This policy outlines the practices with respect to the information collected from users who access the website https://tycoon.io/ (hereinafter referred to as the “Website”) which is owned and operated by Aconian Services Limited, a limited liability company incorporated in Cyprus under registration number HE417183 (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) and is responsible for the protection of the privacy and the safeguarding of both prospective and existing client’s (hereinafter referred to as the “client” and/or collectively as the “clients” or “visitors”) personal data. By accessing the Website, mobile applications, and other online products and registering with the Company, the client hereby gives his/her consent to such collection, processing, storage, and use of personal information by the Company as explained below.
The collection of personal information
The Company collects the necessary information required for the Company to identify, process, and execute its clients’ orders to enter into a contractual relationship with the Company as well as to satisfy its legal obligations along with its legitimate business purposes. The Company receive personal data from our payment partners where the client use their services to make payments to the Company.
To the fullest extent permitted under applicable Data Protection Laws, the Company collect Personal Data about clients/visitors and any other party when: Access or use our Services; Create an Account; Complete online forms, take part in surveys, post on any forums, download information or publications or participate in any other interactive areas that appear within our Services; Interact with the Company using social media; Provide contact details to the Company when registering to use or access any services the Company makes available, and Contact the Company or otherwise connect with the Company, online or offline.
If the client is mainly considered as a natural person, the Company is the personal data controller of the client’s personal data in relation to the processing activities which the client’s personal data undergo as stated further below.
The first type of information is un-identified and non-identifiable information pertaining to a client(s) (“Non-personal Information”), which may be made available or gathered via your use of the Website, even if the client does not participate or register to the Website. The Company may not be aware of the identity of the client from which the Non-personal Information was collected. The Non-personal Information which is being collected may include the aggregated usage information and technical information transmitted by the visitors’ devices, including certain software and hardware information (e.g. the type of browser and operating system the visitors’ devices utilise, language preference, access time, etc.) in order to enhance the functionality of the Website. The Company may also collect information regarding the visitors’ activities on the Website (e.g. pages viewed, online browsing, clicks, actions, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information includes:
- Registration information: When the client registers on the Website, he/she may be asked to provide certain details such as: full name, e-mail address, date of birth, physical address, telegram U-ID, and other information, relevant to the provision of the services and/or to satisfy the legal obligations of the Company.
- Device Information: The Company may also collect Personal Information from the clients. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and/or UUID) and other information which relates to your activity through the Website.
- Payment Information: In order to accept, return, process and/or handle payments and most importantly for anti-money laundering purposes, the client may be required to share personal information within the Website or with our trusted payment processor(s). Such personal information may include the client’s full name, residential/billing address, identity number, financial information (e.g. credit card number, bank account, etc.) and any other information that is required in order to perform the desired purchase.
Based on the aforementioned, the Company collects information which is required to communicate with and identify its clients. In addition, certain demographic information, including, birth date, education, occupation, etc. maybe also collected from the Company’s clients along with information related to their activities for the Company to be in a position to assess the related details which are deemed to be necessary. Examples may include:
- Information that includes personal information provided by the client in the Company’s forms or registration pages, such as the client’s name, address, date of birth, email address, telephone number or other similar data. This information is also used by the Company in order to communicate with the client.
- If required, certain identification/verification information that may consist of the client’s identity card, passport or driving license.
The use of personal information
The Company collects and uses information only for the purposes and the provision of its services and in order to fulfill its compliance and other obligations as per the relevant laws and regulations. In order for the Company to improve its services and inform its clients of any additional products and/or to further promote the Company’s activities, the said information is needed, and in this respect, the clients hereby consent to the usage of this data for such purposes.
In the case where the clients do not wish to receive information for any reason, they can contact the Company by sending an email to: [email protected]
User Rights (For EU Users)
You may request to:
- Receive confirmation as to whether or not personal information concerning the client is being processed, and access the client’s personal information stored, together with provided supplementary information.
- Receive a copy of personal information that the client directly volunteered to the Company in a structured and commonly used format.
- Request rectification of the client’s personal information that is processed by the Company.
- Request erasure of the client’s personal information.
- Object to the processing of personal information by the Company.
- Request to restrict processing of the client’s personal information by the Company.
- Lodge a complaint with the relevant public authority.
However, please note that these rights are not absolute, and may be subject to the Company’s own legitimate interests and regulatory requirements.
How to exercise the rights?
The client may communicate his/her queries regarding his/her personal data to the Company by providing the following details:
- Personal Details:
- Full Name;
- Full residential/billing address;
- Order number;
- Date of order/payment;
- Email address;
- Specific Details of the Request
Only applicable if the client wishes to be represented by a third party. It shall be noted that the client will be required to provide a notarized Power of Attorney authorizing the relevant third party to act on his/her behalf.
- Full name of the representative;
- Relationship with the representative;
- Representative’s legitimate mandate;
- Email address of the representative;
- Representative’s contact number.
Retention of personal data
The Company may retain your personal information for as long as necessary to provide the clients its services, and to comply with its legal obligations, resolve disputes, and to enforce its policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing the client’s personal data, registered documents, communications, and anything else as required by applicable laws and regulations.
The Company may rectify, replenish or remove incomplete or inaccurate information, at any time and at its own discretion.
Protection of personal information
The Company takes reasonable technical and organizational measures to prevent the loss, misuse or alteration of its clients’ personal information. The Company stores all the personal information which is provided by the clients on its secure (password- and firewall-protected) servers.
The clients are responsible for keeping the security details they use for accessing the Company’s services confidential; the Company will not ask the clients for their security details (except when they login to the Company’s Website).
The personal information which is provided by the clients to the Company is treated as confidential and shared only within the Company, its affiliates and service providers based on the service involved and are not disclosed to any third party except under any regulatory or legal proceedings. In case where such disclosure is required to be made by law or any regulatory authority, it will be made on a ‘need-to-know’ basis, unless otherwise instructed by the regulatory authority. In such cases, the Company shall duly inform the third party regarding the confidential nature of the information.
This website is hosted by an external service provider (hoster). Personal data collected on this website is stored on the servers of the hoster. This may include, but is not limited to, IP addresses, contact requests, meta data, communication data, contract information, contact information, names, website requests, and other data generated by a web site.
The use by the hoster serves the purpose of fulfilling the contract with our potential and existing customers (art. 6 para. 1 (b) GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (art. 6 para. 1 (f) GDPR).
Our hoster will only process your data to the extent necessary to fulfill their performance obligations and to follow our instructions with respect to such data.
Completion of a contract for order processing
In order to guarantee data protection compliant processing, we have concluded a data processing agreement (DPA) with our hoster.
Transfer of data outside the EEA
It is noted that some data recipients may be located outside the EEA. In such cases we will transfer the clients’ data only to such countries as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
The Company forbids users under the age of 18 to utilise its services. In the event that the Company becomes aware that a user under the age of 18 has shared any information, it will discard such information. If the Company has any reason to believe that a child under 18 has shared any information with it, please contact us at [email protected]
Affiliates and Partners
The Company may share information with affiliated entities in the event such information is reasonably required by such affiliated entity in order to provide the products or services to the clients. The Company may share information with partners, affiliated entities and associated units in order to offer additional similar products and services that meet the clients’ needs and which are delivered in a manner that is useful and relevant only where the clients have authorised the Company to do so.
Out of respect to the clients’ right to privacy, the Company provides the client within such marketing materials with means to decline receiving further marketing offers from the Company. If the client unsubscribes, the Company will remove its email address and/or telephone number from its marketing distribution lists.
It shall be noted that even if the client has unsubscribed from receiving marketing emails from the Company, the Company may send the client other types of important e-mail communications without offering the client the opportunity to opt out for receiving them. These may include customer service announcements or administrative notices.
Non-affiliated third parties
The Company reserves the right to disclose personal information to third parties where required by the applicable laws, regulations and/or by governmental authorities. The Company may also disclose information as necessary to credit reporting or collection agencies as reasonably required in order to provide the services/products to the Company and/or to its clients.
In addition, the Company may engage third parties to help carry out certain internal functions such as account processing, fulfilment, client service, client satisfaction surveys or other data collection activities relevant to its business. Use of the shared information is strictly limited to the performance of the above and is not permitted for any other purpose. All third parties with which the Company shares personal information are required to protect such personal information in accordance with all relevant legislation and in a manner similar to the way the Company protects the same. The Company will not share personal information with third parties which it considers will not provide its clients the required level of protection.
In cases where the clients have been introduced by another party or any other associated entity of the Company, such introducer and/or associated entity may have access to the clients’ information. Hence, the clients hereby consent to the sharing of information with such entities.
From time to time the Company may contact the clients by email for the purpose of offering them further information about the Company’s products. In addition, the Company may, on occasion, seek to contact the clients, whether by email, for the purpose of informing them of unique promotional offerings provided by the Company for the client. The clients consent to the receipt of such contact when they consent to the Company’s terms and conditions when engaging with the Company. Any person wishing to opt out from further contact with the Company at any time whatsoever is entitled to do so, simply by contacting the Company whether by email and requesting that no further contact on behalf of the Company should be made.
Restriction of responsibility
Use of “Cookies”
A cookie is a file containing an identifier that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that the Company stores about the client may be linked to the information stored in and obtained from cookies.
Cookies required to carry out the electronic communication process or to provide certain functions that you wish to use (e.g. shopping cart function) are stored on the basis of Art. 6 para. 1 (f) GDPR. The website operator has a legitimate interest in the storage of cookies for the purpose of technically correct and optimized provision of its services. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing will be carried out exclusively on the basis of art. 6 para. 1 (a) GDPR; such consent can be withdrawn at any time.
Analysis tools and advertising
We may share your Personal Data with: Third-Party Internet and Marketing Services Vendors including but not limited to Moosend, Facebook, Instagram, Twitter, Discord, Telegram, GoogleCloud, Google Analytics.
We use Google Analytics to collect and analyze information about how users interact with the Services. This includes information about your browsing and search history, as well as information about your device and internet connection. Google Analytics collects this information using cookies and similar technologies. You can learn more about how Google uses this information and how to opt out of tracking by Google Analytics by visiting the Google Analytics website.
To send marketing and promotional communications: We may use the information we collect to send you marketing and promotional communications about our products and services. We may also use remarketing services such as Google Ads (AdWords), Facebook, Instagram, and Twitter to show you advertisements on these platforms based on your interactions with the Services.
Plugins and Tools
YouTube with enhanced privacy
This website includes videos from YouTube. The operator of those sites is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
We use YouTube in enhanced privacy mode. This mode, according to YouTube, means that YouTube does not store information about visitors to this site until they play the video. However, sharing data with YouTube partners is not necessarily excluded by the enhanced privacy mode. Thus, regardless of whether you’re watching a video, YouTube connects to the Google DoubleClick network.
Once you start playing a YouTube video on this site, you will be connected to the servers of YouTube. It lets the YouTube server know which of our pages you’ve visited. If you’re logged in to your YouTube account, YouTube will be able to directly link your browsing behavior with your personal profile. You can prevent this by logging out of your YouTube account.
Furthermore, after launching a video, YouTube may store various cookies on your device. Using these cookies, YouTube can receive information about visitors to this website. This information is used, among other things, to capture video statistics, improve user-friendliness, and prevent fraud. The cookies remain on your device until you delete them.
It is possible that upon launching a YouTube video, other data processing operations may be triggered that we have no control over.
The use of YouTube is in the interest of an attractive presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 (f) GDPR. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing will be carried out exclusively on the basis of art. 6 para. 1 (a) GDPR; such consent can be withdrawn at any time.
We use Moosend (https://moosend.com) to send emails on our behalf.
We use “Google reCAPTCHA” (hereafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Use of reCAPTCHA allows us to check whether the data entered on this website (e.g. in a contact form) was provided by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For analysis, reCAPTCHA evaluates various types of information (e.g. IP address, website visitor’s time spent on the website or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.
The reCAPTCHA analyses take place completely in the background. Site visitors are not notified that an analysis is taking place.
The processing of this data is based on art. 6 para. 1 (f) GDPR. The website operator has a legitimate interest in protecting their websites from abusive automated spying and SPAM.