service such as new books or chapters becoming available on the Service (Updates messages), you can unsubscribe from Updates messages at any time. Please be aware that you cannot opt out of receiving Service messages from us.
• to show you advertisements on our Service and/or send you commercial email about our Service, features, offers, promotions, contests, and events or provide other news or information about third party services that may be of interest to you. We offer you choice to opt out advertisement and/or commercial emails.
• to provide you customer service and support.

We will also notify you if we want to use your personal data for a new or different purpose. We will use your personal data for such other purposes only if and to the extent necessary or permitted by applicable law or with your consent.

5. Legal basis for processing (EEA only).

If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal data will depend on the personal data concerned and the specific context in which we collect it. However, we will normally collect personal data from you only where: (a) we have your consent to do so, (b) where we need the personal data to perform a contract with you (e.g., to deliver the Readsy Service you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

6. Advertising.

6.1. Advertising of other services on Readsy.

Readsy may allow third party advertisers to serve advertisements of a third party products and services within the Service, including rewarded advertisements, rewarded interstitial and/or other types of advertisements (the “Reward Ad”) placed within the App.

We display advertising of third-party services using data you make available to us when you interact with our Service, such as coins purchasing on Readsy or duration of the Service usage. Our custom system enables us to learn about when and what ads you see, what ads you click. This allows us to provide you with more useful and relevant ads. For example, if we know what ads you are shown we can be careful not to show you the same ones repeatedly. Our Privacy Policy does not apply to, and we cannot control the activities of any third party advertisers and/or websites, etc.

YYou can exercise choices over regarding our use and disclosure of your personal data and update your preferences at any time as described in Section 7.

6.2. Advertising of our Service on other websites.

We serve you tailored advertising outside of our Service based on data relating to your access to and use of our Service, as well as data received from third parties.

In order to understand and improve the effectiveness of our advertising, we may use cookies, device identifiers and other technologies to identify the fact that you have visited our Service or seen one of our advertisements on other website, and we may provide that data to one or more third party advertising networks. We may choose to work with Google AdWords, DoubleClick, Google Analytics or other advertising networks. Each of these companies has its own privacy policy. The data we provide may include the time and date of your visit to our Service, pages viewed, links clicked and other data that does not disclose your identity. We may target advertising to you through a variety of ad networks and exchanges, using data from advertising technologies on and of our Services like, unique cookie, or similar tracking technology, pixel, device identifiers, geolocation, operation system information, email. Advertising you receive on other websites is customized based on predictions about your interests generated from your use of our Service, visits to different websites. This type of advertising customization is called “online behavioral“ or “interest-based“ advertising. If you would like more information about this practice, and to learn how to opt out of online behavioral advertising by companies participating in industry self-regulation in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit the Digital Advertising Alliance or Network Advertising Initiative.

At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.

7. Advertising Choices.

You have choices regarding our use and disclosure of your personal data. We offer you choices about receiving advertising.

• • Advertising from third parties on Readsy is tailored to you based on your previous use of Service. You can choose not to receive advertising from third parties by contacting our Customer Service.
• • If you no longer want to receive marketing-related emails (i) from us about our Service or (ii) from third parties about similar services, you can opt out of receiving such electronic communications. Please note that if you opt-out of receiving marketing-related emails, we may still send you important administrative messages that are required to provide you with our Service.
• You can also generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for online behavioral advertising by visiting the opt-out pages on the NAI website and DAA website.

8. Retention Period.

We will retain personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Please note that we have a variety of obligations to retain the data that you provide to us, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if you close Profile, we will retain certain Data to meet our obligations.

9. With whom we share your data?

Protection of your personal data is important for us. Your personal data will be shared with third parties only (i) if we have a legal obligation to do so (ii) if the data transfer is necessary for performance of the contract with you, (iii) if you have consented to the transfer of your data.

Third-party service providers and partner companies will receive your data only if and to the extent necessary for performance of our contract with you or with your consent. In such cases, the extent to which data is shared will however be kept to the absolute minimum. To the extent that our service providers come into contact with your personal data, we will make sure that they too will comply with all applicable data protection laws.

We do not share personal data with other companies, organizations and individuals unless one of the following circumstances applies:

With your consent. We will share personal data with other companies, organizations or individuals when we have your consent to do so.

Other users. . Any data you include on your Profile and any action you take on our Service may be seen by other users. E.g., when you update or add photo (which you can change) it can be seen publicly.

Service providers. We may share your personal data with third parties that perform certain services on our behalf. We use these services to provide hosting for and maintenance of our website, applications development, backup, storage, marketing assistance, performing business and sales analysis, supporting our Service functionality, and supporting contests, sweepstakes, surveys and other features offered through our Service. These Services process your personal data based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

Other Situations. We also may disclose your data, including personal data:

• In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us in our sole and exclusive discretion.
• When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Use&Service or other agreements or policies.
• In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

10. International data transfers.

Readsy is a global business. We may transfer personal data to countries other than the one in which you live. This country may not have the same data protection law as the country in which you initially provided the data. We deploy safeguards if we transfer Personal Data originating from the European Union (EU) and European Economic Area (EEA) to other countries not deemed adequate under applicable data protection law.

We process data outside of the EU and EEA.

In particular, to offer our Service, we need to transfer your personal data to the United States and Ukraine. The United States and Ukraine are not considered to provide an adequate level of protection under EU data protection law. It means that these countries do not have the same data protection laws as the country in which you initially provided the data.

In all cases, we use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the EU. Learn more about the Standard Contractual Clauses adopted by the EU Commission. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data. Readsy accordingly adopted Standard Contractual Clauses so that the data flows necessary to provide, maintain, and develop our Service take place legally.

11. Third-party websites.

There is a number of places on our Service where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement on our Service, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect data, including personal data, from you and, in some instances, provide us with data about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the “privacy“ link typically located at the bottom of the webpage you are visiting.

12. How we protect your personal data?

We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. When personal data is collected on Readsy and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. However, data transfers are generally subject to security gaps, please make sure not to provide your login data to any third parties.

13. Changes to this Privacy Policy.

We may modify this Privacy Policy at any time. If we decide to make material changes to this Privacy Policy, we will provide notice through our Service, or by other means, to provide you an opportunity to revise changes before they become effective. We would also make visible the last date of updates introduced to this Privacy Policy for your convenience. We recommend that you add Readsy to your approved sender list, within your email reader.

If you disagree with the changes to this Privacy Policy, you should close your Profile. Your continued use of our Service after we send a notice about our changes to this Privacy Policy means that you are consenting to the updated Privacy Policy.

14. Privacy Rights.

You may at any time and at no cost demand information about your personal data that are processed by us, correction of any errors in your personal data, termination of processing of your personal data, erasure of your personal data or portability of your personal data. To exercise these rights, simply contact us at any time by e-mail at [email protected] with “Privacy Rights” on the subject line and in the body of your message.

If emailing us your request, please make clear in the email what personal data you would like to have changed or deleted. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

You also have the right to lodge a complaint with a supervisory authority if you believe that your personal data is mistreated. For this you may contact Cyprus Regulatory Authority at http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_el/home_el?opendocument

15. Contact Us.

If you have any questions or concerns about this Privacy Policy or our collection, use, or storage or your data, please do not hesitate to contact us by e-mail at [email protected]