1. PURPOSE AND SCOPE OF THE PRIVACY POLICY

The anonymous company named MEDIA PAY PLUS LTD is headquartered in Cyprus at 161 Arch. Makarios III, 3027, Limassol. Hereinafter, for brevity, it will be referred to as the “Company.”

This Privacy Policy describes the way we collect and process personal data received through the internet or by other means, and the Company’s privacy practices, which are committed to protecting and processing personal data lawfully in accordance with the EU General Data Protection Regulation 679/2016 (GDPR) and its applicable Laws.

The Company targets an adult audience. We do not collect personal information from anyone we know to be under 18 years of age without the prior verifiable consent of the parent or guardian. The parent or guardian has the right, upon request, to be informed of the information provided by the minor and/or to request its deletion. If we become aware that a person submitting personal data is under 18 years of age, we will delete it as soon as possible.

This Privacy Policy is incorporated into and subject to the “General Terms & Conditions” on the Company’s website. The Company conducts its activities through the website.

2. DEFINITIONS

Personal data is information that can be related to an individual – a natural person. Data is considered personal if the person it concerns can be identified.

Profiling is a collection of data that allows the assessment of an individual’s characteristics and therefore significant aspects of their personality.

The data subject is the natural person to whom the personal data relates.

Data processing is any activity that involves personal data, regardless of the means and process applied, e.g., collection, storage, use, review, disclosure, archiving, viewing, and destruction of personal data.

Transfer means access to personal data, for example by allowing access, transmission, or publication.

The data controller is the legal entity that decides the purpose, content, and process of personal data processing.

The data processor is a natural or legal person who processes personal data according to the instructions of the data controller.

3. PURPOSE OF PROCESSING

Personal data is processed only for the purpose indicated at the time of collection or for the purpose provided by law. The information we collect, personal data, helps us to create or improve our relationship with you and to continually personalize and improve your experience with our Company.

The processing of personal data is done lawfully and in good faith, and the data collected or stored is necessary to fulfill the purpose of its processing, which the Company ensures is lawful and consistent with the purpose for which it was collected.

4. TYPES OF PERSONAL DATA COLLECTED AND METHODS OF COLLECTION

WHAT PERSONAL DATA WE COLLECT

The types of personal data that may be collected include your full name, email address, billing information, mobile phone number, and similar data as may be requested from time to time.

We collect your personal data either because you provide it to us or through automated means. Specifically:

A. INFORMATION YOU PROVIDE TO US

We collect personal data from you when you voluntarily submit information to us, specifically when:

• You register on our website to receive mobile entertainment content, such as astrological forecasts, alert tones, games, photos, news, and other items.
• You participate in activities such as competitions, games, surveys, forums.
• You submit opinions, ideas, or suggestions to us or through our conversations.
• Reliable third parties we collaborate with transfer your data to us to achieve the purpose for which you submitted your personal data, as well as from public databases.

B. INFORMATION WE COLLECT AUTOMATICALLY – COOKIES

Cookies are information that is automatically placed in a predefined folder on your computer each time you visit certain websites. Cookies help to uniquely identify your computer on the server. They allow us to collect information related to the server to help you navigate the internet better and to analyze the website and check its operation. The Company uses cookies to recognize your web browser, determine if you have installed the necessary software for access to specific material on our internet sites, determine the total number of visitors, and recognize you when you return to the Company’s website. Information about your activities on our website and other non-personal data may also be used to limit the online advertisements you encounter to those we believe align with your interests. Cookies can store your password for easy access to a previously visited site or can store your preferences to guide you to a customized website.

Cookies and other identification tools do not automatically collect identifiable information about you. Only if you voluntarily submit identifiable information, such as a registration request or email submission, will automatic means be used to provide further information about your use of the websites and/or interactive electronic messages with the ultimate goal of increasing their usefulness to you.

Most browsers are set to accept cookies, but you can set your browser to refuse them or to notify you each time a cookie is received. Note that some parts of our website may not function properly if you reject cookies, preventing access to certain features.

Third-party advertisements may appear on the Company’s website, which may also contain cookies set by the advertiser or the advertiser, which our Company does not control. Therefore, you should check the privacy policy of the advertiser or advertiser to determine if they use cookies and how.

We may use cookies and similar tools to associate your website usage with personal data received from you or a trusted third party. For example, if you have asked us to send you information about future products or promotions, cookies and/or web browsing history related to your activities on our website may allow us to limit the material we provide to what we think you will find interesting, based on your previous online activities and preferences. However, if the Company wishes to combine your personal data and cookies or web browsing history in this way, we will obtain your explicit consent.

Additionally, the technical services and other services of the Company or our partners may automatically collect information about visitors to the Company’s website for maintenance, improvement, security, and other legitimate reasons. Such information may include visitors’ IP addresses, browser type, date, time, and duration of the visit, and specific pages visited.

5. COMPANY PRACTICES REGARDING THE COLLECTION OF PERSONAL DATA AND PROVIDING INFORMATION TO THE SUBJECTS

The Company ensures that when you provide your personal data, you are informed about who collects the information, how and why it is collected, and the type of use of that information by the Company. When you provide your personal data, the Company will notify you of your choices regarding the use of your personal data, including possible sharing with third-party companies.

This Policy describes the types of other companies that may want to send you information about their products and services and, therefore, want to share your personal data, provided you have given the Company your explicit consent to do so.

In cases where personal data is collected manually or in a non-online manner, such as via a postcard or subscription form, detailed notification is not feasible, and in order for the Company to obtain the explicit consent of the subjects, a brief notification is sent describing how to receive the full text of this Policy and other relevant information from us.

The Company’s website may contain links leading to other companies’ websites. Some of these third-party sites may carry the Company’s logo even if we do not manage or depend on them.

The Company’s website may also display advertisements from other companies. The Company is not responsible for the practices of third parties or third-party privacy policies or local online advertising companies to whose website you may be transferred through a link appearing on the Company’s website. When you leave the Company’s site via such a link or by clicking on an advertisement, you should check the applicable privacy policy of the third party or advertiser site to determine how they will handle any personal data they collect from you.

The Company’s website may also link to sites operated by companies related to the Company, such as companies that are members of the Company’s Group. Although Group members adhere to Group rules, data subjects visiting these related sites should refer to their separate privacy policies and practices, which may differ in some respects from this Policy.

6. USE/PROCESSING OF PERSONAL DATA BY THE COMPANY AND TRANSFER TO THIRD PARTIES

The Company will use the personal data you provide in a manner consistent with this Policy and only for the purposes for which it was submitted and will not transfer it to unrelated third parties unless it receives your explicit consent. If the Company receives personal data from a third party, such as a partner, the Company’s use of the information will be governed by this Policy.

The Company may use the personal data you provided during your registration to send you important information and updates about your account and the services you requested the Company to provide. Additionally, when the Company collects personal data from the subject when submitting a request for files and services from the Company, the Company will process the subscription or service request to the subject, including processing order fulfillment and payment, if applicable. In these cases, the Company will not share the information with third parties, except those the Company uses to perform tasks (such as order fulfillment and payment processing), necessary to complete purchases made by the data subject and subscriptions requested via https://mediapayplus.com/.

A third party, processing on behalf of the Company, such as a contractor or service provider, must contractually agree to process personal data in accordance with this policy. The terms of this policy are included in the relevant contracts.

Personal data is disclosed to third parties only if necessary or if the subject gives explicit consent. Personal data must be provided anonymously, if deemed appropriate.

The Company may also use personal data in aggregate, anonymously, for research purposes.

Additionally, a partner company may offer data and file downloads to subjects on behalf of the Company, collecting personal data on behalf of the Company when subjects register at https://mediapayplus.com/ or connect for individual file and service downloads via their mobile phone. The partner company provides us with the personal data needed to offer you information and file downloads and other services you requested. The partner company also provides your mobile carrier with the information needed to charge you for information and file downloads and other services purchased.

The Company may share the personal data you provided to https://mediapayplus.com/ with third parties:

• To fulfill your request for our services, files, and content.
• To request you to participate in surveys related to services offered by the Company.
• If you have given your explicit consent.
• If the Company is legally required to provide the data (e.g., by a court order or other government authority).
• If you have requested the Company to share your personal data with a third party, the Company may provide your personal data to them.
• If the Company reasonably believes that use or disclosure is necessary to protect its rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Third-party processing is not authorized to use your personal data for any purpose other than providing the requested services.

The Company may also transfer your personal data to an affiliated company or successor company in the event of a sale, merger, or consolidation of the Company. If such a transfer occurs, the transferee company will continue to comply with this Policy with respect to the personal data of subjects.

7. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS

The transfer of personal data to third countries or international organizations is done only if the European Commission has issued a decision stating that these countries ensure an adequate level of protection or if appropriate safeguards are provided, or if there are binding corporate rules, or the data subject has given explicit consent or if the transfer is necessary for the execution of a contract between the subject and the controller or for the execution of pre-contractual measures upon the request of the subject.

8. SECURITY OF PERSONAL DATA

The Company implements technical and organizational measures to ensure the security of personal data. All company personnel are trained and obligated to protect personal data, and data protection officers are designated within the Company. Physical access control and security systems are in place to protect the infrastructure, data centers, and other company assets. Also, technical systems include, but are not limited to, encryption, data pseudonymization, and de-identification.

9. RIGHTS OF DATA SUBJECTS

Data subjects have the right to access, correct, delete, restrict, and object to the processing of their personal data. They also have the right to data portability and the right to withdraw their consent at any time. Requests regarding personal data can be submitted to the Company in writing or via email. The Company will respond to requests within the prescribed time limits.

Data subjects also have the right to file a complaint with a supervisory authority if they believe their rights are being violated.

10. DATA STORAGE AND RETENTION

Personal data is stored for as long as necessary to fulfill the purpose for which it was collected and as long as required by law. The specifics of data storage and retention periods are determined by the Company’s Data Retention Policy.

11. SECURITY

The Company takes all appropriate measures recommended by modern technology, as well as organizational and physical measures, to safeguard the personal data in its possession against loss, theft, and unauthorized use, disclosure, or modification. These measures aim to ensure the integrity, confidentiality, and availability of the data. Additionally, the Company uses reasonable methods to ensure that personal data is accurate, up-to-date, and appropriately complete.

12. RIGHTS OF DATA SUBJECTS

Every data subject has the following rights according to the GDPR, which the Company respects and protects:

a) The right to be informed,

b) The right of access,

c) The right to rectification,

d) The right to erasure,

e) The right to restrict processing,

f) The right to data portability,

g) The right to object,

h) Rights related to automated decision-making and profiling.

If you request the Company to cease using your personal data, the Company will comply with this request, retaining only the information necessary for compliance with applicable national legislation.

You can contact the Company to exercise your rights, and the Company will respond within a reasonable timeframe, not exceeding 30 days.

13. MODIFICATION OF THE PRIVACY POLICY TERMS

The above terms constitute the entire agreement with the Company, which reserves the right to modify, renew, or delete all terms herein without any notice. Modifications or renewals will be effective from the moment this document is updated to reflect any changes. Therefore, you should review it regularly to stay informed about the latest policies and practices of the Company. If the Company substantially changes its practices regarding the collection or use of your personal data, your personal data will continue to be governed by the Policy under which it was collected unless you are notified and do not object to the change.

14. CONTACT METHODS FOR RESOLVING PERSONAL DATA PROTECTION ISSUES AND EXERCISING DATA SUBJECTS’ RIGHTS

To exercise your rights, resolve privacy issues, address matters related to the collection and processing of your personal data by the Company, review, correct, or delete your personal data, or to stop any future communication with us, you can contact the Company via email at info@mediapayplus.com, customer service phone number: 2107783277, or by sending a letter to the Company’s headquarters located at 161 Arch. Makarios III, 3027, Limassol, Cyprus.