Privacy Policy/Notice at Collection

1. 1. Information Available Through Searqle

   Searqle collects publicly available information for the purpose of making it available to users that use Searqle. Searqle aggregates the following categories of publicly available information of individuals:

   • - email
   • - phone number
   • - first/last name
   • - age
   • - sex
   • - address/city/country

   (Collectively the “Information”).

   Searqle does not verify and cannot guarantee the accuracy of this Information. It is prohibited for users of Searqle from reselling the Information disclosed to them through Searqle.

   Personal data, such as information that You provide to Searqle or information about Your use of Searqle as further described below, is not part of the Information available to users through Searqle.

   To request that Information about You be removed from public listings on Searqle, please use the Remove a Public Listing tool at Your Rights Exercising Form. This page also contains information about alternate ways to submit a request for the removal of Information about You from public listings. This process is only intended to remove listings available to the general public on Searqle and cannot remove the information from the third-party public sources, such as phone books, social networks, or government records.

2. 2. Personal Data Collection and Use

   Anyone can access our Website without necessity to provide its personal data.

   The purpose of processing your personal data by the Company and collection of information about you are as follows (the “Purpose”):

   • Your intention to use Searqle;
   • For the performance of a contract to which the user is a party, and the collected data are necessary in order for Searqle to identify and bill the user and to charge its bank card number;
   • For verifying your identity and providing customer care service and assistance;
   • Analyze your use of our Website and Searqle to better understand how they are being used so we can improve our services and the user experience, and engage and retain users.

   We may use your personal data to: (a) improve your browsing experience by personalizing the Website and to improve the Searqle; (b) send information to you by email regarding registration status, password verification, payment confirmation; (c) send you communications relating to your use of the Searqle, and (d) provide our partners/providers with statistical information about our users by secured channels under agreements (if applicable); (e) send you marketing and promotional materials and messages.

   As you are willing to use Searqle you are required to provide your personal data (to register an account and purchase the Searqle), thus becoming a user of Searqle.

   Please be aware that you are not obliged to provide us with your personal data. However, if you do not provide us with your email address and payment information, you may not be able to create an account to log into and make a purchase of Searqle.

3. 3. Scope and Categories of Personal Data, Lawful Basis For Personal Data Processing and Data Subject Categories

   We strive to be compliant with data privacy regulations and implemented data minimization principles.

   No.	Scope and categories of personal data	Data subject categories	Processing purpose	Lawful basis for personal data processing
   1	e-mail address, your name	Searqle users	To provide Searqle; to communicate information about Searqle services;	Performance of a contract
   2	e-mail address	Searqle users	To send marketing communications	Consent
   3	IP address	Website users	To provide the features of the Website	Legitimate interest
   4	Location data - for statistics of user's areas involvement	Website users	To provide the features of the Website	Legitimate interest
   5	Automatically collected data (cookies and similar technologies, device and connection data)	Website users	To provide the features of the Website	Consent
   6	Usage data. Searqle gathers data regarding your utilization of Searqle and/or Website, which encompasses the webpages you access, the links you interact with, and the products you buy. Additionally, Searqle captures details concerning your device, such as IP address, device identifiers, and information pertaining to the network, operating system, or software you use to connect to Searqle.	Website users	To provide the features of the Website/Searqle	Legitimate interest
   7	Search History. Searqle retains a history of the searches you conduct on Website.	Website users	To provide the features of the Website/Searqle	Legitimate interest

   The storage of this data takes place against the background that this is the only way to prevent the misuse of Searqle, and, if necessary, to make it possible to investigate committed offenses.

   The personal data are not transferred to third parties, except events, when it’s necessary with an aim to provide Searqle (to our service providers) and/or there is a lawful obligation to transfer these data under request of government authorities and/or the transferring is executed in respect of criminal proceedings.

   We do not authorize the use of your personal data by any third party (only under exceptional conditions as described under "Legal Matters" below). We operate and maintain a variety of online security measures to safeguard and keep your personal information private and secured.

   When you purchase the Searqle you have to fill the user’s information, which should contain your personal information as email, phone number, or your name which is processed and stored by us.

   You also have to fill the payment Information, which should contain your personal data, which might be partly processed by us and processed by the payment providers.

   Based upon the personal data you provide us at registration of an account, we may send you a welcoming e-mail to verify your login and password.

   You may enter to your account on our Website under login and password sent to your email. All your activity in your account is password-protected, and you should keep and take all necessary measures to protect the secrecy of your password.

   We will also communicate with you in response to your inquiries, regarding any information or services you request.

   Based on your separate consent, we may send you the marketing emails. You may always opt-out (unsubscribe) from any communication in your account (except operational and/or non-marketing notification as following: payment acceptance, payment notification, necessary updates notification, refunds issue etc.).

   All personal Data is stored in encrypted way on Searqle servers with using of the last encryption and protection technologies and standards.

   If you use a computer in a public place or share a computer with others, remember to log out/sign out and close your browser window when you finish accessing Searqle in order to prevent others from accessing your personal information. You are solely responsible for the control and use of each password you create.

   Payment information

   We implemented all necessary measures and standards in an area of payment security for Searqle. We cooperate with different payment service providers and before our cooperation we check them according to our policies for the availability of licenses and other permits for the acquirer transactions. Within a payment execution you provide the following information to the payment service provider: (i) credit/debit card number; (ii) expiration date of credit/debit card; (iii) your full name; (iv) your e-mail. This information might be partly collected and stored by us or the payment service provider (if applicable).

   Data that we collect automatically.

   We also collect and store information that is generated automatically as you navigate through our Website to enhance your experience on our Website by using tracking technologies such as Cookies, Log Files and Pixel tags.

   As you navigate our Website(s) information that we automatically collect is information in "log files" about your device’s connection to the Internet, length of time spent on the Website, and the pages accessed during each visit to the Website. We use this information to analyze trends, administer the Website, track user movement on the Website, and gather broad statistical information for aggregate use.

   Our Website uses cookies.

   Cookies are text files that are stored in a computer system via an Internet browser. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Website, Cookies help us track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Website where you have entered preference information before. Cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

   Through the use of cookies, we can provide users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimized with the user in mind.

   The data subject may, at any time, prevent the setting of cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of Cookies.

   Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of Cookies in the Internet browser used, not all functions of our website may be entirely usable.

   If you do not wish to receive Cookies you may be able to refuse them by adjusting your browser settings to reject Cookies. If you do so, we may be unable to offer you some of our functionalities, services or support. If you have previously visited our Website, you may also have to delete any existing cookies from your browser.

   Also, we may use Pixel tags (single-pixel image files also known as transparent GIFs, clear GIFs or web beacons) to access Cookies and to count users who visit the Website or open our HTML-formatted e-mail messages.

   Please, find the detailed information in our Cookie Policy.

4. 4. Encrypted Data

   We have put in place security hardware, software and software update and network scanning procedures designed to safeguard and secure the information (including personal data) under our control and follow generally accepted industry standards. We work (if applicable) with third party service providers and vendors that use encryption and authentication to maintain the confidentiality of your personal data. If stored, we house personal data on systems behind firewalls that are only accessible to limited personnel, who are under data processing agreement.

   We store personal data of all our users in an encrypted way. We use asymmetric public-private key cryptosystem RSA with key size is 4096 bit (further RSA) and symmetric-key algorithm AES with key size is 256 bit (further AES).

   Asymmetric public-private key cryptosystem RSA (key size is 4096 bit) use public encryption key and private decryption key. The public encryption key is storing in database (DB) in open way. The private decryption key is storing in DB encrypted using AES 256 using key which consist of the user’s password and secret key. It cannot be decrypted without user’s password and secret key.

   User’s credentials are user’s login is stored in DB. User’s password is not stored. We store only hash of the password. We generate public-private key pair for cryptosystem RSA during user’s sign up. This public-private key pair is unique for each user. The key pair is stored in DB encrypted format using AES 256.

   Login process: We use user’s password from login form for decrypting user’s original private key.

   Encryption data: We get opened data from devices using encrypted https protocol. We immediately start encryption process of the data on the server in the RAM without storing on server`s disks. We encrypted data using RSA using user’s public encryption key. The encrypted data is saved to our servers.

   Decryption: We get user’s decrypted private key. We decrypt user’s text data using user`s original private decryption key. We show this information to user.

5. 5. Legal Matters

   • comply with the law or legal process served on us;
   • enforce and investigate potential violations of this Privacy Policy, Terms of Use; including use of this Service to participate in, or facilitate activities that violate the law;
   • legitimate interest, including investigate potential fraudulent activities;
   • protect the rights, property, or safety of our Company, its employees, its customers or the public;
   • to provide the features of the Website and Searqle properly.

   In the event of a change of control of Searqle (such as asset transfers through a merger, sale, assignment or liquidation of the business entity, or any of its properties, assets or equity) or, in the event of a direct or indirect sale of any of its publishing properties and/or its Website(s)in our possession will be transferred to the new owner/successor. You will be notified of any such transaction and have an ability to exercise your legal rights under GDPR. You may always change or delete your personal data or opt out by contacting us as provided below, or if the acquirer posts a new Privacy Policy with new contact information, you may change or delete your personal data or opt out by following any new instructions that are posted.

   Searqle may use certain trusted third parties service providers to help us provide, improve, and protect the services offered on the Website. Searqle shares Personal data with these third parties service providers. These third parties service providers will access your information only to perform services on Searqle’s behalf, in compliance with this Privacy Policy, and under the respective agreements. For example, Searqle may provide payment information that you provide to certain payment processors (if applicable), without which a user would not be able to purchase the and solely to effect the sale of products or subscriptions that you have requested, and provides other personal data to third party service providers for purposes such as delivering email communications, providing customer support, and preventing fraudulent transactions.

   Searqle may share IP addresses used to access Website with designated third parties service providers for the sole purpose of preventing and detecting fraud. Searqle may also use services and technologies provided by other companies to assist Searqle in understanding how you use Website. As a result, information about how you use Website may be available to these other companies to the extent that their technology collects such information for Searqle’s use or for purposes of delivering relevant online or mobile advertising to you.

   As we use third party technological services for the provision of Services, we may transfer your personal data internationally. Providers of such technological services may process personal data collected in the course of providing us their services as service providers only uunder the respective agreements.

   Except as specifically noted in this Privacy Policy, Searqle does not sell, exchange, transfer, or give personal data to any other company.

   In case there might be a risk of unauthorized disclosure of personal data the Company communicates the personal data breach to the user (data subject) without undue delay. However, the encryption is useless if the access password or other credentials are weakly protected and stored by user. In this case the Company is not responsible for personal data breach. In the case of a personal data breach, we, as a business, shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the competent supervisory authority.

6. 6. Where Data Subject’s Personal Data Are Stored

   Usually, personal data, which are provided by users are stored on the servers in Germany and Netherlands. We adopted all necessary security measures for protection of your personal data according to the best practices of security, protection and confidentiality. If we transfer your personal data to third party service providers, we will compel each third-party service provider to adopt necessary security measures for protection of your personal data according to the respective data protection agreement.

7. 7. Your Rights

   You may ask Company to disclose what personal data it has about you and what it does with that information, to delete your personal data, to direct Company not to sell or share your personal data, to correct inaccurate information that it has about you, and to limit Company’s use and disclosure of your sensitive personal information:

   • - Right to know: You can request that a Company discloses to you: (1) the categories and/or specific pieces of personal information it has collected about you, (2) the categories of sources for that personal information, (3) the purposes for which the Company uses that information, (4) the categories of third parties with whom the Company discloses the information, and (5) the categories of information that the Company sells or discloses to third parties. You can make a request to know up to twice a year, free of charge.
   • - Right to delete: You can request that Company delete personal information it collected from you and tell it service providers to do the same, subject to certain exceptions (such as if the business is legally required to keep the information). Company cannot delete Personal Information that it is under a legal obligation to maintain.
   • - Right to opt-out of sale or sharing: You may request that Company stop selling or sharing your personal information (“opt-out”), including via a user-enabled global privacy control. Company cannot sell or share your personal information after they receive your opt-out request unless you later authorize it to do so again.
   • - Right to correct: You may ask Company to correct inaccurate information that it has about you.
   • - Right to limit use and disclosure of sensitive personal information: You can direct Company to only use your sensitive personal information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the services you requested.

   If one of the aforementioned reasons applies, user may at any time contact us via email support@searqle.com or submit the respective request via the link Your Rights Exercising Form. We shall promptly ensure that the request is complied with immediately.

   Searqle will not discriminate against You for exercising Your rights under this section of this Privacy Policy.

8. 8. Children's Privacy

   Provision of Searqle generally not aimed at children. This Website is not intended for use by children under the age of 18. The Company is acting in compliance with COPPA. We do not knowingly collect information from children and minors. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Website without their permission.

   Our Website and Service is not directed to, nor do we knowingly collect personal data from children under the age of 13. If we obtain actual knowledge (including via email support@searqle.com) that we have collected personal data from a child, we will comply with industry guidelines and applicable laws and will promptly delete it, unless we are legally obligated to retain such data.

   Searqle does not knowingly aggregate or provide Information about people under the age of 18. Searqle’s email search may return Information about children between the ages of 13 and 18 because this Information originates from third-party social networking sites and websites that permit children who are 13 years and older to create public profiles. To remove any Searqle listing, including a listing that contains information about a person under the age of 18, please use Remove a Public Listing tool at Your Rights Exercising Form.

9. 9. Data Retention

   The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period and when we no longer need personal data, we routinely and securely delete or destroy it, as long as it is no longer necessary to achieve the Purpose. As the business we shall process and store the personal data of the user (data subject) only for the period necessary to achieve the purpose of Searqle provision, or as far as this is granted by the laws or regulations to which the Company is subject to.

10. 10. Miscellaneous

    We may modify this Privacy Policy at any time and post any changes to the Privacy Policy on the Website, so please review it frequently. We indicate the date of the current version of this Privacy Policy above, so you know when it was last updated.

    Changes to this Privacy Policy may not affect your personal data we have previously collected from you or after such changes.

    If you object to the changes, please contact us as provided below.

    This Privacy Policy is governed by and construed with the laws of Delaware.

    Any claim or dispute which might arise out of or in connection with this Privacy Policy shall be settled in accordance with provisions of ToU.

    If you have any questions or propositions, please, get in touch with us by the e-mail: support@searqle.com.