Privacy Policy

Seventy Souls Tech Group Ltd ("we," "us," or "our") is providing this Privacy Policy to inform users of our policies and procedures regarding the collection, use, and disclosure of personal information received from users of (i) this website, (ii) any other website owned and operated by Seventy Souls Tech Group Ltd or its affiliates, and (iii) any of our mobile applications (the "Apps"). The websites and Apps are collectively referred to as the "Services."

Legal Basis for Processing (GDPR)

As a Cyprus-registered 🇪🇺 entity, we process personal data in accordance with the 🇪🇺 General Data Protection Regulation (GDPR). The legal bases we rely on are:

• Consent (Art. 6(1)(a) GDPR): Where you have given us clear consent to process your personal data for a specific purpose.
• Contract (Art. 6(1)(b) GDPR): Where processing is necessary to perform a contract with you, or to take steps at your request before entering a contract.
• Legal Obligation (Art. 6(1)(c) GDPR): Where processing is necessary to comply with a legal obligation under 🇪🇺 or Cypriot law.
• Legitimate Interests (Art. 6(1)(f) GDPR): Where processing is necessary for our legitimate interests, provided these are not overridden by your interests or fundamental rights.

1. Information Collection and Use

We collect personally identifiable information to provide our Services to you, to communicate with you, and to administer your registered user account, should you have one.

Information We Collect

Through the Services, we may collect the following categories of personal information about you, including, but not limited to:

• Registration Information: In order to use certain features of the Services, you must register and create an account. When creating an account, you will be asked for basic registration information such as your email address, username, and password.
• Identification Information: We may also ask you to provide identification information to confirm your identity, including your first and last name, username, address, and telephone number.
• Commercial Information: We may keep a history of the content you browse, the services you use, and purchases made through the Services.
• Technical and Navigational Information: We collect information about your interaction with our Services, including the browser you use, pages visited, average time spent, IP address, unique device identifier for mobile devices, operating system version, and app version.
• Location Information: If you elect to use location-based features, we may collect location information from your device. You can control or disable this through your device settings.
• Other Information: Feedback, questions, comments, suggestions, or other ideas you voluntarily provide.

Use of Your Information

We use your information to:

• Provide, maintain, and improve the Services;
• Communicate with you about updates, changes to our terms and policies;
• Understand how you engage with our Services;
• Develop new features and products;
• Protect against fraud, criminal activity, or abuse of our Services;
• Meet legal requirements and comply with legal proceedings;
• Market to you, where you have given appropriate consent (you may opt out at any time).

2. Cookies and Trackers

Like many websites, we use cookie technology to gather additional information regarding the usage of the site to optimise the Services. A cookie is a small data file which we transfer to the hard drive of your computer. We do not use cookies to collect personally identifiable information in isolation.

Strictly Necessary Cookies

We use cookies which are strictly necessary to enable you to use the website and access certain features, such as being able to log in. These cookies are crucial for the use and navigation of the website.

Optional Cookies

We use analytics cookies that enable us to track and count the amount of visitors who have visited the website, and to understand how visitors navigate around the site. This helps us enhance the functionality of our Services. These cookies only give us anonymous traffic metrics.

Your Choices

You can control cookies through your browser settings. Please be aware that restricting cookies may limit certain functionality of the website. As an 🇪🇺 entity, we provide clear cookie consent mechanisms where required.

3. Information Sharing and Disclosure

Service Providers

We employ certain trusted third parties to conduct features and deliver services on our behalf, including web hosting, analytics, and maintenance. We disclose your personal information to those third parties only to the extent required, and only under binding contractual commitments (Data Processing Agreements) that commit those third parties to maintaining the privacy and security of your information in accordance with GDPR.

Compliance with Laws and Law Enforcement

Seventy Souls Tech Group Ltd co-operates with government and law enforcement agencies or private parties to enforce and obey the law. We may provide information concerning you to government or law enforcement agencies as we consider necessary or proper to comply with legal processes, to protect the property and rights of Seventy Souls Tech Group Ltd or a third party, or to prevent or stop illegal activities.

Business Transfers

Seventy Souls Tech Group Ltd may sell, transfer, or otherwise share some or all of its assets, including your personal information, in the context of a merger, acquisition, reorganisation, or sale of assets. In such cases, we will notify you and ensure appropriate data protection measures are in place.

Personal Information

Unless otherwise specified in this Privacy Policy, we do not sell, disclose, or provide your personal information to any third party for their marketing purposes without your permission.

4. Advertising

We may display advertisements in the Services. Such ads may be provided by third-party advertising partners who may use cookies or similar tracking technologies. To the extent required under GDPR, we will obtain your consent before serving interest-based advertising.

To opt out of interest-based advertising, please visit aboutads.info/choices or optout.networkadvertising.org.

5. Security

Seventy Souls Tech Group Ltd takes commercially reasonable and technically appropriate measures to maintain the confidentiality and security of your personal information. We utilise administrative, physical, and electronic procedures to protect your data from unauthorised access. As an 🇪🇺 entity, we comply with the security requirements of GDPR (Art. 32).

6. Data Retention

We will keep your personal information for as long as necessary for the purposes outlined in this Privacy Policy, for so long as we have a valid business reason for doing so, or as long as required by law — whichever is longer. We apply GDPR data minimisation and storage limitation principles.

7. Your Rights Under GDPR

As a data subject in the 🇪🇺 (or anywhere in the world that we serve), you have the following rights:

• Right of Access (Art. 15): You have the right to request a copy of the personal data we hold about you.
• Right to Rectification (Art. 16): You have the right to request correction of inaccurate personal data.
• Right to Erasure (Art. 17): You have the right to request deletion of your personal data ("right to be forgotten") under certain conditions.
• Right to Restrict Processing (Art. 18): You have the right to request that we restrict the processing of your personal data.
• Right to Data Portability (Art. 20): You have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object (Art. 21): You have the right to object to our processing of your personal data.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus, or with any 🇪🇺 supervisory authority.

To exercise any of these rights, please contact us through our support page.

8. Our Policy Towards Children

The Services are not intended for children under 13 years of age, and we do not knowingly gather personally identifiable information from children under the age of 13. If a parent or legal guardian discovers that their child has provided us with personal information without their permission, they should contact us through our support page. If we become aware that a child under 13 has shared personally identifiable information with us, we will delete such information from our records promptly.

9. International Data Transfers

Seventy Souls Tech Group Ltd is registered in Cyprus, an 🇪🇺 member state. Your personal data is processed within the 🇪🇺. Where we use third-party service providers that process data outside the 🇪🇺/EEA, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses) in accordance with GDPR Chapter V.

10. Links to Other Websites

Our Services may include links to third-party websites that are not operated or controlled by Seventy Souls Tech Group Ltd. We exercise no control over any third-party websites and encourage you to review their privacy policies.

11. California Privacy Rights (CCPA)

If you are a California resident, you may have additional rights regarding your personal information. To submit a request regarding your California privacy rights, please contact us through our support page.

12. Updates to This Policy

We may update this privacy policy periodically. We will notify you of any material changes by posting the new privacy policy on our website and, where appropriate, by in-app notification. Please check this privacy policy periodically for any changes.

13. Contact Us

If you want to access your personal data, have any questions about the processing of personal data, or wish to exercise your data subject rights, please contact us through our Contact & Support page.

For formal legal or data protection matters: