Privacy Statement

Effective: 26th November 2020

This Privacy Statement explains how Menetray OÜ. (“Menetray, “we,” or “us”) collects and uses your personal information to provide our services to you. This Privacy Statement applies to the personal information we collect when you use our websites, mobile applications and other online products and services (collectively, the “Services”) or when you otherwise interact with us. This Privacy Statement does not apply to websites, applications, or services that display or link to other privacy statements.

We may change this Privacy Statement from time to time. If we make changes, we will notify you by revising the date at the top of this page. If we make material changes, we will provide you with notice through the Services or through other means, such as email. We encourage you to review the Privacy Statement whenever you access the Services or otherwise interact with us to stay informed about our privacy practices and the ways in which you can exercise choice over these practices. The practices described in this Privacy Statement are subject to applicable laws in the locations in which we operate; this means that we only engage in the practices described below in a particular location if permitted under the laws of that location. Capitalized terms used but not defined in this Privacy Statement have the meanings given to them in the "Terms of Service".

How Do We Collect and Use Your Information?

The information we collect varies based on how you interact with us, which Services you use, and the choices you make. We collect and process information about you with your consent and/or as necessary to provide the products and services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

We collect information about you in various ways when you use our Services, including information you provide directly, information collected automatically, and information collected via third-party data sources.

When you are asked to provide information, you may decline. But if you choose not to provide information that is necessary for certain products or features, those products or features may not be available or function correctly.

How Do We Share Your Information?

We may share the personal information we collect with third parties as follows or as otherwise described in this Privacy Statement:

• when you make or accept a connection with another user.
• when you sign up for and participate in the interactive areas of our Services, such as creating a user profile or writing a review.
• with vendors, consultants, business partners, and other service providers who need access to such information to carry out work on our behalf.
• In response to a request for information if we believe disclosure is in accordance with or required by, any applicable law, regulation or legal process.
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property or safety of Menetray OÜ, its employees, its users or the public.
• in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, divestiture, bankruptcy, dissolution, or other transaction or proceeding involving sale, transfer or divestiture of all or a portion of our business or assets to another company, to the extent permitted under applicable law.
• between and among Menetray OÜ and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.
• on an aggregated and anonymized basis.
• With your consent or at your direction.

Social Sharing Features

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of information collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Third Parties

We may allow others to provide analytics services and/or serve advertisements on our behalf across the Internet. These entities may use cookies, pixel tags, web beacons or other similar technologies to collect information about your use of our websites and third-party websites. To learn more about how these third parties use these technologies and how to manage your preferences, please read our "Cookie Policy". Note that if you opt-out of third-party advertising cookies, you will still see online ads, but they will not be personalized.

Information Security

Menetray OÜ takes reasonable measures designed to help protect information about you from loss, theft, misuse and unauthorized access, use, disclosure, alteration, and destruction. Please be aware that no method of transmission over the Internet or through mobile applications is 100% safe. Therefore, although we use commercially reasonable means to protect your information, we cannot guarantee its absolute security.

Transfer and Location of Information

The information we collect may be stored and processed in your region, in the United States, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. The processing locations are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the information in the event of an outage or other problem. We take steps designed to ensure that the information we collect under this statement is processed according to the provisions of this statement and applicable law wherever the information is located.

We transfer information from the UK, European Economic Area, and Switzerland to the United States and other countries that have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including executing the Standard Contractual Clauses approved by the European Commission, to help ensure your rights and protections. To learn more about the European Commission’s Standard Contractual Clauses, please click here.

Information Retention

We retain information for as long as necessary to provide the products and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different information types in the context of different products, actual retention periods can vary based on criteria such as user expectations or consent, the sensitivity of the information, the availability of automated controls that enable users to delete information, and our legal or contractual obligations.

Your Choices

Managing Your Account

You may update, correct or delete certain information about you at any time by logging into your account through our website or our mobile application and navigating to the ‘Profile’ link. If you need assistance, you may contact us using the contact information below.

If you wish to deactivate your account, please contact us using the contact information below. We may decline requests that are prohibited by law, could adversely affect the privacy or other rights of another person, where we are unable to authenticate you as the person to whom the information relates, or are not required to be honored by applicable law.

Location Information

When you first install or launch any of our mobile applications that collect location information, you will be asked to consent to the application’s collection of this information. We require location information to use certain features of our Services, so if you do not consent to this collection, you cannot use those features. If you initially consent to our collection of location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, certain features of our mobile applications will no longer function. You may also stop our collection of location information by following the standard uninstall process to remove our mobile application from your device.

Emails

You may choose whether you wish to receive marketing emails from us by updating your “Notifications” preferences under “Account Settings” in your online profile or through our mobile application. If you receive marketing emails and you wish to opt-out, you may also do so by clicking “Unsubscribe” in those emails. If you opt-out of receiving marketing emails, we may still send you Service-related emails, such as those about your account or your ongoing business relationship with us.

Mobile Push Notifications/Alerts

We may send push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Text messages

With your consent as required by applicable law, we may send marketing and/or service-related text messages to your mobile device. You may opt-out of receiving these messages by following the prompt in an individual message or updating your “Notifications” preferences under “Account Settings” in your online profile or through our mobile application. However, if you are a Service Provider in the U.S. or Canada, certain Services that you provide (as detailed in the Menetray OÜ Service) may require you to receive service-related messages. If you do not want to receive these service-related text messages, then in addition to adjusting your Notifications preferences, you must withdraw from providing such Services.

Cookies

Refer to our "Cookie Policy" for information on how to manage your choices with cookies used on our website.

UK and European Economic Area Data Protection Rights

If the processing of your personal data is subject to UK or EEA data protection law, then in addition to the controls listed above, you have certain rights with respect to that information:

• You can request access to or rectification of your personal data.
• You can request deletion of your personal data. However, please note that a request to delete your personal data may be restricted if there is a valid legal reason to retain it and may continue to be retained by third parties with whom you communicated through the Menetray OÜ Service. We may also retain cached or archived copies of information about your account for up to a year;
• If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
• You may have the right to request your personal data in a format in which it can be transferred to another provider;
• You can object to our processing of your personal data if that processing is based on the “Legitimate Interests” basis set forth above; and
• For residents of France, you can send us specific instructions regarding the use of your information after your death.

UK/EEA Data Subject Rights

If you wish to exercise your UK or EEA data subject rights, please contact us. Please note that we may ask you to verify your identity and request before taking further action on your request.

If you wish to escalate your inquiry after contacting our Privacy Team, you are welcome to contact our Data Protection Officer.

You also have the right to lodge a complaint with a regional supervisory authority, but we encourage you to first contact us with any questions or concerns.