Europe Privacy Policy

This Europe Privacy Policy (the "Policy") sets forth the principles and procedures followed by VIRTUAL NETWORK LAB LLC FZ and its affiliates (hereinafter collectively referred to as "Peerobyte", "We", "Us"), the owner and operator of the website peerobyte.com (hereinafter referred to as the "Site"), with respect to the collection, processing, storage and use of personal data of its users under the jurisdiction of the European Economic Area (EEA), the United Kingdom or Switzerland (hereinafter referred to as "You", "Customers", "Users").

1. General Provisions

1.1. This document forms an integral part of the Peerobyte Customer Agreement (the "Agreement") in the event that you are located in the jurisdiction of the European Economic Area (EEA), the United Kingdom or Switzerland.
1.2. Terms used herein and not defined herein are defined in the text of the Agreement.
1.3. This document supplements the Peerobyte Privacy Policy and applies to users subject to the jurisdiction of the European Economic Area (EEA), the United Kingdom or Switzerland. In the event of any inconsistency between this document and the Peerobyte Privacy Policy, the terms of this Policy shall prevail.
1.4. This document, in accordance with the European Union General Data Protection Regulation and the UK General Data Protection Regulation (collectively, the "GDPR"), notifies and clarifies the policies We use on the Site regarding cookies, the collection, use, transfer and disclosure of personal data by Us, and contains other legal notices regarding personal data:
• collected automatically through the Site.
• The information you enter when you register an Account on Our Site, subscribe to Our Services, or otherwise use Our Services.
• collected in the course of Our commercial activities carried out elsewhere, where We act as the controller of that data and where its processing is subject to the requirements of the GDPR.
1.5. This Policy does not apply to personal data collected, stored, transferred or distributed by third party sites.
1.6. As part of its obligations under personal data protection legislation, Peerobyte acts as the controller of the collection, processing and storage of personal data collected from You, whether through Our Site, in the course of providing the Services or in the context of Our business activities with customers and partners. In the context of this Policy, personal data means any information relating to an individual that can be identified or ascertained.
1.7. We reserve the right to make changes to this Policy at any time and in any manner. An updated or revised version supersedes all previous versions of this Policy immediately upon posting. Your use of the Site or Services following the posting of such changes means that you accept the revised Policy.
1.8. An up-to-date version of this Policy is posted on Our Website.
1.9. You should periodically check this Policy for changes by revisiting the Site, refreshing the page and noting the date this Policy was last modified, which is listed at the top of this document.
1.10. If We make any changes to this Policy that may materially affect Our policies and procedures with respect to the personal information We have previously collected from You, We reserve the right to notify You of such changes by sending You a letter to Your email or a message to Your personal Account area on Our Site.
1.11. Peerobyte is not responsible for the content or privacy policies of external sites linked from Our Site, as they are operated by third parties. We strongly encourage you to read the privacy policies of these sites before using them. This Policy is limited to the processing of personal data collected directly through Our Site or as part of Our activities.

2. Data collection

2.1. We automatically record information generated by your browser or device when you visit Our Site or use Our Services, including: your domain; your IP address; the date, start time and duration of your visit to the Site or use of the Services; the type of browser you are using; your operating system; information about the pages you have viewed; information about you and your device obtained from third-party sources; Internet traffic; and other data about your computer or device.
2.2. We do not automatically apply automatically collected information, which may include personal data and is collected when you visit the Site or use the Services, to attempt to identify you personally and do not associate it with data you provide to Us on your own initiative.
2.3. Our Site uses cookies, the policy on the use of which is detailed in the Cookies Policy document which forms an integral part of the Agreement.
2.4. We may receive data about you from third parties, namely MaxMind and Kount.
2.5. In order to access certain areas and functionality of Our Site, to receive or make full use of Our Services, to interact with Us or to initiate such interaction, You may be required to provide Us with certain personal data, the nature of which depends on the extent of Your involvement. Personal Data is required for Us to enter into a contractual relationship with You, for example, to prepare for entering into a supply contract or to provide information about Our Services and for the direct performance of the contract, i.e. the provision of the Services. Failure to provide such data may prevent Us from providing the Services to You as required by law.
2.6. Users are required to provide information such as name, address, email, phone number and other information necessary for billing and payment for the Services in order to receive Our Services.
2.7. Site visitors, current and potential suppliers, and subscribers may provide personal information by filling out forms, such as feedback forms, on Our Site, at trade shows or any other location where We do business, by downloading documents from the Site, by signing up for newsletters or other communications, or by communicating with Us via telephone, messenger or email. Typically in such cases, Your personal information will include Your name, company name, company address, e-mail address, telephone number and any other information necessary to address inquiries or complaints.
2.8. Users registering on Our Site are required to provide their e-mail address.

3. Data storage

3.1. We use a number of measures, including data encryption, to protect the confidential information transmitted to end users. While We make reasonable efforts to maintain the integrity and security of Our networks and systems, We cannot eliminate the risks of unauthorized access to this information by third parties. While We take all reasonable precautions to minimize the risk of security breaches, We cannot guarantee complete protection against cyber criminals seeking to illegally access data. We recognize that there is a risk of security breaches despite the measures We take, and You accept this risk by using Our Services and entrusting Us with Your personal information.
3.2. We retain personal data for as long as necessary to fulfill the purposes for which it was collected. Generally, the retention period for personal data is subject to an appropriate statute of limitations so that We can have up-to-date information about Your relationship with Us.
3.3. We may reduce or increase the retention period for personal data and retain it for as long as We need to, for example, if required to do so by law, tax or accounting records, litigation, a supervisory or regulatory authority, or any other organization that has the right to make inquiries regarding personal data.
3.4. We retain your personal data for marketing purposes for 18 months after your last inquiry or other contact initiated by you.

4. Data utilization

4.1. We are not in the business of selling or renting your personal data to third parties.
4.2. We use anonymized and aggregated data, such as that collected automatically, to customize Our marketing strategies and to optimize user interaction with Our Site by improving its structure, functionality and content, including advertising, based on the general preferences and needs of a group of users.
4.3. All processing and use of your personal data is justified by the existence of a basis for processing. In most cases, such a basis will be:
• processing is necessary to fulfill a contract with you (for example, if you subscribe to Our Services) or to take steps at your request before entering into a contract (for example, to place an order or provide a Service), or to provide product information that you have requested;
• processing is necessary for Us to comply with a relevant legal obligation, such as maintaining tax or accounting records;
• processing is carried out within Our legitimate interests, which are not overridden by Your interests and fundamental rights and freedoms. Our legitimate interests are to use the data of subscribers, Site users, suppliers and customers to conduct and develop Our business with them and others, limiting the use of their personal data to purposes that support the conduct and development of Our business;
• You have consented to the processing of personal data.
4.4. We process the personal data collected by Us for the following purposes, strictly complying with the principles of GDPR, ensuring transparency and giving You control over Your data:
• Providing you with the Services you have subscribed to or otherwise requested.
• Delivering the documents you request, responding to your inquiries, complaints, communications and providing other proactive communication.
• Managing and executing purchase, sale or service agreements with Our partners and customers, including providing after-sales support.
• Informing users of the Site or recipients of the Services about changes to the Agreement, policies, service plans, Services, informing about events, promotions, new features and functionality of the Site, new Peerobyte products and Services.
• Periodic email communications about Our products and Services to those who have consented to receive them. To unsubscribe from receiving marketing communications, click on the "Opt Out" or "Unsubscribe" link at the bottom of each email or contact Our support team via email: [email protected]. If you have an Account on the Site, you may also opt-out of mailings by changing your Account settings or by contacting Our support team through Our Site's ticketing system.
• Send periodic emails that include information about Our existing and new products and Services to subscribers of Our Services. To opt-out of receiving marketing emails, click on the "Opt-Out" or "Unsubscribe" link at the bottom of each email or contact Our support team via email: [email protected]. You may also opt-out of mailings by changing Your Account settings or by contacting Our support team via Our Site's ticketing system. If You opt-out of these marketing emails, You will continue to receive system notifications and other information related to Your Account.
• Providing transactions related to the Site, Peerobyte's products and Services.
• Analyzing and improving interactions with Our Site and Services, including personalizing your experience and targeting new markets for marketing and advertising initiatives.
• Protect and secure the Site, Peerobyte's confidential information and its employees from unauthorized access, use or disclosure.
• Taking action against fraud, threats, claims and other legal liabilities while complying with our contractual obligations and legal requirements.
4.5. In individual cases, the basis and/or purpose of the use of personal data may differ from the above, in which case you will be provided with a separate notice or contract containing the necessary additional information regarding the use of your personal data.

5. Data Disclosure

5.1. Your personal data may be transferred to third parties in the context of a reorganization, sale or merger of Peerobyte, its assets, or the assets of related companies. In such circumstances, the personal data of Our users may be one of the transferred assets.
5.2. If We believe it is necessary to disclose personal information about users of Our Services, Our Site, Our customers or suppliers, such disclosure will be for the following reasons:
• Responding to requests from organizations that have a legal right to request disclosure of personal data.
• Meeting the requirements of laws and regulations requiring disclosure of personal data.
• The need to identify, contact, pre-litigate, or bring legal action against a person who violates the Agreement, Peerobyte Acceptable Use Policy, or any other Peerobyte Agreement or Policy in effect for the customer.
• Protecting Our rights, the rights of Our customers, the rights of third parties or the public at large, in litigation and other proceedings in which disclosure of personal data is required.
• Contacting law enforcement authorities, alerting third parties or the public at large, in the event that We suspect or expressly identify illegal activities of Our Client.
• A request by a personal data subject to ensure access, disclosure or transfer to third parties of his/her own personal data.

6. Data transfer

6.1. In order to ensure the integrity and security of Your personal data, Your personal data may be distributed across data centers located in different territories and owned by Us, Our affiliated companies and external providers.
6.2. For transfers of personal data from the UK to the EEA, We will be guided by the UK's decision that the EEA countries provide adequate protection for personal data. And for transfers of personal data from the EEA to the UK, We will be guided by the EU's decision that the UK provides adequate protection for personal data.
6.3. If Your Personal Data is transferred from data centers within the United Kingdom or the European Economic Area (EEA) to data centers outside of the EEA to Our affiliates or external service providers, We will take all necessary steps to ensure that Your Personal Data is afforded an appropriate level of protection that meets the standards of the territories where the Personal Data was originally located.
6.4. In the case of transfers of data from the UK or EEA to countries that are not subject to an appropriate data protection adequacy decision, such as the United States of America, then We protect your personal data using Standard contractual clauses (SCCs) and other necessary data protection measures. We rely on SCCs for data transfers to the United States and other territories, including transfers within Our corporate group.
6.5. Peerobyte reserves the right to forward and share with third parties any information provided by You that is not personally identifiable information and is not otherwise subject to restrictions under the Agreement, this Policy and Your signed contract with Us.
6.6. To request details of the arrangements for transferring your personal data outside the EEA or the UK, you can email: [email protected] to Our Legal Support Team.

7. Your rights

7.1. Under the GDPR all personal data subjects have rights, in particular these:
• The right to access, rectify and delete Your personal data. You have the right to request access to and obtain a copy of any of Your personal data that We may hold about You, to request correction of any inaccuracies or errors in Your personal data, and to request deletion of Your personal data in certain circumstances. You can review and update most of this data yourself online at Your account profile page on the Site or by emailing [email protected] to Our support team.
• Right to restrict processing. You have the right to restrict Our processing of Your personal data, allowing only storage, if:
o You dispute the accuracy of personal data until We take sufficient steps to correct or verify its accuracy.
o Processing is unlawful, but You do not want Us to delete personal data.
o We no longer need your personal data for processing purposes, but you need such personal data to establish, exercise or defend legal claims.
o You have objected to processing justified on grounds of legitimate interest, pending verification of whether We have a compelling legitimate reason to proceed with the processing.
If you have restricted the processing of your personal data, we will only proceed to process it with your consent or for the establishment, exercise or defense of legal claims.
• Right to lodge a complaint.
You also have the right to lodge a complaint with the supervisory authority in your place of residence, place of work or place of alleged infringement, if you believe that the processing of your personal data violates applicable law.
• The right to data portability and readability.
You have the right to receive the personal data You have provided to Us in a structured, commonly used and machine-readable format and have the right to transfer this data to another controller without interference from Us, provided that the processing is based on Your consent or on the need to fulfill a contract and the processing is carried out using automated means. This right also includes the possibility to request the direct transfer of data from Us to another controller, if technically feasible.
• The right to withdraw consent.
Where applicable, you have the right to withdraw your consent at any time. For example, if you wish to opt-out of receiving email marketing communications, you may change your Account profile settings on the Site, use the "Opt Out" or "Unsubscribe" link at the bottom of each email, or contact Our support team via email: [email protected].
• The right to object to processing (including profiling) on the grounds of legitimate interests.
If We are guided by legitimate interests in processing personal data, You have the right to object to such processing. If You object, We must stop such processing unless We can demonstrate compelling legitimate grounds for the processing that override Your interests, rights and freedoms or We need to process the personal data to establish, exercise or defend legal claims. If We rely on Our legitimate interest as the basis for processing Your personal data, We believe We can demonstrate such compelling legitimate grounds, but We will consider each case on a case-by-case basis.
• The right to object to direct marketing (including profiling).
You have the right to object to Us using Your personal data (including profiling) for direct marketing purposes, such as when We use Your personal data to invite You to Our promotional events.
7.2. If you wish to exercise any of your rights or if you have any questions or complaints regarding your personal data, you can send an e-mail to [email protected] to Our support service or, if you have an Account on the Website, via the ticket system of Our Website.

8. Child data collection

8.1. Our Site and Our Services are not intended for use by children under the age of 16.
8.2. If you are under 16 years of age, please leave Our Site and do not use Our Services.
8.3. Peerobyte does not knowingly collect, store, transfer or use personal data from children under the age of 16.
8.4. If you are under the age of 16, please do not provide any personal information, even if Our Site asks you to do so, and simply leave the Site.
8.5. If you are under the age of 16 and have submitted personal information to Our Site or otherwise provided your personal information to Us, please ask your parent or guardian to notify Peerobyte by writing to [email protected] and Peerobyte will endeavor to delete all of your personal information as soon as possible.