Privacy Policy of BRO OÜ (BRO LLC)

This Website collects some Personal Data from its Users.

Personal Data collected for the following purposes and using the following services:

    • Access to third-party accounts

      • Facebook account access

        Permissions: About Me; Birthday; Contact email; Email; Hometown; Photos

      • Twitter account access

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Advertising

      • AdMob and Facebook Audience Network

        Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

      • Google AdSense, Taboola Monetize Content, Apple iAd, Microsoft Advertising, Google Ad Manager, IntelliTXT and OpenX Ad Exchange

        Personal Data: Cookies; Usage Data

      • Direct Email Marketing (DEM)

        Personal Data: email address

    • Analytics

      • Facebook Ads conversion tracking (Facebook pixel), Google Ads conversion tracking, Google Analytics, LinkedIn conversion tracking, Matomo, Twitter Ads conversion tracking, Wordpress Stats and Yandex Metrica

        Personal Data: Cookies; Usage Data

      • Facebook Analytics for Apps

        Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

      • Google Analytics for Firebase

        Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

      • TestFlight

        Personal Data: Cookies; email address; Usage Data

    • Commercial affiliation

      • AliExpress Affiliate, Amazon Affiliation, Amazon Omakase, Banggood Affiliates Program, Booking.com Affiliate Partner Programme, CJ Affiliate by Conversant, ClickBank, eBay Partner Network, ShareAsale, Skimlinks and VigLink

        Personal Data: Cookies; Usage Data

    • Contacting the User

      • Contact form

        Personal Data: country; email address; first name; last name; phone number; various types of Data

      • Mailing list or newsletter

        Personal Data: Cookies; country; date of birth; email address; first name; last name

    • Content commenting

      • Comment system managed directly

        Personal Data: Cookies; email address; first name; last name; phone number; Usage Data; username; website

      • Disqus

        Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service

      • Facebook Comments

        Personal Data: Cookies; Usage Data

    • Data transfer outside the EU

      • Data transfer abroad based on standard contractual clauses, Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield, Data transfer to countries that guarantee European standards, Other legal basis for Data transfer abroad and Data transfer abroad based on consent

        Personal Data: various types of Data

    • Device permissions for Personal Data access

      • Device permissions for Personal Data access

        Personal Data: Approximate location permission (continuous); Approximate location permission (non-continuous); Camera permission; Contacts permission; Microphone permission; Motion sensors permission; Phone permission; Precise location permission (continuous); Precise location permission (non-continuous); Sensors permission; Social media accounts permission; Storage permission

    • Displaying content from external platforms

      • GitHub button and social widgets

        Personal Data: Usage Data

      • Google Calendar widget, Google Maps widget, Google Site Search, Getty Images widget, Instagram widget, Vimeo video and YouTube video widget

        Personal Data: Cookies; Usage Data

      • Google Fonts

        Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

      • Gravatar

        Personal Data: email address; Usage Data

    • Handling payments

      • Amazon Payments, Android Pay, Apple Pay, Authorize.Net, Google Pay, Neteller, PayPal, PayPal Payments Hub, Skrill and Yandex.Money

        Personal Data: various types of Data as specified in the privacy policy of the service

      • PayPal Carrier Payments

        Personal Data: phone number; various types of Data as specified in the privacy policy of the service

    • Hosting and backend infrastructure

      • Google Cloud Storage

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Infrastructure monitoring

      • New Relic

        Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service

      • Firebase Crash Reporting, Firebase Performance Monitoring and Uptime Robot

        Personal Data: various types of Data as specified in the privacy policy of the service

      • Web Performance

        Personal Data: Cookies; Usage Data

    • Interaction with data collection platforms and other third parties

      • Mailchimp widget

        Personal Data: email address; first name; last name; phone number; Usage Data

    • Interaction with external social networks and platforms

      • AddThis, Facebook Like button and social widgets, Google Friend Connect, Google+ +1 button and social widgets, LinkedIn button and social widgets, PayPal button and widgets, Pinterest “Pin it” button and social widgets, Reddit button and widgets, Shareaholic, ShareThis, Socialize, StumbleUpon button and social widgets, Tumblr sharing button and social widgets, Twitter Tweet button and social widgets and VK Like button and social widgets

        Personal Data: Cookies; Usage Data

      • Buffer button and social widgets and YouTube button and social widgets

        Personal Data: Usage Data

    • Interaction with live chat platforms

      • Facebook Messenger Customer Chat

        Personal Data: About Me; Cookies; Data communicated while using the service; Usage Data

    • Interaction with online survey platforms

      • GetSiteControl Survey Widget and SurveyMonkey Widget

        Personal Data: Cookies; Usage Data

    • Interaction with support and feedback platforms

      • Uservoice Widget

        Personal Data: Cookies; email address; Usage Data

      • Apptentive Widget

        Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

    • Location-based interactions

      • Non-continuous geolocation and Geolocation

        Personal Data: geographic position

    • Managing contacts and sending messages

      • Firebase Notifications and Firebase Cloud Messaging

        Personal Data: various types of Data as specified in the privacy policy of the service

      • GetResponse

        Personal Data: email address

      • Mailchimp

        Personal Data: address; company name; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username

      • OneSignal

        Personal Data: Cookies; email address; geographic position; language; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in the privacy policy of the service

    • Managing landing and invitation pages

      • Mailchimp Landing Page

        Personal Data: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; username

    • Platform services and hosting

      • WordPress.com

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Registration and authentication

      • Direct registration

        Personal Data: address; billing address; city; company name; country; data relating to the point of sale; date of birth; email address; first name; gender; house number; language; last name; password; phone number; picture; prefix ; province; shipping address; Tax ID; Twitter handle; User ID; username; various types of Data; VAT Number; website; workplace; ZIP/Postal code

      • Facebook Authentication, Google OAuth, GitHub OAuth, Instagram Authentication, Linkedin OAuth, Log In with PayPal, Login with Amazon, Mailchimp OAuth, OneDrive OAuth, Pinterest OAuth, Twitter OAuth, VK Client Authorization, Windows Live Connect, WordPress.com Single Sign On and YouTube OAuth

        Personal Data: various types of Data as specified in the privacy policy of the service

      • Firebase Authentication

        Personal Data: email address; first name; last name; password; phone number; profile picture; social media accounts ; username

    • Remarketing and behavioral targeting

      • Google Ads Remarketing, Google Ad Manager Audience Extension, Facebook Remarketing, LinkedIn Website Retargeting, Remarketing with Google Analytics and Twitter Remarketing

        Personal Data: Cookies; Usage Data

      • Facebook Custom Audience and Twitter Tailored Audiences

        Personal Data: Cookies; email address

    • Social features

      • Firebase Dynamic Links and Firebase Invites

        Personal Data: various types of Data as specified in the privacy policy of the service

      • Inviting and suggesting friends

        Personal Data: various types of Data

      • Public profile

        Personal Data: country; date of birth; first name; last name; picture; username

    • SPAM protection

      • Google reCAPTCHA

        Personal Data: Cookies; Usage Data

      • Akismet

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Tag Management

      • Google Tag Manager

        Personal Data: Usage Data

    • Traffic optimization and distribution

      • Cloudflare

        Personal Data: Cookies; various types of Data as specified in the privacy policy of the service

Further information about Personal Data

    • SmartAd

      SmartAd is advertising network, that belongs to BITE Corporation and All Media Baltics and the following companies under those groups: All Media Eesti AS, TV Play Baltics AS, All Media Digital OÜ, Mediainvest Holding AS, Buduaar Meedia OÜ.

      This service uses the “bepolite_id” Cookie, which tracks use of BRO OÜ (BRO LLC) and User behavior concerning ads, products and services offered.

      Personal Data collected: Cookies and Usage Data.

      Place of processing: Europe – Privacy Policy Peterburi tee 81, 11415 Tallinn, Estonia, referred to “Data protection officer”, email: smartad@smartad.ee.

    • Analysis and predictions based on the User’s Data (“profiling”)

      The Owner may use the Personal and Usage Data collected through this Website to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
      User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
      The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

    • Automated decision-making

      Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Website may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Website adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
      Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
      The rationale behind the automated decision making is:

      • to enable or otherwise improve the decision-making process;
      • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
      • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
      • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Website, Users can check the relevant sections in this document.

      Consequences of automated decision-making processes for Users and rights of Users subjected to it

      As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
      In particular, Users have the right to:

      • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
      • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
      • request and obtain from the Owner human intervention on such processing.

      To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

    • Personal Data collected through sources other than the User

      The Owner of this Website may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
      Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

    • Push notifications

      This Website may send push notifications to the User.

    • Selling goods and services online

      The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
      The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Website depends on the payment system used.

    • The Service is not directed to children under the age of 13

      Users declare themselves to be adult according to their applicable legislation. Minors may use this Website only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Website.

    • Unique device identification

      This Website may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

    • User identification via a universally unique identifier (UUID)

      This Website may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

Contact information

    • Owner and Data Controller

      BRO OÜ
      Reg. nr. 14093867
      VAT: EE101915913
      Address: Tuukri 19, Tallinn, Estonia
      E-Mail: gdpr@borissov.ee
      Contact person: Roman Borissov

      Owner contact email: gdpr@borissov.ee