This statement tells how RubyGarage gathers, uses, and manages website visitors' data.
This website and its owners take a proactive approach to user privacy and ensure that necessary steps are taken to protect the privacy of its users throughout their visit. This website complies with the national laws of the visitor’s country as well as requirements for user privacy.
Cookies are small files saved to a user’s computer/device hard drive that track, save, and store information about the user’s interactions and website use. They allow a website, through its server, to provide users with a tailored experience within the site.
Users are advised to take necessary steps within their web browser security settings to block all cookies from this website and its external serving vendors if they wish to deny the use and saving of cookies from this website to their computer’s/device’s hard drive.
This site uses the Lucky Orange analytics system to help improve usability and the customer experience. Lucky Orange may record mouse clicks, mouse movements, and scrolling activity. Lucky Orange may also record keystroke information that is voluntarily entered on this website. Lucky Orange does not track this activity on any site that does not use the Lucky Orange system. You can choose to disable the Lucky Orange service at http://www.luckyorange.com/disable.php. Note that doing so will disable other features of the Lucky Orange system that this site employs, such as one-to-one support chat.
Contact & Communication
Users contacting this website or its owners do so at their own discretion and provide any personal details requested at their own risk. Your personal information is kept private and stored securely until such time that it is no longer required or has no use. Every effort has been made to ensure a safe and secure form to email submission process, but users are still advised that using such form to email processes are done at their own risk.
This website and its owners use information submitted to provide you with further information about the products and services they offer and to assist you in answering any questions or queries you may submit. This includes using your details to subscribe you to any email newsletter program the website operates, but only if this was made clear to you and your express permission was granted when submitting a form to email process or when you, the consumer, have previously purchased from or enquired about purchasing from the company a product or service that the email newsletter relates to. This is by no means an entire list of your user rights with regard to receiving email marketing material. Your details are not passed on to any third parties.
This website operates an email newsletter program to inform subscribers about products and services supplied by this website. Users can subscribe through an automated online process should they wish to do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.
Subscriptions are made in compliance with spam laws of the visitor’s country. All personal details relating to subscriptions are held securely and in accordance with the current data protection laws of the visitor’s country. No personal details are passed on to third parties or shared with companies or people outside of the company that operates this website.
Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include: opening of emails, forwarding of emails, clicking of links within email content, and times, dates, and frequency of activity. This list of tracked activities is not comprehensive.
Information tracked in emails is used to refine future email campaigns and supply users with more relevant content based on their activity.
Subscribers are given the opportunity to unsubscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated unsubscribe system is unavailable, clear instructions on how to unsubscribe will be detailed instead.
Although this website only intends to include quality, safe, and relevant links to external sites, users are advised to adopt a policy of caution before clicking any links to external websites contained throughout this website. (External links are clickable text, banners, or image links that direct the user to other websites).
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note that they click on external links at their own risk and that neither this website nor its owners can be held liable for any damages or implications caused by visiting any external links on this website.
Social Media Platforms
Communication, engagement, and actions taken on external social media platforms that this website and its owners participate on are governed by the terms and conditions as well as the privacy policies of each respective social media platform.
Users are advised to use social media platforms wisely and communicate/engage on them with due care and caution with regard to their own privacy and personal details. Neither this website nor its owners will ever ask for personal or sensitive information through social media platforms, and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as telephone or email.
This website may use social sharing buttons that help users share web content directly from website pages to a given social media platform. Users are advised before using such social sharing buttons that they do so at their own discretion and should note that social media platforms may track and save requests to share a web page through a social media platform account.
Shortened Links on Social Media
This website and its owners, through their social media platform accounts, may share links to relevant website pages.
Users are advised to exercise caution and good judgement before clicking any shortened URLs published on social media platforms by this website or its owners. Despite the best efforts to ensure only genuine URLs are published, social media platforms are prone to spamming and hacking, and therefore neither this website nor its owners can be held liable for any damages or implications caused by visiting any shortened links.
Our full contact details are as follows:
- Full name of company: DigitalRockets OU d/b/a RubyGarage
- Name or title of Data Security Officer ("DSO"):
- Email address: [email protected]
- Physical address: Tallinn, Lasnamäe linnaosa, Liikuri tn 10-107, 13618
You have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance and we will do our very best to deal with your concerns.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Collection and use of data
Categories Of Data We Collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. We do not collect personal data about you unless you voluntarily submit that information to us or that information is collected via certain automated technologies discussed below.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, date of birth, username or similar identifier.
- Contact Data includes address, email address
- Technical Data includes internet protocol (IP) addresses, location information, browser type, browser language, pages viewed, time spent and the date and time of a visit.
Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we will not be able to provide the Services to you.
Automated technologies or interactions. As you interact with us, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. Some of the ways in which we or Services may collect are further described below:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- To perform specific services that you have requested;
- To respond to your direct inquiries;
- To provide, maintain, improve and secure our Services and develop and offer new features and functionality;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- To send you marketing materials;
- To process any application for employment;
- Where we need to comply with a legal or regulatory obligation.
We will also process your personal data in accordance with your consent. You have the right to withdraw consent to marketing at any time by contacting us at [email protected] Below are other types of lawful basis that we may rely on to process your personal data:
- Legitimate Interest means our interest in conducting and managing our business to enable us to give you the best services/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a Legal or Regulatory Obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation.
Disclosures Of Your Personal Data
We may share your personal data with the parties set out below:
- Third parties (including service providers and subcontractors) to aid us with improve, analyze and secure the Services and to develop and offer new products and services.
- Third parties (including service providers and subcontractors) working on behalf of or with Company to provide (i) information about our products or services, or (ii) the products or services requested by you. These third parties are subject to confidentiality agreements and do not have any independent or legal right to share your personal data.
Company reserves the right to disclose personal data it collects: (i) if Company believes it is necessary to do so in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Service's Terms and Conditions, Agreements between us or as otherwise required by law; (ii) when Company believes that disclosure is necessary to protect its legal rights and/or to comply with a judicial proceeding, court order or legal process served on Company; or (iii) to transfer information in the event of a merger, acquisition, transfer of assets, or other organizational restructuring or change of control.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Withdrawing Your Consent
If you have given us consent to process your personal data, you have the right to withdraw your consent at any time.
Confidentiality and security of personal data
Company maintains commercially reasonable physical, electronic and procedural safeguards that comply with applicable laws and regulations to protect the confidentiality of your personal data. However, as no method of transmission over the Internet, nor method of electronic storage, is 100% secure, Company cannot guarantee the absolute security of your personal data.
We retain your information for as long as needed for our functions or activities or to comply with our legal obligations (such as reporting to regulatory authorities), to resolve disputes and to enforce our rights. We also may retain your information to support our business operations and develop our Services. The criteria used to determine our data retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes.) When we no longer need to use your information, we will take steps to properly anonymize or destroy it. We may retain information that is not personally identified to an individual User, including without limitation anonymized data and aggregate information, in our discretion.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, and if that is the case, we will notify you at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
To exercise your rights, please contact us at [email protected]
If you are situated in the EU, whenever we transfer your personal data to processors outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. We may use approved transfer methods such as specific contracts approved by the European Commission which give personal data the same protection it has in the EU. For further details, please contact us [email protected]
The Company works only with individuals who are at least 18 years old.
v.2.0 April 2020