Effective: 07/30/2021.

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal data, when you participate in our Reseller Program (as defined in the Reseller Program Terms) and your rights and choices regarding your personal data. It applies to the processing of personal data we collect from you or about you when you use and interact with the Vendor website that displays or links to this Privacy Policy or when you apply for participation or participate in our Reseller Program or otherwise interact with us with regard to our Reseller Program.

When we use the terms “Movavi,” “Vendor,” “we,” “us,” or “our,” they mean Movavi Software Limited. Movavi has the greatest respect for your privacy and gives special attention to the confidentiality of information submitted to us when you are applying for participation or participating in our Reseller Program.

If you see an undefined term in this Privacy Policy, it has the same definition as in our Reseller Program Terms.

In our Reseller Program may participate either individuals or legal entities. With respect to personal data (as defined by applicable law), Movavi may be a Data Processor or Data Controller and Data Processor simultaneously. If Movavi is a Data Processor, it processes personal data in accordance with the Data Processing Schedule.

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, you should not use our website, apply for participation, or participate in our Reseller Program or otherwise provide us with your personal data. By using and/or accessing the Vendor website, applying for participation, or participating in our Reseller Program or otherwise providing us with your personal data, you acknowledge that you have read and understood this Privacy Policy. Your use of the Vendor website and participation in the Reseller Program is also governed by our Reseller Program Terms.

We collect certain information from you when you are using and/or accessing the Vendor website, participate or apply for participation in our Reseller Program. This information is further described below.

1.1. Information you provide to us while applying for participation or participating in the Reseller Program.

• Personal data and online identifiers, such as your name, address, phone number, email address, browser and device information such as your device’s Internet protocol (“IP”) address, unique device identifiers as well as hardware or operating system device identifiers (e.g., IDFA for iOS and AAID for Android).
• Commercial and transaction information, such as information about payments received.
• Information required if you are a Reseller, such as a name, address, phone number, email address, Taxpayer Identification Number (which may be an individual’s Social Security Number), payment information (e.g., bank details), VAT registration numbers, or other foreign tax identification numbers (for foreign legal entities).
• End User information. We may obtain personal data of the End User from the Reseller, for example, if the End User purchases a Vendor software license through such Reseller. The End User personal data we may receive may include business contact information, including mailing addresses, job titles, email addresses, and phone numbers.

1.2. Automatically collected information from your participation in our Reseller Program.

• Information about your behavior on the Vendor website. Such information may include information regarding your browsing, usage, and interactions; information that allows us to identify browsers and devices you have interacted with previously; the website you came from before and visited after; the region where your device is located; a network to which your device is connected; geo-IP data; and information related to the pages you are viewing on the Vendor website.
• Generalized information. To the extent permitted by applicable law, we also collect, create, process, and store information that is not personal data such as sets of aggregate data and other generalized information that does not reveal your identity. We retain the right to use and disclose information that is not personal data in any manner permitted by law.

We do not collect sensitive personal data such as sexual preferences, religion, political views, or health conditions. We will not request it from you, and neither do we need it.

Persons under the age of 13, or any higher minimum age in the jurisdiction where that person resides, should not provide us with personal information unless they have a verifiable permission of their parent(s) or legal guardian(s). The Vendor website, products, and services are not intended for children under the age of 13 or equivalent minimum age in the relevant jurisdiction. We do not knowingly collect personal information from children. If we learn that we have collected personal data of a child under the relevant minimum age without the consent of the holder of parental responsibility over that child, we will take steps to delete the information as soon as possible. Parents or legal guardians who believe that their child has submitted personal information to us and would like us to delete that information may contact us at partners@movavi.com.

We use, store, and process the information we collect from or about you for the following purposes: (i) to perform the Reseller Program; (ii) to provide, improve, and develop our services and products and comply with our legal obligations; (iii) to send periodic emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship; (iv) subject to your consent, to send promotional messages, marketing, advertising, and other information that may be interesting to you; (v) for administration or internal analysis; and (vi) to fulfill other commitments.

Your personal data may also be processed for additional purposes according to applicable law or agreements.

We may share personal data with our service providers as described below when it is necessary for the performance of the Reseller Program, provision of the services, information, or products to you, within the limits of the purposes listed above.

If the information submitted by you contains personal data, by applying for participation or participating in our Reseller Program, you freely and voluntarily grant us written informed consent to process that data for the purposes defined in this Privacy Policy. This includes any action (operation) or sequence of actions (operations) performed with or without using automated tools: collecting, recording, sorting, accumulating, storing, specifying (updating, changing), withdrawing, using, transferring (distributing, providing, or accessing) information to third parties, including cross-border transfer to other jurisdictions, disclosing or making available, anonymization, restriction, blocking, deleting, and destruction of personal data. The foregoing consent can be revoked at any time with immediate effect for the future by emailing us at partners@movavi.com.

You can opt out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or by sending us an email at partners@movavi.com.

Our Privacy Policy is based on the following principles:

• We process the provided data exclusively for the purposes and according to the methods provided when the data was collected.
• We use the collected data for purposes in addition to those for which it was released only when the Reseller has expressly consented to such usage.
• We let third parties access the provided data exclusively for the purposes described herein.
• We do not disclose the data, assign or transfer it to third parties for their own processing unless the Reseller has been informed in advance and has given their consent.
• We respond to requests for cancelling, changing, or adding the data provided.
• We ensure proper and lawful data management.
• We do not sell your personal data to any third party.
• We safeguard the privacy of Resellers and apply appropriate security measures to protect the confidentiality, integrity, and availability of the data provided.

We would like to make sure you are fully aware of all of your data protection rights. You are entitled to the following.

• Right to access. You have the right to request from us copies of your personal data.
• Right to rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
• Right to erasure. You have the right to request that we erase your personal data, under certain conditions.
• Right to restrict processing. You have the right to request that we restrict the processing of your personal data, under certain conditions.
• Right to object to processing. You have the right to object to our processing of your personal data, under certain conditions.
• Right to data portability. You have the right to request that we transfer the data that we have collected to another organization or directly to you, under certain conditions.
• Right to withdraw consent. If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
• Right to make a complaint with the data protection authority. If you have a concern about our privacy practices, including the way we handle your personal data, you can report it to the data protection authority that is authorized to hear those concerns.

If you would like to exercise any of these rights, please contact us at our email: partners@movavi.com.

We will not sell, rent, lease, or otherwise provide your personal data to others, except in order to perform the Reseller Program or provide you with the products and services you request and as further described below or with your permission or as required by applicable law.

• Service providers. We may engage other companies and people to perform tasks on our behalf, in which case they are helping us provide our services and perform the Reseller Program. In particular, we use third-party providers of payment processing, fraud prevention, and risk assessment, hosting and other information technology services, email communication and customer support services, partner portals, analytical services, statistical services, marketing, advertising, and investor relations. Following our instructions, these parties may process your personal data in the course of providing the relevant services to us.
• Affiliates. We may share your data with our affiliates for administrative purposes; for helping us perform the Reseller Program and our services, provide related customer support or to conduct sales and marketing activities on our behalf. For example, if you request information about a company or a service from us, then we may pass your personal data relevant to such a request onto another affiliated company to enable them to appropriately respond to your request.
• Business transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of a service to another provider, your personal data and other information may be transferred to a successor or affiliate as part of that transaction.
• Legal requirements. We may share your personal data so that we can comply with a legal obligation to which we are subject, protect and defend the rights or property of Movavi, act in urgent circumstances to protect your personal safety or that of the public, or protect Movavi against legal liability. For example, where we are obliged to share your personal data with regulatory bodies which govern our work and services; government departments such as law enforcement; courts; financial institutions; external auditors; etc.

If we collect your personal data, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under the applicable laws, but no longer than reasonably necessary in the light of the purposes above. We may need your personal data to establish, bring, or defend legal claims. For this purpose, we retain your personal data for 7 years after the date it is no longer needed by us for any transactions, fulfilling contract purposes.

This notice is designed to help you understand what cookies are, how Movavi uses them, and the choices you have in regard to their use. By continuing to use the Vendor website, you are agreeing to the use of cookies in the manner described in this notice.

Cookies are small text files that are stored on your browser or the hard drive of your computer or other device when you visit the Vendor website. This allows the Vendor website to recognize you as a user either for the duration of your visit (using a “session cookie”) or for repeat visits ( a “persistent cookie”). They are not harmful and do not contain any information such as your home address, date of birth, or credit card details.

There are a number of different types of cookies, however, the Vendor website uses:

• Strictly necessary cookies. These cookies are essential for helping you to navigate the Vendor website and use its features, such as accessing secure areas of the Vendor website. Without these cookies, the services you have asked for cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the Internet.
• Analytical/performance cookies. In order to keep the Vendor website and services relevant, easy to use and up to date, we use web analytics services to help us understand how people use the Vendor website. For example, we can see which parts of the Vendor website are most popular, identify when errors occur, and test different versions of a page or feature to see which one works best.
• Functionality cookies. These cookies allow websites and applications to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. The information these cookies collect is usually anonymized, which means we cannot identify you personally. They do not gather any information about you that could be used for selling, advertising, or remembering where you have been on the Internet but help us provide advertising that is more relevant to you.
• Targeted marketing cookies. We also use cookies to assist in targeted advertising. Without these cookies, online advertisements you encounter will be less relevant to you and your interests. We also use them to measure the effectiveness of our marketing communications, for example, by telling us if you have responded to an advert that we have sent you. The information stored in cookies is safe and anonymous to any external third party, and your account security is never compromised. For information on how to disable cookies, please consult the “Help” tab of your browser via the menu bar. Should you need any help, please contact us via email at partners@movavi.com.

We take appropriate technical and organizational measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal data. This includes the necessary physical, electronic, and managerial procedures designed to protect data integrity, access, and use.

Amendments. This Privacy Policy may be amended or updated by us at our sole discretion without prior notification. We recommend that you regularly read the latest version of the Privacy Policy. A new version of the Privacy Policy is effective from the moment of its publication unless specified otherwise by such a new version of the Privacy Policy.

Governing law. This Privacy Policy, including its construction, method of adoption, performing, amending, and termination is subject to legislation of the Republic of Cyprus.