1.1 The Information on Users is divided into personally identifiable and non-personally identifiable Information depending on whether Information can identify the User as a specific person. Information about legal persons does not fall within the scope of Information as defined in our Terms of Use and Privacy Policy documents. 1.2 The Information on Users is divided into personally identifiable and non-personally identifiable Information depending on whether Information can identify the User as a specific person. Information about legal persons does not fall within the scope of Information as defined in our Terms of Use and Privacy Policy documents. 1.3 Goldberry Web Limited, an English Limited Company, registered with the England and Wales Trade and Companies Registry under company number no.13090305, having its registered office at 63-66 Hatton Garden, London, England, EC1N 8LE, has a position of a ‘Controller’ as defined in EU GDPR and we shall be responsible for, and be able to demonstrate compliance with, the principles relating to processing of personal data. Goldberry Web Limited has a position of a ‘processor’ within the meaning of EU GDPR with regard to Information obtained on behalf of Users during the course of using our Services. We can be contacted by sending an e-mail to [email protected] 2.1 We may obtain some of your personal Information in order to provide our Services. The Information we collect is necessary to provide our Services, and we shall not collect any Information which is not required by the nature of our Services. We may collect some of the following personal Information:

• First and last name
• E-mail address
• Phone number
• IP address and server log files
• Payment information
• Other information which you choose to provide

(A) Name

2.2 In order to register to use our Platform you have to provide your first and last name. We will only use this information to create an account for you and to address you whenever we contact you. The legal basis for processing of this information is contractual obligation. If you do not provide your name during the registration you will not be able to register an account with us.

(B) Email address

2.3 We require your e-mail address when you register to use the Services, or you may provide it when you subscribe to the newsletter or when you contact our support. We will only use your email address in accordance with this Privacy Policy, including the rules for the duration of the collection. We collect your email address to comply with our contractual obligation of providing our Services, or with your consent, depending on the purpose of collection. We will collect your email address in the following cases:

• - When you register for an account with us. We will collect your email address to create and manage an account for you and to send you notifications about your account such as when you want to recover your password, receive a message, we change our privacy policy, or if there is a data breach. An account is necessary to access some of our Services and if you do not provide us with your e-mail address for this purpose you will not be able to access these Services.
• - When you contact us. We will collect your email address whenever you contact us through our email [email protected]. Whenever we collect your email address this way, we will only use it in order to respond to your enquiry.
• - When you subscribe to the newsletter. We will collect your email address when you subscribe to receive more information about Geolocate. By subscribing to the newsletter you provide your consent for receiving the emails with the latest news regarding Geolocate and related products.

(C) Phone number

2.4 We may collect your phone number when you choose to use our services. Some services require a phone number to enable the use of this application for its intended purpose, considering the way our Services function. If you provide your phone number for this purpose we will only use it to deliver requested services and we do not use your phone number for other purposes.

(D) IP Address and server log files

2.5 We integrate security systems on our Platform to prevent malicious attempts and exploits of the Site. We scan IP addresses and ban IP addresses that show malicious signs such as too many password failures, seeking exploits and similar. We process this information in the interest of protecting the integrity of the Site and of the databases connected with it. We collect your IP address on the basis of a legitimate interest to maintain the integrity and safety of our databases. 2.6 The Platform collects a series of general data and information when a person accesses the Site. This general data and information are stored in the server log files. Information that is collected includes (1) the software and browser types and versions used, (2) the operating system used by the accessing system, (3) the date and time of access to the Services, (4) the Internet service provider of the accessing system, and (5) any other similar data and information that may be used in the event of attacks on our information technology systems. 2.7 We collect this information for breach investigation purposes. When using this information, we may connect specific log files with specific Users provided that Users are logged in their Geolocate accounts when accessing the Site. This information is needed to (1) troubleshoot problems and correct system bugs, (2) deliver the content of our Platform correctly, (3) optimize the content of our Platform as well as its advertisement, (4) ensure the long-term viability of our information technology systems and website technology, and (5) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. We collect this information based on our legitimate interest.

(E) Payment information

2.8 All payments on the Platform are conducted through third party service providers such as Stripe Inc. or PayPal Inc, depending on the method of payment. You hereby understand that by making purchase through our Platform your personal information is being processed and handled in accordance with respective Third-Party’s policies. Stripe’s privacy policy is available here https://stripe.com/us/privacy, and PayPal’s privacy policy is available here https://www.paypal.com/us/webapps/mpp/ua/privacyfull? locale.x=en_US.

(F) Other Information

2.9 You may at some point choose to provide other information which is not required for the proper functioning of the Services. In all such cases we will use this information only for the purpose for which you disclosed it. If we are not sure as to why you are providing such information, we will contact you wherever possible. Otherwise we will delete such information.

(G) General

2.10 Some Services will not be available to you if you do not provide the requested Information. We may keep records of any questions, complaints or compliments made by you and the response, if any. Whenever you contact us, we shall collect any information which you chose to provide. We shall store and use this information only for the purpose of responding to your enquiries. Information contained within the enquiry, free from any personally identifiable Information, will be stored on our servers for the purpose of improving our Services and providing the best customer support possible. 2.11 We do not sell or rent personal Information to any Third-Party. We use collected Information for our internal and marketing purposes, as necessary by the nature of the Services, and only in accordance with this Privacy Policy. In some instances, we are obliged to comply with court orders and government requests and provide Information or parts of it to authorized bodies. 2.12 We may disclose your personal information to our partners, agents and operators under confidentiality or similar agreements, including payment processors and shipping companies who we believe reasonably need to come into contact with that information: (i) to provide Services per your request; (ii) to administer our business or the Site; (iii) to provide customer support; (iv) to update account information; (v) to forward updates, announcements, and newsletters; (vi) to respond to your communications, and communicate with you about the Site and other activities related to the Site; (vii) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of the Site’s business or operations (including without limitation in connection with bankruptcy or any similar proceedings); or (viii) as otherwise authorized by you. 2.13 We have implemented security procedures and measures in order to ensure appropriate protection of the Information we process, against any misuse, unauthorized access, disclosure or modification. We will remove any Information about you upon your request no later than fifteen (15) days after the request has been made. 2.14 We acknowledge that the safety of your Information is one of the highest priorities and therefore only authorized processors have access to your information. Although we take all appropriate measures in respect to keeping your information secure, you understand that no data security measures in the world can offer 100% protection. If we ever find or suspect a personal data breach we will without delay, within seventy-two (72) hours after becoming aware of it, notify the appropriate supervisory authority about the breach and Users where necessary. 2.15 The processing of the information is being performed automatically, without human intervention. However, whenever you contact us through email, the Information within the email will be handled and processed by a real person in order to provide you with the answer to the email. 2.16 Users may request access to, modification and erasure of personal Information and exercise the right to object. Such requests should be submitted to [email protected]. 3.1 The Platform and other third-party analytics platforms collect a series of general data and information when a User or automated system calls up the Platform. This general data and information are stored in the server log files. Collected may be (1) the software types and versions used, (2) the operating system used by the accessing system, (3) the date and time of access to the services, (4) the internet service provider of the accessing system, and (5) any other similar data and information that may be used in the event of attacks on our information technology systems. 3.2 We collect this information for breach investigation purposes. When using this information, we do not draw any conclusions about the User. Rather, this information is needed to (1) deliver the content of our Platform correctly, (2) optimize the content of our Platform as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. The anonymous data of the server log files are stored separately from all personal data provided by a data subject. 4.1 Regarding the Information we collect from Users about the fax recipients, Geolocate acts as a processor to comply with the User’s request for services. Geolocate may not use collected Information for their own use and only collects such Information on behalf of the Users. Regarding such Information, Users have the position of a data controller with the meaning of EU GDPR. 5.1 Information will be stored on secure servers, controlled and maintained in accordance with sufficient privacy safeguards. We may store or transfer Information on data subjects located in the EU to servers located in countries deemed adequate by the European Commission, or in countries which the European Commission has not deemed inadequate, provided that such countries implement appropriate and suitable safeguards regarding the security of personal information. 5.2 Information is stored on the servers only for the duration necessary for providing the Services and maintaining the integrity of our databases. We will maintain records of processing activities for the purpose of demonstrating compliance with EU GDPR. 5.3 Some services require the use of third-party solutions. When you are redirected from our Site to the third-party website you are no longer interacting with our Site. Any information that you provide through third-party websites will be handled and processed in accordance with their Privacy Policies and other applicable terms. 6.1 The Site or e-mails may contain links to other external websites that do not fall under our domain. We are not responsible for the privacy practices or the content of such external websites. If you choose to follow such links to external websites, you do so at your risk. 6.2 Cookies help us optimize and improve the user experience of the Site by helping us deliver crucial functionalities. The cookies we use may vary over time as we continuously update and improve our Site and Services. More information can be found in our cookie policy. 7.1 If you register an account with us, we will store your Information for as long as you have an active account. As soon as you delete your account, we will remove all Information we have collected about you unless we have appropriate legal grounds for continuing their processing. If your account has been terminated or suspended due to the breach of the Terms, we will keep your Information for up to two years in order to prevent repeated registration and to enforce suspension measures. 8.1 You may request to:

• Obtain confirmation if your Information is processed, access Information about you that we had stored as well as supplementary information.
• Receive a copy of Information on you that is held by Geolocate in a structured, commonly used and machine-readable format.
• Correct your Information.
• Have your Personal Information deleted.
• Object to the processing of Information by Geolocate.
• Restrict the processing of your Information by Geolocate.
• File a complaint with a supervisory authority.

9.1 We reserve the right to change our Privacy Policy at any time. The current version of our Privacy Policy is available through the Site, indicating the effective date. You are encouraged to periodically check our Privacy Policy. 10.1 If you have any queries or concerns regarding our Privacy Policy and how the information is handled, or you wish to access, retrieve, amend, or update your Information feel free to contact us at [email protected].