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Privacy Policy
Last updated: 27/07/2023
§1 - Who are we
Comtechna UAB. is the Data Controller of the information you provide us and is governed by the European Union and the Lithuanian Government.
§2 - Your rights
Under data protection law, you have the right to request any details of any personal data we may hold about you. Where we have no legitimate reason to continue to keep your information, you have the right to be forgotten. We do not use your information for marketing purposes or share your information that we collected with anyone outside the Data Controller or its parent companies. We may use automated decision-making when processing your data, this can be, but not limited to, preventing fraudulant activities and compliance with other regulations specified in this policy.
§3 - What we collect & why we collect it
The Data Controller will collect the following information on you to provide the service:
§3a - Email addresses
We collect your email address to better protect your account from theft and to communicate to you electronically in a convenient manner.
§3b - IP addresses, user agents & 2-digit ISO country codes
This is stored alongside your account and any order you may create on the Service, this information is kept to prevent fraud and to help protect you from attacks against your account.
§3c - Usernames & third-party payment service provider identifiers
This is stored to identify you on our service, your username can be rectified at any time. We also collect identifiers from any registered payment service provider, this is so we can identify you on the respective service and provide it to your customers. We also will collect the identifier given by the third-party payment service provider and attach it to any order created with a third-party gateway, this is to allow the order to be tied to your respective account data on the third-party payment service provider and provide a better service.
§3d - Payment gateways, delivery states & fees
We will collect and store the chosen gateway ID that was used for payment along with the state of the order and the fee taken by the third-party payment service provider and the Service. This is for compliance with local laws and to provide a better experience for sellers.
§3e - Creation dates
All entities stored are tied with a creation date, this is for analytical purposes for the Service, and the seller.
§3f - Cryptocurrency wallets
This is to provide cryptocurrency services to you when opted-into, your wallet is specific to your account and will never change, you retain full control of the cryptocurrency wallet. Stored data includes the seed phrase, encryption keys are never stored.
§3g - Product images, names, prices, items and descriptions
This is to provide your storefront with basic features to provide the Service, and analytical purposes.
§3h - Store views
To provide analytics to the Service and the seller about their stores performance.
§3i - Customer email addresses
To provide services to any customer that is utilising the Service on behalf of a seller.
Some of the data we collect is anonymously stored and does not contain any personally identifiable information, the following falls under this category:
§3j - Error messages, stack traces and codes
This is to help make the Service better and fix any bugs or errors that have been encountered by regular usage, the data will usually include the browser name, version and operating system along with the request headers (excluding Authorization values).
§4 - Security measures
We take your security very seriously and we have implemented various security measures to help protect your account. Although we have taken extensive measures to protect your data on the Service, the full security of your data cannot be guaranteed. The following features and measures have been implemented:
- Strong password storage techniques, using industry standard and award-winning methods;
- Wallet encryption keys are derived from immutable user data and never stored;
- Unknown login location detection and multi-factor authentication;
- 2-factor authentication;
- Strong password requirements policy;
§5 - Security measures
You have the right to the portability of your data, the Service offers a feautre to request an archive containing all of the information that the Data Controller has stored about you, this is a fully automated process and will be handled within 14 days of the request. It will be transferred to you via an electronic mail (email) message.
§6 - Rectification of your data
The Service provides the necessary tools to rectify or delete any outdated or invalid information from your account automatically. You also have the right to be forgotten and your data can be fully erased from our system from the Service administration dashboard.
§7 - International data transmission
The Service utilises services that may transfer your data outside of the European Economic Area (EEA), the following services along with their respective Terms of Service and Privacy Policies are utilised by the Service and may transfer your data outside the EEA:
§7a - Cloudflare, Inc.
Cloudflare, Inc. may utilise Cookies on the Service's website, these cookies may be used for analytical and security purposes as detailed in the respective service's Terms of Service and Privacy Policy. https://www.cloudflare.com/privacypolicy https://www.cloudflare.com/website-terms/
§7b - Stripe, Inc.
Stripe, Inc. may utilise Cookies on the Service's website, these cookies may be used for analytical, security and required purposes such as service operation as detailed in the respective service's Terms of Service and Privacy Policy. https://stripe.com/privacy https://stripe.com/legal/ssa
§8 - Legal bases for processing (EEA users)
We collect and process information about you only where we have legal bases under applicable EU laws. Therefore this means we collect and use your information only where:
- We need it to provide you with the Service, including to operate the Services, provide customer support, and protect the safety and security of the Services;
- We need your data to comply with a legal obligation;
- You give us consent to do so for a specific purpose;
§9 - Retention time
Collected data may be stored and attached to your account for as long as required by the purpose they have been collected for:
- The Data Controller shall retain personal data collected for your legitimate interests as long as needed to fulfil such purposes;
- Data may be retained for a more extended period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Data Controller may be obliged to retain personal data for a more extended period whenever required to do so for the performance of a legal obligation or upon order of an authority;
Once the retention period expires, the Data Controller will delete the personal data. Therefore, the Data Controller cannot enforce the right of access, the right to erasure, rectification, and data portability after the expiration of the retention period.