PRIVACY POLICY

Effective Date: 26.09.2024

MOREADS OÜis a private limited company registered in Estonia, with the company number 16627899 whose registered office is at Harju maakond, Tallinn, Kristiine linnaosa, Tulika tn 17, 10613 (“CleanWave”, “We”, “Us”) who collects, uses and discloses information when you access or use mobile app “CleanWave” available at AppStore (the “Application”, “App”, “CleanWave”), make purchases through including all subdomains of this Website, (the "Website") or otherwise interact with us.

This Privacy Policy describes how we collect and use the Personal Data you provide. It also describes the choices available to you regarding our use of your Personal Data and how you can access the information. We respect your privacy, and we take protecting it seriously.

This Policy applies to the following people:

• people who use the Application and/or the Website (For the purposes of this policy, we define the term “User”, “you”, "your", "yours" as a person who has concluded the installation of an Application and/or uses the Website).
• people who make complaints to us by email.

CleanWave does not sell your personal data to third parties. A “sale” of Personal data under the California Consumer Privacy Act (CCPA) is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal data of a Consumer to another business or third party “for monetary or other valuable consideration.” If we decide to sell the Application and/or the Website, we will inform you about this, so you can forbid us from transferring your personal data together with our business. If so, we will delete your data from the databases prior to a business transfer.

We adhere to the following principles in order to protect your privacy:

• principle of purposefulness — we process personal data fairly and in a transparent manner only for the achievement of determined and lawful objectives, and they shall not be processed in a manner not conforming to the objectives of data processing;
• principle of minimalism — we collect personal data only to the extent necessary for the achievement of determined purposes and do not keep personal data if it is no longer needed;
• principle of restricted use — we use personal data for other purposes only with the consent of the data subject or with the permission of a competent authority;
• principle of data quality — we update personal data shall be up-to-date, complete, and necessary for the achievement of the purpose of data processing;
• principle of security — security measures shall be applied in order to protect personal data from unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical and organizational measures;
• principle of individual participation — the persons shall be notified of data collected concerning him or her, the persons shall be granted access to the data concerning him or her, and the persons have the right to demand the correction of inaccurate or misleading data.

1. PERSONAL DATA THAT WE COLLECT AND PROCESS

1.1 In order to fulfill our obligations to provision a license for the mobile app “CleanWave” for you and applicable terms of use. We are entitled to ask you to provide us with your Personal Data such as:

• Email address: We collect your email address when you subscribe to our newsletter, create an account, or contact us.

We may collect additional personal data that may be required for fulfilling our obligations to you, ensuring the functionality of the application, or for other legitimate purposes. This may include, but is not limited to, data necessary for improving service quality, analyzing application usage, and complying with legal requirements. We may also share this data with third parties as needed to achieve these purposes.

2. USE OF COLLECTED PERSONAL DATA

2.1 We may use your email address for the following purposes:

• Communication: To send you newsletters, promotional materials, and important updates regarding our services.
• Customer Support: To respond to your inquiries, comments, or any other messages.
• Legal Compliance: To comply with applicable laws, regulations, and legal requests.

3. CONSENT TO PERSONAL DATA PROCESSING

3.1 EU Persons Consent to Personal Data Processing

3.1.1 If you are an EU Person and to process your Personal Data, we need to receive your consent, as it is prescribed by General Data Protection Regulation (“GDPR”); we will process your Personal Data only in the case we have received from you a freely given, specific, informed and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data ( "Consent").

3.1.2 You may give your Consent by ticking a box when visiting the Application. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that CleanWave shall be entitled to process your Personal Data as it is indicated by your Consent.

3.1.3 Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the Processing has multiple purposes, your Consent should be deemed given for all of them.

3.1.4 You have the right to withdraw your Consent at any time. You can submit such a request at support@moreads.org. Your withdrawal of Consent shall not affect the lawfulness of your Personal Data processing based on Consent before its withdrawal.

3.1.5 Except as required or enabled by law we will not use or disclose your Personal Data for any purpose for which you refuse Consent or later withdraw your Consent. If you withdraw Consent, you agree that in spite of this withdrawal, we may continue to use those Personal Data previously provided to us to the extent that we are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation you may have towards CleanWave or in any other way permitted by law.

3.2 Non-EU Persons Consent to Personal Data Processing

3.2.1 If you are not an EU Person, by transferring to us your Personal Data via the Application and/or the Website or otherwise, you irrevocably and unconditionally consent and agree that the CleanWave shall be entitled, in accordance with this Policy: to Process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), your Personal Data so provided to us, as well as your Personal Data collected from your use of the Application (i.e. your Personal Data which we collect automatically and/or from other sources); and to use cookies and web beacons (pixel tags) to collect your Personal Data.

4. СOMPLIANCE WITH APPLICABLE LAWS

4.1. This Privacy Policy is governed by and complies with applicable data protection laws, including but not limited to:

• General Data Protection Regulation (GDPR) (EU): Ensuring rights of EU citizens regarding their personal data.
• California Consumer Privacy Act (CCPA) (USA): Providing California residents with rights related to their personal information.
• Children's Online Privacy Protection Act (COPPA) (USA): Protecting the privacy of children under 13 online.
• Other Relevant Local Laws: Depending on your location, we will comply with any other applicable data protection regulations.

5. DATA ACCESS, DATA CORRECTION, DATA DELETION, DATA PORTABILITY, AND WITHDRAWAL OF THE CONSENT

5.1 You can review, correct, update, delete or transfer your personally identifiable information. For that, contact at support@moreads.org. We will acknowledge your request within seventy-two (72) hours and handle it promptly and as required by law.

• Right to access. You may contact us to get confirmation as to whether or not we are processing your personal data. When we process your personal data, we will inform You of what categories of personal data we process regarding You, the processing purposes, the categories of recipients to whom personal data have been or will be disclosed and the envisaged storage period or criteria to determine that period.
• Right to withdraw consent.
• In case our processing is based on the consent granted, You may withdraw the consent at any time by contacting us or by using the functionalities of our Application. You can withdraw your consent at any time by replying to the email with your withdrawal, and your Personal Data will be deleted in forty-eight (48) hours. Withdrawing consent may lead to fewer possibilities to use our Application.
• Right to object. In case our processing is based on our legitimate interest to run, maintain and develop our business, You have the right to object at any time to our processing. We shall then no longer process your personal data unless for the provision of our Application or if we demonstrate other compelling legitimate grounds for our processing that override your interests, rights, and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, You have the right to prohibit us from using personal data for direct marketing purposes, by contacting us or by using the functionalities of the Application or unsubscribe possibilities in connection with our direct marketing messages.
• Right to restriction of the processing. You have the right to obtain from us restriction of processing of your personal data, as foreseen by applicable data protection law, e.g., to allow our verification of the accuracy of personal data after your contesting of accuracy or to prevent us from erasing personal data when personal data are no longer necessary for the purposes but still required for your legal claims or when our processing is unlawful. Restriction of processing may lead to fewer possibilities to use our Application.
• Right to data portability. You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format and to independently transmit those data to a third party, in case our processing is based on your consent and carried out by automated means.
• Opt-Out: You can opt out of receiving marketing communications at any time by following the unsubscribe link in our emails.

6. INFORMATION SECURITY

6.1 We care to ensure the security of personal data. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When we or our contractors process Your information, we also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is done through appropriate administrative, technical, and physical measures.

6.2 There is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, we cannot guarantee its absolute security.

6.3 We never process any kind of criminal offense data. Also, we never undertake profiling of personal data.

7. CONTRACTORS

7.1 We work with third-party services providers who provide website, application development, hosting, payment processing, maintenance, and other services for us. They may be located outside of the EEA. These contractors may have access to or process Personal Data on our behalf as part of providing those services for us. We limit the information provided to these Application providers to that which is reasonably necessary for them to perform their functions.

7.2 All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the European Economic Area may be possible only in the case when we have obtained your consent for it.

7.3 We use Google Analytics to create statistics about visitors to the Websites on the Internet. For more information about the Google Analytics Privacy Policy, please review it at: https://policies.google.com/privacy?hl=en-US.

8. PAYMENT DATA

8.1 In purchasing a subscription directly from the Website, we utilize the services of a third-party payment processor to ensure that your payment information is processed securely. If you pay by credit card, payment information is encrypted and transmitted directly to the payment processor. We do not store your payment information, have no control over it, and are not responsible or liable for payment processors, their collection, or use of your Personal Information.

9. OPT-OUT

9.1 You can deactivate local notifications by changing the notification settings in accordance with the instructions of the operating system running on the Users’ device.

10. CHILDREN’S PRIVACY

10.1 Our services are not directed to individuals under 13 years old. We do not knowingly collect personal data from children under 13. If we learn that we have collected data from a child under 13, we will take steps to delete such information promptly.

11. INTERNATIONAL DATA TRANSFERS

11.1 Your information may be transferred to and processed in countries outside of your own, including the United States and other jurisdictions where we or our service providers operate. We ensure that such transfers comply with applicable data protection laws, such as GDPR, by implementing Standard Contractual Clauses or other appropriate safeguards.

12. COOKIES AND SIMILAR TECHNOLOGIES

12.1 Our Website and Apps may use cookies and/or similar technologies to enhance your experience. You can control cookies through your browser or device settings, but disabling them may affect your use of our services.

13. APPLICATION OF THIS PRIVACY POLICY

13.1 This Privacy Policy is applicable to our Application and/or the Website. Once redirected to another website or App, this Policy is no longer applicable.

14. ACCEPTANCE OF THESE CONDITIONS

14.1 We assume that all Users have carefully read this document and agree to its content. If one does not agree with this Privacy policy, they should refrain from using the Application and/or the Website.

15. CHANGES AND UPDATES TO OUR PRIVACY POLICY

15.1 From time to time, we may update this Privacy Policy. We encourage You to periodically check back and review this Policy so that You always will know what information we collect, how we use it, and with whom we share it.

16. CONTACT US

16.1 If you have any questions please contact at support@moreads.org.