Matomba takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.

We recommend that you read this privacy policy in full to ensure you are fully informed.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of the privacy policy.

The privacy policy is fully compliant with the requirements of the current legal framework in relation to data processing and with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Table of contents

1. Basic information

1.1. About Us

Matomba is an online marketing platform (the “Services”) located on the website https://matomba.com  (the "Site") and operated by LLC MATOMBA TECHNOLOGIES INN 5043077977 OGRN 1225000087597 KPP 504301001 ("us", "we", or "our", “Matomba”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site, our clients and clients of our clients.

1.2. Key terms

• "Personal Information" is any information that is related directly or indirectly to a specific or identifiable individual. Examples of personal data include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
• "User" means a user of the Site.
• "Clients of the user" means any person that is the user’s client.
• "You" and "your" means, depending on the context, either a user or a client of the user.
• "Client" means any person, entity, public authority, agency or other body that is registered with us to use the Services.
• “Contact” means any person or entity that is a client of our Client.

2. Data privacy

This section applies to the Personal Information we collect and process from a user or a client of the user through the provision of the Services.

Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your clients. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email or communicate with us in any other way.

We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use  and in this privacy policy.

2.1. Privacy for Clients

It applies to the Personal Information we collect and process from a Client or potential Client through the provision of the Services.

2.1.1. Data we collect from our Clients

Matomba collects the following data:

• Registration information: to become a user of our Services you need to create an account. When you register for an account, you will be asked to provide certain basic information, such as your name, email address, password, phone number.
• Billing and communications information: If you purchase our Services, you may also need to provide us with payment and billing information, such as your credit card details and billing address. Matomba will also maintain a record of your billing transactions and purchases, and any communications and responses.
• Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services: Device information, Log data, Product usage data. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below.
• Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
• Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.
• Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other communications you send through the Services. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services.
• Information we collect from other sources: From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.
• Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.

2.1.2. Use of your personal data

Matomba collects your data for the following purposes:

• To bill and collect money owed to us by you. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments.
• To send you system alert messages. For example, we may inform you about temporary or permanent changes to our Services, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.
• To communicate with you on the Site.
• For our data analytics projects. Our data analytics projects use data from Matomba accounts, including your Personal Information, to provide and improve the Services. We use information, like your purchase history, provided to us by Clients, so we can make more informed predictions, decisions, and products for our Clients. For example, we use data from Matomba accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Clients. If you prefer not to share this data, you can opt out of data analytics projects at any time by emailing us at support@matomba.com
• To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Clients and third parties, as well as our own. This may include developing tools and algorithms that help us prevent violations.
• To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
• To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting or security requirements.
• To prosecute and defend a court, arbitration, or similar legal proceeding.
• To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• To provide, support and improve the Services.
• To provide suggestions to you.
• Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.

2.2. Privacy for Contacts

It applies to the information we process about our Clients’ Contacts as a data processor pursuant to our legitimate business interests and business interests of our Clients. Our Services are intended for use by our Clients. As a result, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Clients who acts as controllers of data processing. Matomba is not responsible for the privacy or security practices of our Clients, which may differ from those set forth in this privacy policy.

2.2.1. Data we collect from our Contacts

The Personal Information that we may collect or receive about you falls into the following categories:

(i) Information we receive about Contacts from our Clients: A Client may provide Personal Information about you to us through the Services. They may provide us with certain contact information or other Personal Information about you such as your name, email address, telephone number, social media contacts, online messenger’s contacts. Moreover, when you enter the information in the gaps of the quiz built-in on the websites of our Client, we will receive it. You may have the opportunity to update some of this information by electing to update or manage your preferences via an email you receive from a Client.

(ii) Information we collect automatically: When you enter the information in the gaps of the quiz built-in on the websites of our Client we automatically collect your Personal information such as your name, email address, telephone number, social media contacts and online messenger’s contacts (ID, numbers).

(iii) Information we collect from other sources: We do not collect any personal data from  sources other than listed in paragraphs (i), (ii) of 2.2.1. of this policy.

2.2.2. Use of Personal Information

We may use the Personal Information we collect or receive about you for our legitimate business interests, including:

• To provide the Services to our Clients that will help them to pursue their legitimate business interests such as providing their services and goods to you.
• To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
• To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
• To prosecute and defend a court, arbitration, or similar legal proceeding.
• To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.

3. General information

3.1. Cookies

Matomba collects cookies of our users and Clients. Matomba do not collect cookies of our Contacts.

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Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information. Nevertheless, you can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

What types of cookies do we use:

• Functionality - Matomba uses these cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising - Matomba uses these cookies to collect information about your visit to our Site, the content you viewed, the links you followed and information about your browser, device, and your IP address.

3.2. We store your data

Matomba securely stores your data at data center “ObjectRocket”, a Rackspace Company.

Matomba will keep your personal data until the objects of the policy are achieved but no longer than for 3 (three) years since data collecting.

3.3. Your data protection rights

Matomba would like to make sure you are fully aware of all of your data protection rights. Every user, Client or a Contact is entitled to the following:

• The right to access - You have the right to request Matomba for copies of your personal data. We may charge you a small fee for this service.
• The right to rectification - You have the right to request that Matomba correct any information you believe is inaccurate. You also have the right to request Matomba to complete information you believe is incomplete.
• The right to erasure You have the right to request that Matomba erase your personal data, under certain conditions.
• The right to restrict processing - You have the right to request that Matomba restrict the processing of your personal data, under certain conditions.
• The right to object to processing - You have the right to object to Matomba processing of your personal data, under certain conditions.
• The right to data portability - You have the right to request that Matomba transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: support@matomba.com.

3.4. Marketing

If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop Matomba from contacting you for marketing purposes.

3.5. Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. If personal data breach is likely to result in a high risk to the rights and freedoms personal data breach, you will be aware in less than 72 hours.

Data Center Security:

• Every day Matomba processes lots of personal data, which must be highly protected. For these purposes, we use the services of data center “ObjectRocket”, a Rackspace Company.
• Our data center manages physical security 24/7 with secure connection, authorized access.

Protection from Data Loss, Corruption.

• All databases are kept separate and dedicated to preventing corruption and overlap. We have multiple layers of logic that segregate user accounts from each other.
• Account data is mirrored and regularly backed up off site.

Banking information protection

• Be aware that nobody will be informed about your banking transactions. We depersonalize your data in case of payment.
• Matomba credit card processing vendor uses security measures to protect your information both during the transaction and after it is complete. Our vendor is certified as compliant with card association security initiatives, including the Visa Cardholder Information Security and Compliance (CISP), MasterCard® Site Data Protection Program (SDP), and Discovery Information Security and Compliance (DISC).

3.6. Changes to this Privacy Policy

This Privacy Policy is effective as of 23 October 2019 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the e-mail address you have provided us, or by placing a prominent notice on our website.

3.7. How to contact us

If you have any questions about Matomba privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

E-mail us at: support@matomba.com

3.8. How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Matomba has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.

Website: ico.org.uk

Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF&.