PRIVACY POLICY
EFFECTIVE DATE - February 13, 2025
We, Wups, Ltd., registration number 40203098394 , whose legal address is Brīvības gatve 234-77, Riga, LV-1039.
“ITMARKETING service” is an interactive online service provided by Wups, Sia and available at https://itmarketing.lv
All references herein to “we”, “us” or “our” shall be construed as references to Wups, Sia and the ITMARKETING service.
The concepts of “controller” and “processor”
Controller – ITMARKETING Service, which processes your personal data as a customer of the Service, which you provide to us when contacting us using the "Contact us" / "Support service" form, during registration or using other methods of data transfer.
Processor - ITMARKETING Service, which receives personal data from the Service's clients - legal entities - employees or representatives of the clients of the said Service.
When we act as controller and processor
ITMARKETING will act as the “controller” of the personal data you provide to us when you contact us via the “Contact Us” / “Support Service” form, during registration or through other data transfer methods. You do not need to provide any personal information to view the public pages of our website.
If you are an employee or authorized representative of one of our clients who has entered into a User Agreement with us for the provision of goods or services, we will act as a “processor” of your personal data transferred by our client. Our client will act as the controller of your information. As a processor, we do not own, control, or use any data provided to us by our clients who act as controllers.
Personally identifiable information
“Personally identifiable information” (or “PII”) refers to contact information that directly or indirectly identifies you, such as your name, phone number, country and city, company name, email address, IP address, or any other information that can be easily linked to you. We do not collect sensitive information, such as GPS information, racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic or biometric data, health data, or data about an individual’s sex life.
Passive or automatically collected data
Passively or automatically collected data (hereinafter referred to as “Usage Data”) is collected when you use this website. We, our affiliates and our marketing partners may use automated means to collect various types of information about you, your computer or other device used to access this website, its services, related web applications and downloadable software. This information is based on your use of the website and may be obtained when you visit other websites. Usage Data is essentially anonymous, but it can be used indirectly to identify an individual.
Why do we need your data?
We need to know your PII that you provide to us when we act as a controller so that we can respond to your request submitted through the contact page and other communication methods. We also need to know your PII to send you emails and for other purposes. Including in connection with the exchange of PII as described below in the “Sharing and Disclosure of Information” section. We also need to know the PII of users who are authorized representatives of our clients when we act as a processor to regulate the authorized user’s use of our services.
We need to know your DPI so that we can fully identify and verify our authorized users to exclude fraudulent activities, fraud, and increase user trust in the Service.
How we collect and use your data
The ITMARKETING service collects PII directly from you when you send us a message, provide your email address in the “Contact Us” / “Customer Service” form on our web pages or other forms of feedback, as well as when you register on the site.
By registering for ITMARKETING, you consent to the collection of your PII and to the sending of email messages to you, including the use of PII for promotional emails aimed at promoting our products or products similar to our products or services. You may withdraw your consent at any time by unsubscribing from our emails using the unsubscribe link included in each email.
The ITMARKETING service uses third-party applications to add information to the data we collect from you. This data enhancement allows us to provide more useful, personalized communications.
We collect usage data as described above and cookie data. For more information and how to set your browser to refuse cookies, see the Cookies and Opt-Out Procedures section below.
When withdrawing funds from the Service, we may request information from you to comply with payment system requirements. This information may include, but is not limited to:
- Full name
- Identity document - Residential address
The user assumes full responsibility for providing correct data.
Itmarketing will store this information in encrypted form and, upon request, will send it to the payment system or government authorities if required by law (e.g. AML).
We do not request any additional information from residents of the Russian Federation.
We may use Usage Data for any purpose, including without limitation, to tailor remarketing (excluding the European Union), offers and content displayed to you based on your visits to and/or use of this Site or Services, and to analyze the effectiveness of and your interaction with advertisements, offers and content.
Subject to your right to opt out, we may combine usage data with the PII we collect and use the combined data to create profiles about you for the sole purpose of improving our products and services and enhancing your user experience on our Service.
To collect DPI information, the ITMARKETING service engages its authorized partner - the verification service.
The verification service directly collects, processes and stores the DPI received during the verification process, in compliance with all applicable Russian and European Union legislation. The ITMARKETING service does not participate in the process of collecting and processing DPI, does not store and does not use this information, receiving all the necessary verification data from the verification service.
How long do we keep your data?
We will not retain your PII for longer than necessary. This means that we will retain your PII for any of the following periods of time (or a combination thereof):
Once we delete your PII from our databases, it will remain in our backup system until it is purged.
Information exchange and disclosure
General Disclosure Policy. We may share and disclose your PII as described below. We may disclose and share Usage Data without restriction, including in the situations described below . Please contact us at info@itmarketing.lv to opt out of having your information shared with third parties.
Affiliates. We may share your PII and usage data with any of our affiliates, including our subsidiaries. Affiliates are companies that we legally control or that control us.
Subprocessors. We may share your PII and usage data with our trusted subprocessors who help us build and maintain this website. For example, we may contract with third parties to process payments, host servers, provide security, and provide software development, support, optimization, analytics, reporting, maintenance, and development services. In addition, our Subprocessors will only be granted access to your information if it is truly necessary to provide the services specified in the contracts.
Successors: If we sell or otherwise transfer some or all of our business or assets to another organization (such as in an acquisition, merger, bankruptcy, or liquidation), we may transfer your PII and Usage Data. In such a case, we will ensure that the buyer or recipient agrees to the obligations set forth in this Policy.
Mandatory Obligations. Except for sharing your information as described in this section “Sharing and Disclosure of Information,” ITMARKETING will not disclose information about you or the content of your communications unless it is compelled to do so by circumstances, in any of the following cases where it is really necessary:
Marketing partners for remarketing purposes. We may share your information with third-party services for remarketing purposes. For a description of remarketing and your opt-out rights, see the Remarketing section below.
Cookie data and opt-out procedures
The ITMARKETING service may automatically collect Usage Data using cookies. Cookies are small text files that a website uses to recognize repeat visits by users, ensure continuous user access to the website, and facilitate the use of the website. Cookies also allow the website to track user behavior and gather information about website usage that can be used to improve the content.
You can refuse to accept cookies by activating the settings on your browser that allow you to refuse the storage of cookies. However, if you select this setting, you may not be able to access certain parts of our website. Unless you have set your browser to refuse cookies, our system will issue cookies when you log in to our website.
Remarketing
The ITMARKETING service uses third-party tracking cookies and pixels, including Google Ads, Yandex tracking code, and Google Tag Manager tracking code.
This means that we will continue to show you advertisements across the Internet, particularly on the Google and Yandex information networks. Third-party vendors, including Google, will place cookies on web browsers to serve advertisements based on your previous visits to our site. This allows us to make special offers and continue to sell services to those who have shown interest. We do not re-market to users in the European Union.
You can opt out of Google's use of cookies by visiting the Ads Preferences Manager . Additionally, you can opt out of third-party cookies by visiting the Network Advertising Opt-Out Page .
Analytics
We may connect third-party analytics services to monitor and analyze web traffic and track user behavior on this website.
Google Analytics (Google). Google Analytics is a web analytics service provided by Google Inc. (Google). Google uses the data collected to track and examine how users use this website, to compile reports on website activity and to share this data with other Google services.
Information collected: Cookies and usage data. Please visit our privacy policy at https://policies.google.com/?hl=en . You can opt out of Google Analytics using the Google opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout .
Your rights
You can contact us to find out whether we are processing your PII. If so, you can ask us what personally identifiable information we hold and what we do with your data. If requested, we may provide you (or, where technically feasible, a third party you designate) with a copy of any PII we hold for a fee in accordance with law (not to exceed the cost of reproducing such documents).
We may deny a request to access or correct PII under the circumstances permitted by law. And if we do, we will provide you with written notice of the reasons for the denial.
In addition, you can:
If you request us to exercise any of the rights set out above, we will, where applicable, notify other authorized parties that store and process your PII of your request.
Privacy Notice for Users in the European Union
Wups, Sia is committed to resolving complaints about how we store or use your personal information. EU residents with questions or complaints about this policy should first contact RemoteFirst Group Limited at info@itmarketing.lv .
You can complain about unresolved disputes regarding the protection of personal data to the EU data protection authorities. The contact details of the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .
Wups, Sia will cooperate with the relevant EU data protection authorities in investigating and resolving complaints.
As a last resort, complaints about privacy violations that remain unresolved after using these and other channels must undergo mandatory internal arbitration before the European Commission establishes a dedicated Data Protection Board.
Links to other sites
This site may contain links to other sites. If you click on any links to sites or accept any promotional offers, your click information and any information you provide during the registration or purchase process will be transmitted to those sites. We assume no responsibility for the policies and practices of those sites. You should exercise caution and review any privacy policies posted on any of those sites before providing any information.
Online policy for children
We are committed to ensuring the security of personal information online for all visitors to our site, including children. This site is a public site. In accordance with the Children's Online Privacy Protection Act (COPPA), we will not knowingly collect or sell any information from children under the age of 16. If you are a parent or guardian who discovers that your child under the age of 16 has submitted personal information without your permission or consent, we will remove the information from our list at your request. To request removal of your child's information, please contact our site using the "Help Desk" link below, and be sure to include the same login information that your child submitted in your message.
Do not track requests
Some web browsers include a "Do Not Track" feature that tells websites you visit that you do not want to be tracked about your online activities. Each browser transmits Do Not Track signals to a website differently, preventing the website from processing each request correctly. To avoid errors between browsers and the website, we do not currently respond to Do Not Track signals. As technology and the interaction between your browser and the website improve, we will review your ability to respond to Do Not Track signals and make changes to our policy.
Requests and complaints
If you have any questions or complaints about our use of your PII, please let us know. You can contact us at any time using the “Support” section below and we will do our best to resolve the issue and get back to you.
Contact us
Wups, Sia
Brīvības gatve 234-77, Riga, LV-1039
info@itmarketing.lv
Content changes on February 7, 2025: EU Data Protection Regulation (GDPR).