EMPOWERED PRIVACY POLICY

Effective Date: 12 November 2024

Empowered Privacy Policy (the “Policy”) explains all the privacy matters you may face when using our website, and other websites run by Empowered (the “Website”) jointly the “Service”, operated by LATHINOL LIMITED (“Empowered” or “we”).

Some services that may be employed by either Empowered or you to interact with the Services may have their own privacy rules (third-party privacy policies). Thus, if your personal data is processed by such services, such processing is governed by third-party privacy policies, not this present Policy.

This Privacy Policy explains what personal data is collected when you use our websites, and the services provided through them, how such personal data will be processed.

By using our service, you promise us that (i) you have read, understand and agree to this privacy policy, and (ii) you are over 18 years of age. If you do not agree, or are unable to make this promise, you must not use the service.

1.Changes and Updates to Policy

Reasons of Updates. We may revise the Policy according to new developments or advances in legislation and the broader data protection landscape from time to time, so please check this page regularly to ensure you’re always up -to-date with any changes.

Communication on Updates. If we make any changes hereto that, in our sole discretion, are substantial, we will notify you by email (to the address associated with your profile), post a notice within Empowered Services or make a notification appear in your profile when you next log in to Empowered before amendments become effective.

2. Your Data Controller and Data Processors; Service providers, Contractors and Third Parties Accessing Data

Information about who processes your data and with whom we may share your data is considered to be one of the most vital points you should know, so we place this article here, in the Policy's beginning. In this section, we also explain what third-party sources we may use to receive your data from.

2.1 Roles and Definitions. The first you should know is information about your data controller and processors. The data controller is an entity that determines the purposes and means of the processing of the data. The data processor is an entity that processes the data on behalf of the controller. A third party is a person whose access to the data depends on their rights or duties.

Data Controller; EU Representative; Data Protection Officers:

• in this current case, your data controller is LATHINOL LIMITED, 705, Spyrou Araouzou & Koumantarias, Fayza House, 5th floor, office No.: 2, 3036, Limassol, Cyprus; email: support@empowered-web.com;
• our EU Representative – for General Data Protection Regulation (GDPR) compliance purposes – is Risovel Limited, a company with its registered address at 705, Spyrou Araouzou & Koumantarias, Fayza House, 5th floor, office No.: 2, 3036, Limassol, Cyprus;
• our UK Representive is AMORIGIN LIMITED, with its registered address at Ibex House, 61 Baker Street, Weybridge, England, KT13 8AH;
• our Data Protection Officer (DPO), If you are an EU/UK citizen or a resident, feel free to contact our EU DPO in case you have any questions via support@empowered-web.com

2.2 Data Processors. We engage partners to carry out specific services or business functions on our behalf using their technologies and resources based on our instructions. This cooperation may involve, in particular, processing your data using their software development kits (SDKs), APIs, cookies, and other technologies. Consequently, your information is transferred and processed on their servers (usually without a partner's direct access to the specific pieces of information) on our behalf for our purposes.

Such type of processing of personal data may be regarded as sharing information with third parties. We strive to conclude specific data processing agreements with all such parties to establish the rules for processing your data specifically on our behalf and limited to it. Our partners help us operate, provide, improve, integrate, customize, support, and market our Service.

We share personal data with third parties that we hire to provide services or perform business functions on our behalf based on our instructions. We process your personal information using the following types of service providers (and, in certain cases, their subprocessors):

A. Cloud storage providers

To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon. You may read more on Amazon’s security practices on its website..

B. Gateway service providers and payment processing partners

We use various payment processing and payment gateway providers that help us connect with different banks and payment systems around the world. These providers allow us to offer our customers a wide range of payment options and ensure fast and smooth transactions. Each payment processing provider has its own terms and conditions and privacy policy that may apply to the transactions they process. To enable the purchase and to process your payments we use Solid payment processing provider.

C. Communication services providers

Mailgun provides us with customer service software, which enables us to handle your inquiries and requests via emailother channels (if applicable). Thus, when you contact us via any of these channels, some of your information is automatically transferred to Mailgun . The transfer is required to provide you with timely and effective support.

D. Data analytics providers

We use Adjust and Amplitude to collect and analyze data on how our services are used. When you engage with our services, some information is shared with Adjust and Amplitude. Such sharing process is essential for us to monitor performance and make data-driven improvements that benefit you as the user and enhance user behaviour.

E. Advertising providers

We collaborate with Meta, TikTok, and Google to make your advertising experience more personalized and meaningful. By sharing certain data, these platforms can present ads that are tailored to your interests, so that you see more relevant advertisements.

F. Third Parties: Law Protection and Enforcement Bodies; Attorneys-at-Law.

Empowered is a place free of any kind of abuse, violence, laws and third-party rights infringement. We designed Empowered as a safe harbor for people to be themselves and express their emotions. We do our utmost to protect our biggest value, sense of security of our users, so we may disclose your data to third parties in the following cases:

• we will cooperate with law enforcement inquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behaviour or to protect the vital interests of a person. We may share any personal data that we hold about you, depending on the nature of the request or the issue that we are dealing with;
• we will disclose your data if it’s necessary so as to comply with a judicial proceeding, court order, or legal request of a state body (a law protection or enforcement body). We may share any personal data that we hold about you, depending on the nature of the request or the issue that we are dealing with;
• we may also cooperate with all third parties to enforce their intellectual property or other rights in the event we are notified of an offence by one of our users. Still, we will share your data if we receive respective and motivated legal request of such by the third party’s attorney-at-law, proving your violation only. We may share any personal data that we hold about you, depending on the nature of the request or the issue that we are dealing with. Please note, if we find no proof sufficiently established in an inquiry, we will not disclose your data;
• society may be cruel at times; wrong words or actions of others may hurt. Still, this is not a reason to harm yourself. Here, at Empowered, we believe that every issue can be fixed, and we are ready to share contact details of our partners who may offer professional help. If we detect suicidal behavior by our users, we may report such a case to the police or professional non-governmental organization, so as to prevent our users from making the biggest mistake of their lives. We may share your name, contact details and geolocation with those bodies;
• we may transfer your data to a respective law protection or enforcement body if we detect illegal activity or we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person. We may share any personal data that we hold about you, depending on the nature of the violation or the issue that we are dealing with; and finally
• we will share your data with our lawyers, a court, arbitrators, or any authorized professional etc. if we detect your conduct is in breach of Empowered’s Terms of Service or any integral parts thereto or in order to protect the rights and property of Empowered, its affiliates, or the public or to comply with legal and regulatory obligations.

3. Empowered’s Approaches toward Children’s Privacy

The Site is intended for a general audience and not directed to children under thirteen (13) years of age. We do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe we have collected such information in a manner not permitted by COPPA, please contact us by email at support@empowered-web.com, and we will remove such data to the extent required by COPPA.

4. Collection of Personal Data

In this article, we explain what data we collect (categories and a full list of data), the sources we get your data from, the purposes for which the data is used, and our legal basis to process your data. Here, we also share some useful data privacy tips with you.

For the users who are California residents, you may find more information about the collection of categories of personal information and sensitive personal information in sections 8.1-8.2. hereof.

4.1 Personal Data Collected and Source.

We may collect data you give such as email, name, last name, date of birth, information provided in response to quizzes. We also collect data automatically such as IP address, device type, user agent.

Data you give us
When you register for and/or use the Website and the Service, you provide us with information about yourself, for example, your email address, name, date of birth (age). We may also ask you to answer some questions relating to lifestyle and relationships. You can provide us with your email when you contact our support team.

Data we collect automatically:

Data about how you found us We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad).

Device and Location data We collect data from your mobile device. Examples of such data include: IP address,type and model of a device, operating system.

Usage data We record how you interact with our Website. For example, we log what pages you have viewed, the features and content you interact with, how often you use the Website, how long you are on the Website, your purchases, your taps on certain areas of the interface, the features.

Advertising Trackers We collect cookies, pixels and other trackers to tailor ads and possibly even show them to you at the relevant time.

4.2 Purposes of Data Processing

We collect the mention data in section 4.1. with the following purpo

• To provide our Service. This includes enabling you to use the Website in a seamless manner and preventing or addressing Website errors or technical issues. As a result of such processing, we will use your email, for example, for sending you the information about your purchase.
• To customize your experience. We process your personal data, such as age, relationship status to adjust the content of the Website and provide content tailored to your personal preferences. We may also use the information provided by you during the quiz on relationship and lifestyle to make the most suitable offer to you. As a result of such processing, you get access, for example, to educational courses designed for your goals.
• To manage your account and provide you with customer support. We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Website, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.
• To communicate with you regarding your use of our Website. We communicate with you, for example, by push notifications or by emails. These may include reminders or other information about the Website. To opt-out of receiving emails, you should click unsubscribe link in the footer of each email.
• To research and analyze your use of the Website. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Website and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Website. As a consequence, we often decide how to improve the Website based on the results obtained from this processing. For example, if we discover that users choose certain features of the Website, we may focus on improving the category or decide to remove it.
• To send you marketing communications. We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Website. We may show you advertisements on our Website, and send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.
• To personalize our ads. We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website, you might see ads of our products in your Meta's feed.
• To enforce our Terms and Conditions of Use and to prevent and combat fraud. We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
• To comply with legal obligations. We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

4.3 Legal Basis for Data Processing (EEA users)

This subsection applies exclusively to users based in the EEA. We process your personal data in accordance with the legal bases established by the GDPR.

• performing the contract with you: under this basis we provide our Service, customize your experience, manage your account and provide you with customer support.
• legal obligation: under this basis we comply with legal obligations.
• legitimate interest: under this basis we research and analyze your use of the Website, enforce our Terms and Conditions of Use and to prevent and combat fraud
• your consent: under this basis we communicate with you regarding your use of our Website, send you marketing communications, personalize our ads.

Specifically, in order to process the mention data in section 4.1. we rely on the following legal grounds: legitimate interest and performing the contract with you.

5. Duration and Location of Processing; Cross-Border Data Transfer

5.1 Retention. Empowered is committed to processing your personal data as long as it is actually useful and necessary to offer you a quality service through their processing. Therefore, Empowered will make all reasonable and timely efforts to minimize the processing and retention time for your personal data.

Even if you request the erasure of your personal data, Empowered will have the right to store and retain them for the time necessary to comply with the legal obligations that apply, as well as to make them available to the competent authorities in the different matters that are applicable.

Generally, we delete or anonymize your information, including sensitive information indicated for California Residents, within two years.

5.2 Location of Servers. Our servers are based in the USA and EU, so your data may be processed and hosted outside the EU. We inform you that we use EU servers to collect and process EU and UK residents’ data and we use USA servers to collect and process data of users from the rest of the countries.

5.3 Cross-Border Data Transfer. The sharing of personal data may involve cross-border data transfers to the United States of America and other jurisdictions that may have different laws about data processing. If we transfer personal data collected within the EEA to countries with not adequate level of data protection, we deploy special safeguards. In particular, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here) (or any new version of contractual clauses issued by a data protection body (if any), or (ii) the European Commission adequacy decisions about certain countries (details available here).

6. Cookies and similar tracking technologies

We use cookies and other tracking technologies to improve your user experience and obtain data about how the website is being used. This data enables us to develop and optimize the Website and make the use of the Services more comfortable for you. Please read out Cookies Policy to find out more.

7. Your Data Privacy Rights

Being a data subject, you have the following rights:

• a right to request access to your data: you can ask us what personal information of yours is being processed, as well as for clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties that have access to information. To exercise this right, please contact us at support@empowered-web.com. Please find more details in section 11 hereof;
• a right to request us to rectify your personal information: you can ask all the inaccurate personal information concerning you to be corrected. You can also complete the personal information if you feel there is a need to do so. To exercise this right, please contact us at support@empowered-web.com or use a specific area of your profile. Additionally, we are happy to note that there is the alternative way to amend your data. You control your Empowered profile, so are able to correct or update (other than your mobile number and location (the latter is automatically updated)) your information at any time by just logging in to Empowered and using the respective settings;
• a right to request us to erase personal information: you can request us to erase such data in the following circumstances: (i) where you believe it is no longer necessary for us to hold that personal data, (ii) where we process it on the basis of your consent and you wish to withdraw your consent, (iii) where we process your personal data on the basis of our legitimate interest and you object to such processing, (iv) where you no longer wish us to use your personal data to solicit you commercially, or (v) where you believe that we are unlawfully processing your personal data. In most cases, we will erase it ourselves, unless otherwise required by legislation. To exercise this right, please contact us at support@empowered-web.com;
• a right to withdraw your consent for the collection and processing of your data by us: you can revoke your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. To exercise the right, please contact us at support@empowered-web.com;
• The right to give post-mortem instructions: you have the right to set out instructions for the retention, deletion and disclosure of your data after your death.
• If you are based in the EEA the following additonal rights apply to you: The right to lodge a complaint with supervisory authority: you can file a complaint with a supervisory authority if you believe that our processing of your personal data violates the GDPR.
• The right to data portability: you have a right to receive your personal data in a machine-readable format. To exercise the right, please contact us at support@empowered-web.com.

8. Notice to California Residents

This Section here applies to California consumers only. This section also provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act of 2018, Cal. Civ. Code §§ 1798.100–1798.199, the California Privacy Rights Act and the associated regulations (collectively, the “CPPA”).

8.1. Categories of Personal Data. For the users who are California residents, you may find the categories of personal information Empowered collects and the business purposes and the sources for which your personal information is collected in section 4.1 hereof.

8.2. Sensitive personal information. In addition to the collection of personal data listed in section 4.1. You also may find the categories of your sensitive personal information under the CPPA and the business purposes for which such information is collected.

8.3. Selling/Sharing of your personal information. The definition of “sale” under CPPA is broad and covers many common business activities, even when the personal Information is not exchanged for money. Empowered does not sell personal information for monetary consideration; however, we may share certain personal information with third parties under circumstances which might be deemed a “sale” or “share” under CPPA for “interest-based advertising” or “cross-context behavioral advertising.” In other words, Empowered may share your personal information with a third party to help serve you with personalized content or ads that may be more relevant to your interest.

The third parties, service providers and other processors with which we may share or disclose specific pieces of personal information over the 12-month period prior to the effective date of our Privacy Policy are indicated in sections 2.2 hereof. We disclose your personal information, including sensitive information, with processors, service providers and contractors indicated in sections 2.2 hereof for business purposes that it is not defined as a “sale” or “share” under CPPA. We enter a contract with them that describes the purpose and requires the recipient to both keep that personal Information, including sensitive personal information, confidential and not use it for any purpose except as described in the contract.

Empowered may share in the sense of CPPA certain personal information (Advertising identifier; localization data; IP Address) with our ad/ marketing partners. These third-parties may also collect information directly from you through tracking technologies such as cookies. You may request to opt-out of the sale/sharing of your personal information, please see below on how to submit such request.

8.4. Your rights. For the users who are California residents, you have the following rights in addition to those listed in section 7 above.

The right to know what personal information is being collected and the right to know what personal information is sold or shared. You have the right to request, twice within a 12-month period, the following information about the data we have collected about you during the past 12 months:

• The categories of personal information Empowered has collected about you.
• The categories of sources from which the personal information is collected.
• The business or commercial purpose for collecting, selling, or sharing personal information.
• The categories of personal information that Empowered sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared.
• The categories of third parties to whom Empowered discloses personal information.
• The specific pieces of personal information it has collected about that consumer.

The right to delete your personal information or correct inaccurate personal information. You may request Empowered to delete any personal information about you that Empowered has collected. You also have the right to request Empowered to correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

How to Submit a Request. To submit a request for information required to be disclosed and a request for deletion or correction, please contact us by email at support@empowered-web.com.

Right to limit the use of your sensitive personal information. You may direct Empowered, which collects your sensitive personal information indicated in section 8.2. hereof, to limit the use or disclosure to that use which is necessary to perform the Services.

If you choose to exercise any of your privacy rights under the CPPA, you have the right not to receive discriminatory treatment by Empowered.

You are always welcome to request “.pdf” copy of this Policy or any other integral part of Empowered’s Terms of Use (as well as Empowered’s Terms of Use themselves); just let us know by sending your request to support@empowered-web.com.

To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your data or complying with your request. If requests from a consumer are manifestly unfounded or excessive, in particular, because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you the reason for refusing the request.

You may also use an authorized agent to submit your request. If you do, we may ask for evidence that you have provided the agent valid power of attorney or other written permission to submit requests on your behalf, and we may also take steps to verify your identity. Owing to a sensitive nature of your data, we reserve the right to reject, at any time, requests concerning your data submitted by any third party.

9. Notice to Virginia and Texas Residents

Consumers residing in Virginia or Texas are afforded certain additional rights with respect to their personal information under the Virginia Consumer Data Protection Act (VCDPA) and the Texas Data Privacy and Security Act (TDPSA), respectively. If you are a Virginia or Texas resident, this section applies to you.

9.1. Our collection and use of personal information. You may find the categories of personal information Empowered collects and the purposes and sources for which your personal information is collected in section 4.1. hereof.

9.2. Exercising your consumer rights: You have the right to request (1) to confirm whether or not a controller is processing the consumer's personal data and to access such personal data; (2) To correct inaccuracies in the consumer's personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer's personal data; (3) To delete personal data provided by or obtained about the consumer; (4) To obtain a copy of the consumer's personal data that the consumer previously provided to the controller in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means; (5) to opt out of the processing of the personal data for purposes of targeted advertising.

You may exercise your rights by contacting us at support@empowered-web.com. See more details in section 10 below. We will not discriminate against you if you exercise your rights under the VCDPA or TDPSA. You may contact us at support@empowered-web.com if you want to appeal Empowered`s refusal to take action on your request. The appeal process is conspicuously available and similar to the process for submitting requests. Empowered will have 60 days of receipt of an appeal to inform you in writing of any action taken or not taken in response to the appeal. If the appeal is denied, you may contact the Attorney General of your state to submit a complaint. For Texas, you can do so at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint, and for Virginia at https://www.oag.state.va.us/consumer-protection/file-a-complaint

9.3. Sale of personal information and process of personal information for targeted advertising. We do not sell your personal information. We do not exchange your personal data for monetary consideration with third parties, so no opt-out choice is necessary for that. However, we do process your personal information for targeted advertising in the sense of VCDPA or TDPSA. We display advertisements to you where such adds are based on personal data obtained from nonaffiliated websites. You can opt out of the processing of personal data for purposes of targeted advertising by contacting us at support@empowered-web.com.

10. Data Subjects’ Access and Erasure Requests

10.1. Method for Submitting Requests. If you are a California, Texas or Virginia consumer, you may exercise your privacy rights under sections 8 or 9.

10.2. Timeframes. In the event you submit your request to us, we will act as follows:

• within 10 business days following confirmation of receipt of your letter, we shall request that you provide us with relevant data for a verification procedure;
• if you are a California, Texas or Virginia consumer, we will have 45 calendar days following the date of your request to process your request. In the event of your failure to pass the verification process within 45 calendar days, we may deny your request or prolong the term of processing up to an additional 45 calendar days; please be sure that we will notify you about our decision.

11. Data Protection

We regularly monitor our systems for possible vulnerabilities and attacks and review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures.

TO THE MAXIMUM EXTENT ALLOWED BY APPLICABLE LAW, WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORISED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.

We would be glad to hear from you. If you have any questions regarding this Policy, please contact us at support@empowered-web.com