Privacy Policy

Vitamare Group Holdings Ltd: Online Privacy Notice

Last updated: January 20, 2022

We at Vitamare Group Holdings Ltd, along with Vitamare Consulting Gulf FZ-LLC, Vitamare Group Capital Inc., CPP Intelligent Systems Solutions Ltd, Mobadv Ltd, E-Spark Fintech Group Ltd, Intelligent Leads LLC, 24K Management DMCC and Kraken Properties Ltd (“collectively Vitamare Group”), respect your concerns about privacy. This Online Privacy Notice applies to personal information we obtain through this website (“Site”). This Online Privacy Notice describes the types of personal information we obtain through the Site, how we may use the information, with whom we may share it and the choices you may have regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

If you would like information about our online and offline privacy practices and your privacy rights, please see the section of this Privacy Notice called “Consumer Privacy Statement.”

Below you will find information pertaining to the following areas:

· Information We Obtain

· How We Use The Information We Obtain

· Information We Share

· Your Options

· Access and Correction

· Data Transfers

· Links To Other Websites

· How We Protect Personal Information

· Updates To Our Online Privacy Notice

· How To Contact Us

· California Consumer Privacy Statement

Information We Obtain

We may obtain the following types of personal information when you choose to provide it through our Site:

· Contact information, such as your name, postal address, email address and telephone number;

· personal information in content you provide on our Site; and

· information about your education, work and military history, legal work eligibility status, and

· other information relevant to specific jobs for which you may apply.

In addition, when you visit our Site, we may collect certain information by automated means, such as cookies and web beacons. The information we obtain in this manner includes IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, and dates and times of website visits. A “cookie” beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.

Information about our cookie practices in the European Union is available here. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.

How We Use The Information We Obtain

We use the information we obtain through the Site to:

· respond to and communicate with you about your requests, questions and comments;

· operate, evaluate, and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing, and advertising; analyzing and enhancing our products, services and Site; and performing accounting, auditing, billing, reconciliation and collection activities);

· perform data analyses and other processing (including market and consumer research, trend analysis, financial analysis, anonymization, encryption and tokenization of personal information);

· manage career opportunities;

· protect against, identify, and prevent fraud and other criminal activity, claims and other liabilities; and

· comply with and enforce applicable legal requirements, relevant industry standards and our policies.

In addition, we use information collected online through cookies, web beacons and other automated means for purposes such as (i) customizing our users’ visits to our Site, (ii) delivering content (including advertising) tailored to our users’ interests and the manner in which our users browse our Site, and (iii) managing our business. We also use this information to help diagnose technical and service problems, administer our Site, identify users of our Site, and gather demographic information about our users. We use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We may use third-party web analytics services on our Site, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web who use the information to evaluate use of the Site. To learn more about Google Analytics and how to opt out, please visit www.google.com/analytics/learn/privacy.html

Our Site is not designed to respond to “do not track” signals received from browsers.

Information We Share

We do not sell or otherwise share personal information about you, except as described in this Online Privacy Notice. We share personal information with third parties who perform services on our behalf. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also share the personal information we obtain with our affiliates and subsidiaries for the purposes described in the section of this Online Privacy Notice called “How We Use the information We Obtain.”

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Your Options

We offer you certain choices about how we communicate with you and what information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the How To Contact Us section of this Online Privacy Notice.

Access and Corrections

To the extent provided by the law of your jurisdiction, you may (i) have the right to access certain personal information we maintain about you and obtain a copy of that information, (ii) update or correct inaccuracies in that information, (iii) object to our use of your personal information, and (iv) delete your personal information from our database. To exercise these rights, please contact us as indicated in the How To Contact Us section of this Online Privacy Notice. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. A charge may be applicable before we provide you with a copy of any of your personal information that we maintain.

Data Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected, including the U.S. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this Online Privacy Notice and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information.

Vitamare Group is certified under the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield frameworks (collectively, the “Privacy Shield”) developed by the U.S. Department of Commerce and the European Commission and Swiss Federal Data Protection and Information Commissioner, respectively. Click here to view our EU/Swiss-U.S. Privacy Shield Privacy Policy. We no longer rely on the EU-U.S. Privacy Shield to transfer personal information to the U.S.

Links To Other Websites

Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Vitamare Group. Linked websites typically have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with Vitamare Group, any use of those websites, or the privacy practices of those websites.

How We Protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Updates To Our Online Privacy Notice

This Online Privacy Notice will be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Site to notify you of any significant changes to our Online Privacy Notice and indicate at the top of the notice when it was most recently updated.

How To Contact Us

If you have any questions about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at privacy@vitamaregroup.com or write to us at:

Vitamare Group Holdings Ltd Attn: 22 Arch Makarios III Avenue, Makaria Center, Suite 403, Larnaca 6017, Cyprus

Consumer Privacy Statement

Last Updated: January 20, 2022

This California Consumer Privacy Statement (“Statement”) supplements the Vitamare Group Holdings Ltd Online Privacy Notice. It applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to Vitamare Group personnel. Sections 2-5 of this Statement do not apply to job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

· Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers

· Additional Data Subject: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information

· Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status

· Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies

· Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements

· Sensory Information: audio, electronic, visual, and similar information

· Employment Information: professional or employment-related information

· Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy

· Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Online Privacy Notice and for the following business purposes specified in the CCPA:

· Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

· Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

· Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

· Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

· Debugging to identify and repair errors that impair existing intended functionality

· Undertaking internal research for technological development and demonstration

· Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

· Managing career opportunities with Vitamare Group.

1. Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

· Directly from you, such as when you contact us with a question or comment

· From your devices, such as when you visit our Site

· Vendors who provide services on our behalf

· Social networks

· Government entities

· Data brokers

1. Sale of Personal Information

We do not and will not sell your personal information.

1. Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information

Category of Third Party

Identifiers

Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks

Additional

Protected Classifications

Commercial

Online Activity

Employment Information

Education Information

Inferences

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: Government entities.

1. Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request: To submit an access or deletion request (or to submit a request as an authorized agent on behalf of a consumer), email us at privacy@vitamaregroup.com or call us at +357 24257550. For questions or concerns about our privacy policies and practices, please contact us as described in the How to Contact Us section of our Online Privacy Notice.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: your email address, the name of the Vitamare Group representative with whom you typically interact, and the date of your last interaction with an Vitamare Group representative. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

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