Privacy policy

Your use and access to https://praa.ms, including any of its subdomains and linked and mirrored websites and webpages as well as mobile applications and associated social media platforms, branded or non-branded (“Website”), which are owned and maintained by PRAAMS SLU, its employees, officers, directors, shareholders, affiliates, subsidiaries, successors and assigns and other affiliated and related entities and individuals and their agents (“PRAAMS”, “we”, “our”, “us”) as well as contractors, subcontractors, suppliers and other legal and individual persons arising in connection with provision and sale of Information and their agents (“Counterparties”) are governed by this Privacy policy (the “Policy”), the Terms of service (the “Terms”) and other policies and terms of PRAAMS. PRAAMS offers access and use of the Website and the Information as defined below and in the Terms to you conditioned upon your acceptance of the Policy, the Terms and other policies and terms of PRAAMS and Counterparties as published on the Website and resources owned and managed by Counterparties. If you do not agree with this Policy, Terms or other policies and terms of PRAAMS, please do not use and access the Website.Definitions and Collection of Information Cookie is a small text file placed on your device when browsing the Website. Our policy regarding the use of cookies is explained in our Cookie Policy.Data Controller and Processor is a person who determines the purposes and how personal data is collected and processed. Regarding the Website and this Policy, PRAAMS is your data's Data Controller and Processor.Data Processor (or Service Provider) is a person who collects and processes the data on behalf of the Data Controller. We use the services of several independent and regulated Service Providers to process your data efficiently and safely.GDPR is the General Data Protection Regulation (EU 2016/679).Financial Data is information related to your payment method, including but not limited to credit card number, card brand, and expiration date. For analytical purposes, we collect limited and personally-unidentifiable Financial Data such as, for example, the name of the card networks (e.g., Visa, Mastercard) and only the last four digits of the PAN (e.g., *1234) when you purchase, order, gift, return, exchange, or request information using the Website. We rely on external Counterparties and Service Providers who, as we believe, can process and store your data safely and efficiently and in accordance with the applicable laws, rules, and regulations, including PCI-DSS standards. Our payment processors keep all Financial Data, and we strongly encourage you to review their terms and policies.Personal Data is information about an individual who can be identified from this data, including but not limited to email address, Usage Data (as defined below), watchlists, and portfolio data. We respect your privacy and strive to collect as little personal information as possible. At the same time, to make your use of the Website and the Information easier and more pleasing and being subject to the laws, rules, and regulations on personal data, from time to time, we ask you to provide us with specific personal data. The primary uses of this type of data are account management and contact purposes such as newsletters, marketing and promotional materials and other information that may interest you. You are not obliged to provide any Personal Data to us, though failing to provide it may prevent you from enjoying certain valuable features and functionality of the Website, including account creation. User is the individual using the Website and the Information (as defined in the Terms). Usage Data is the information collected automatically and generated by the use of the Website or the Information (as defined in the Terms) or from the associated infrastructure, including but not limited to IP address, browser type and version, the pages of the Website you visited along with the time, duration and sequence of the visits, unique device identifiers, language and other user-defined system preferences, device name and type, operating system, your country and location of your device, other interactions with the Website and mobile application, diagnostic data, mobile device ID, model and manufacturer, and additional information you choose to provide to us and through permitted system preferences. Please note that your system preferences, as set by you in your browser, operating system and/or mobile phone, and settings associated with your Google account and Apple ID, may allow for automatically sharing more data with us.Use of informationWe may use your information, collected as mentioned above, to:
  • Offer efficient, pleasing and customised user experience of the Website and Information,
  • Communicate with you, including via email, regarding the creation and management of account, including the creation of a personalised profile, watchlists and portfolio lists,
  • Communicate with you, including via email, regarding the fulfilment and management of orders, purchases, payments, refunds, and other related transactions on the Website,
  • Offer targeted and general newsletters, marketing or promotional materials, updates on the Website, offer and promote new products, services and tools, or other information, which, as we believe, may be of interest or use to you,
  • Collect anonymous statistical and analytical data for internal use and third parties to improve the user experience and enhance the operation of the Website,
  • Perform other business activities as needed, including but not limited to providing customer support, responding to customer requests and questions regarding the use of the services and tools of the Website, requesting feedback, resolving disputes, detecting, preventing and addressing problems and technical issues, and solicit support for the Website,
  • Prevent and monitor fraud, including theft, protect against other criminal activity, as well as assist law enforcement when we are obliged by law to cooperate with the courts, officials, regulators, public authorities and other law enforcement institutions,
  • Perform other activities permitted by laws, rules, and regulations.
Disclosure of informationWe may use your information, collected as mentioned above, for the following purposes, and we do not share any of your information with the third parties engaged in marketing, advertising, and promoting products and services. Third-party Service Providers. We may share your information with third parties and Counterparties, including but not limited to payment processors, email service providers, data analysis providers, security and hosting services, and customer and market service providers. Law enforcement and protection of others. If sharing your information is required by the laws, rules or regulations or is necessary, as we decide in our sole discretion, for a legal process or investigation, including those related to violations of our terms and policies, or to protect the rights, property, and safety of others, including protecting us against legal liability, or to prevent any fraudulent or potentially fraudulent activity, we may share your information as permitted and required by the applicable laws, rules, and regulations. PRAAMS Group. We may share your information with our affiliates or members of the PRAAMS Group (the “Group”), which will honour this Policy and the Terms, including but not limited to signing non-disclosure agreements. The Group includes parent and subsidiary companies, ultimate beneficiary owners and prospective investors, and other companies we control or are under our common control. Third-party websites and applications. The Website may contain links to third-party websites and applications. The Policy does not cover the information you provide to these websites and applications, and we do not guarantee the privacy and safety of your data. We are not responsible for the practices and policies of any third parties regarding the collection, use and sharing of your information. We strongly recommend that you inform yourself of the rules and policies of these third-party websites and applications before using and accessing them. Security of informationWe use required technical, analytical, administrative and physical security measures to protect your personal data. Although we have taken reasonable and necessary steps to secure the personal information, including but not limited to encryption, selection of trusted and reputable service providers, and limitation of the amount and breadth of personal information collection, we warn you that no security measures could be sufficient, no data security systems are impenetrable, and no method of internet-based data transmission or method of electronic storage can fully guarantee the absence of interception or another misuse. Therefore, we and our Counterparties cannot fully guarantee the complete security of your data.If we learn of a breach of security systems under our control or those of our Counterparties, we reserve the right to notify you by email so that you can take appropriate steps. By using and accessing the Website, accepting the Terms and the Policy, or providing personal information, you agree to our right to communicate via email regarding security and privacy issues relating to your use of and access to the Website.“Do not track” (“DNT”) signalsDNT is a usage preference setting in your browser to inform third-party websites that you do not want to be tracked. You can select or change the DNT preference setting in your browser.Policy for childrenWe do not intend to and do not knowingly solicit information from, market to or provide our services to children under 18. If you become aware that we have accidentally collected any information from children under the age of 18, please get in touch with us using the contact information provided below, and we will take the necessary steps up to the termination of an account and deletion of all of the information provided by this person. We strongly appreciate your cooperation. Your options and rights regarding informationYou can review, update, correct, rectify, or change your account information and preferences or terminate your account anytime. You can do this by changing or updating your account settings on the Website, or you can contact us using the contact information below with such a request. Account termination means the complete deactivation and deletion of your account and all the associated data from our active databases without our ability to restore it. At the same time, we warn you that certain information required by laws, rules, and regulations or necessary, as we decide in our sole discretion, to protect the rights, property or safety of others, including protecting us against legal liability or to prevent any fraudulent activity and Usage Data will be retained in our passive databases. The period during which we will keep the data is determined by the applicable laws, rules, and regulations and by our internal data policies.You can opt-out of receiving any email communication or correspondence from us anytime. You can do this by changing or updating your account and profile settings on the Website, or you can contact us using the contact information below with such a request. This provision does not cover third-party email communication or correspondence; you shall contact them directly. You are responsible for keeping the account information and unique password; failure to protect this information is your own risk. At any time, you can contact us using the contact information below with the following requests:
  • If you are unable to access or change the information provided to us, including Personal Data,
  • If you want to know what Personal Data we hold about you,
  • If you want to receive a copy of the information we hold about you, including Personal Data,
We will process your request within 30 days once we obtain all the required information. You have the rights associated with your personal information, its collection, use, disclosure, and safety as stipulated by the GDPR. Transfer of dataYour information is subject to transfer and maintenance on servers outside your state, province, country or another form of governmental jurisdiction where the data collection, use, disclosure, and protection laws, rules, and regulations may differ from those of your jurisdiction. We and our Counterparties transfer your data, including Personal Data, to the GDPR-compliant servers and cloud services located in European Union and Andorra and process it there. Your use of and access to the Website and the Information, as defined in the Terms, serves as consent to the Policy, and the submission of such data represents your agreement to such transfer.Changes to the PolicyWe reserve the right at any time and without prior notice and in our sole discretion to change, update, withdraw, amend, or replace the Policy, in parts or entirety, including but not limited to changing all or any portion of the Policy, the Website or the Information, as defined in the Terms.The updated Policy will be posted on the Website. We reserve the right not to notify you about changes, updates, withdrawals, amendments, replacements or any other Policy modification by email. You are responsible for checking the Website periodically for changes, updates, revisions, replacements or any further modification of the Policy. You agree and acknowledge that your continued access and use of the Website and Information constitutes legally binding acceptance of these changes, updates, amendments, replacement or any other modification of the Policy. Contact usIf you have questions or comments about the Policy, please get in touch with us at [email protected]LAST UPDATE 12 JUNE 2023