General Privacy Policy of Reconcilio

Last updated: September 01, 2024

Reconcilio, (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to RECONCILIO LTD, Cyprus, Company Number: HE447807, is committed to protecting your personal information that we may receive while you are using our website and services.

This Privacy Policy sets out the principles regarding the collection, use and disclosure of Your information when You use our provided Services, and aims to inform You about Your privacy rights.

We use Your Personal data to provide and improve Our Services. By using Our Service, You agree to the collection and use of information in accordance with this Privacy Policy.

This Privacy Policy is governed by the Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”).

For the purposes of this Privacy Policy, Reconcilio is acting as Data Controller as it is the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
What is personal data and processing?

Personal data is any information that relates to an identified or identifiable individual (Article 3(1) of the General Data Protection Regulation “GDPR”).

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

When we say “data subject” or “User” we are referring to you as the individual accessing or using the Service, or the company, or other legal entity on behalf of which such an individual is accessing or using the “Website” Reconcilio.com, accessible from https://Reconcilio.com (the “Service”).

What information we collect about you?

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Address, State, Province, ZIP/Postal code, City

• Bank account information in order to pay for products and/or services within the Service

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). Usage Data may include information such as Your Device's, namely any device that can access the Service such as a computer, a cellphone or a digital tablet, Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:

  • Date of birth

  • Passport or National ID card

  • Bank card statement

  • Other information linking You to an address

When You access the Service by or through a mobile device, We may collect certain information automatically such as:

• the type of mobile device You use,

• Your mobile device unique ID,

• the IP address of Your mobile device,

• Your mobile operating system,

• the type of mobile Internet browser You use,

• unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Website or when You access the Service by or through a mobile device.

We also collect the following information automatically when you use our Services:

Tracking technologies and Cookies: We use Cookies, namely small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses, and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include: Cookies or Browser Cookies, Flash cookies, Web Beacons, Necessary / Essential Cookies, Cookies Policy / Notice Acceptance Cookies, Functionality Cookies, Tracking and Performance Cookies. For more information about the Cookies we use and your choices regarding cookies, please visit our Cookies Policy.

How we use the information we collect:

We may use your Personal Data to provide, monitor the usage and maintain our Service, to contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, and manage Your registration as a user of the Service, namely Your unique account created for You to access our Service or parts of our Service. Moreover, for the performance of a contract for the products, items or services You have purchased or of any other contract with Us, to manage your requests and to provide you with news, special offers and general information about other goods, services and events which we offer are other examples of using the information we collect about you. Additionally, we use your information for business transfers in order to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred. Lastly, We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

Legal bases for processing Your personal data:

If you are an individual residing in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. In this context, we may process Personal Data under the following conditions:

  Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.

  Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre- contractual obligations thereof.

  Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

  Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

How we share information we collect:

We may share Your personal information with Service Providers considered under GDPR as Data Processors, in order to monitor and analyze the use of our Service, for payment processing and to contact You. Service Provider can be any natural or legal person who processes the data on behalf of the Company and mostly third-party companies, or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. Furthermore, we may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company. We may, also, share Your information with Our business partners and/or Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. What is more, we might share your information with other users in cases where your information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, namely any website or any social network website through which a User can log in or create an account to use the Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

Lastly, upon your consent, we may disclose Your personal information for any other purpose.

How long we retain Your Personal Data:

We retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy and we use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

How we transfer information we collect internationally:

We might transfer, process, and maintain Your information, on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Whenever we transfer your information, we take steps to protect it and ensure that is treated securely and in accordance with this Privacy Policy. No transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information..

When we disclose Your Personal Data:

We may disclose and transfer Your Personal Data in case of a business transaction such as a merger, acquisition or asset sale. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy. Moreover, under certain circumstances imposed by law enforcement, we may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Lastly we may disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing in connection with the Service, to protect the personal safety of Users of the Service or the public and protect against legal liability.

How we store and secure information we collect:

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Other important privacy information on the Processing of Your Personal Data:

Our Service Providers may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies. Please refer to their Privacy Policies as they might be based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service. Such as Google Analytics, Firebase, Sendinblue, Stripe and Revolut. More specifically:

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

Firebase

Firebase is an analytics service provided by Google Inc. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy.

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners' sites or apps webpage: https://policies.google.com/technologies/partner-sites

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Sendinblue

Their Privacy Policy can be viewed at https://www.sendinblue.com/legal/privacypolicy/.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy.

Revolut

Their Privacy Policy can be viewed at https://www.revolut.com/legal/privacy.

When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

Links to Other Websites:

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Our "Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA):

Our Service does not respond to Do Not Track signals. Do not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Our policy towards Children:

The Services are not directed to children under 13 years of age (and in applicable jurisdictions in the EU, individuals under 16 years of age). We do not knowingly collect personally identifiable information from anyone under the age of 13 (and in applicable jurisdictions in the EU, individuals under 16 years of age). If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

What are Your Rights as data subject?

We respect the confidentiality of Your Personal Data and guarantee You can exercise Your rights.

Under this Privacy Policy and in accordance with GDPR you have the following rights as data subjects:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

• Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.

• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

How to exercise Your rights under GDPR:

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Effective Date and Policy Changes:

We may update Our Privacy Policy from time to time. We post any privacy policy We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

How You can contact Us:

If you have any comments or questions about this Privacy Policy or the way we handle or process your Personal Data or if you wish to exercise any of your rights, please send an email at:

  admin@Reconcilio.com

Cookies policy

Last updated: September 01, 2024

Reconcilio, (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to RECONCILIO LTD, Cyprus, Company Number: HE447807, is committed to protecting your personal information that we may receive while you are using our website and services.

With this Cookies Policy ("Cookies Policy") we provide you with more information about the type and manner of using cookies on Our “Website”, namely https://Reconcilio.com/ . We point out that the Cookies Policy works in addition to the Privacy Policy of Our Website, which You can find at the following link https://Reconcilio.com/privacy .

This Cookies Policy may be modified at any time. Any modification will be effective from the moment it is announced on the Website. In case of modification, the date on which it took place will be indicated. The Cookies Policy, as configured by the most recent modification, is always considered valid. It is recommended that you check this page periodically to ensure that you are aware of any changes.

What are cookies? Do We use cookies?

A cookie is a small text file that a website stores on Your computer or mobile device when You visit the Website. We use cookies, as described below, for an orderly and secure operation of our Website. The Website retrieves this information on each visit in order to offer related services.

First party cookies are cookies set by the Website You are visiting. Only that Website can read them. In addition, a Website might potentially use external services, which also set their own cookies, known as third-party cookies. Depending on their duration, cookies are either "session cookies" or "persistent cookies". Persistent cookies are cookies saved on Your computer and are not deleted automatically when You quit Your browser, unlike a session cookie, which is deleted when You quit Your browser. In this context, persistent cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can find further information on persistent and session cookies below.

Every time You visit the Our Website, You will be prompted to accept or refuse cookies. The purpose is to enable the site to remember Your preferences (such as user name, language, etc.) for a certain period of time. That way, You do not have to re-enter them when browsing around the site during the same visit. Cookies can also be used to establish anonymised statistics about the browsing experience on Our Website.

How do We use cookies? What types of Cookies do we use and for what purposes?

More specifically, the technologies We use may include:

• Cookies or Browser Cookie: A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

• Flash Cookies: Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable- local-shared-objects- flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_lo cal_shared_objects_.

• Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

With regards to Persistent / Session cookies, We use both for the purposes set out below:

• Necessary / Essential Cookies (Session Cookies) - Administered by: Us

These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies (Persistent Cookies) - Administered by: Us

These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies (Persistent Cookies) - Administered by: Us

These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

• Tracking and Performance Cookies (Persistent Cookies) - Administered by: Third- Parties

These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify You as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how Our users react to them

More specifically:

Cookie Type

Description

Purpose/Service

Necessary / Essential Cookies

These cookies are necessary for the operation of the website and cannot be disabled in our systems. They are usually set only in response to actions taken by you, related to a request for services, such as setting your privacy preferences, logging in or filling out forms. You can set your browser to block or notify you about these cookies, but some parts of the site may not work in this case.

Security and operation of the Website

Tracking and Performance Cookies

These cookies allow us to measure visits and traffic sources in order to calculate and improve the performance of our site. They help us know which pages are most and least popular and see how visitors move around the site. All information collected by these cookies is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site.

Performance and traffic of the site improvement

Functionality Cookies

These cookies enable the provision of enhanced features and personalization, such as videos. They may be set by us or by third party service providers whose services we have added to our pages. If you do not allow these cookies, some or all of these features may not work properly.

Providing improved functionality and personalization

Targeting Cookies

These cookies are set through our site by our advertising partners. They may be used by these companies to create a profile of your interests and to display relevant advertisements on other sites. They work by uniquely identifying your browser and device. If you do not allow these cookies, you will not enjoy our targeted ads on different websites.

Create profiles based on preferences and display relevant advertisements

What kind of data do we collect from you through the use of Cookies?

Through cookies we collect and process the following types of data:

• Terminal equipment identification data (phone, tablet, laptop).

• Identification data of the Reconcilio member/ User (if he has created an account)

• Internet protocol address of the User.

• User's browser data.

How can you manage cookies?

When you enter the main page of the Website, you will find a short informative note (cookie banner) with a pop-up window about the use of cookies by us, which is located in a central position in Our Website. In this information note you will find important information on the description and operation of the different categories of cookies. You will also have the option to accept the use of all non-technically necessary Cookies (statistical analysis cookies, advertising and social networking cookies) or reject non-technically necessary Cookies (statistical analysis cookies, advertising and social networking cookies). Technically necessary cookies do not require user consent and are always enabled. In addition, a "SETTINGS" option is given, where you can find more detailed information about the cookies we use and set/change your preferences regarding the use of cookies.

Specifically:

• You can select "ACCEPT", acknowledge the use of technically necessary cookies and provide your consent to the use of all the above non-necessary cookies.

• Otherwise, by selecting "REJECT", you acknowledge the use of technically necessary cookies and reject any other category of cookies.

• By selecting "SETTINGS" you can be informed in detail about cookies and choose (or change) your preferences regarding the use of cookies (with the exception of technically necessary cookies, which are always enabled).

We use technically necessary cookies and, subject to your prior free and express consent, statistical analysis cookies, advertising and social networking cookies). retroactive result, through the "SETTINGS" option.

Moreover, you can always delete all cookies from your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited. Be aware though that you may also lose some saved information (e.g. saved login details, site preferences). You have also the option to block cookies but you may then have to manually adjust some preferences every time you visit a site/page while some services and functionalities may not work properly at all (e.g. profile logging-in). You are always free to disable our cookies by adjusting your browser settings. Please note that by deleting or disabling our cookies, your user experience may be affected and you might not be able to take advantage of certain functions and the complete user experience of our Website.

Regarding the managing of site-specific cookies, for a more detailed control, please check the privacy and cookie settings in your preferred browser.

We remind you, moreover, that as data subjects you have the rights of access, correction, deletion, restriction of processing, portability, opposition, objection to automated decision- making and recourse to the competent Supervisory Authority.

How can you change your preferences regarding cookies?

You are always free to change your cookie preferences by clicking on manage cookie settings.

How can you contact us?

If you have any questions about this Cookies Policy or if you wish to exercise any of the rights, you have as a data subject please contact the Data Protection Officer at the following email address: admin@reconcilio.com