Privacy Policy

Privacy Policy
Last updated: June 09, 2023

INTRODUCTION
The Company (hereinafter "We" or "the Company") has developed this Policy (hereinafter "Policy") in order to establish a set of measures aimed at better combating violations, combating money laundering and ensuring the processing of your personal data.
In doing so, we recognize and greatly respect your privacy rights, and we provide this policy (“Privacy Policy“) to make you aware of how we collect and use information from you pertaining to your use of https://1mlndrops.com/ (our “Website“) as well as the products or services that you access through the Website (our “Products“). We also explain in this Privacy Policy certain rights that you have in respect of your Personal Information (as defined herein). We will not use or share your information with anyone except as described in this Privacy Policy.
Our online properties may include links to websites and online services that are operated by other companies not under the control or direction of Us. If you provide or submit personal information to those websites or online services, the privacy policies on those websites or online services apply to your personal information.
We are committed to helping you embed privacy into your strategy and operations by providing simple, scalable and intelligent solutions that help our clients continuously manage privacy compliance and risk.
The Policy includes identification of Clients, verification and monitoring requirements, guidance on screening process (including the requirement to establish the identity of beneficial owners), the reporting of suspicious circumstances in accordance with relevant laws.
Please read this Privacy Policy carefully to understand our practices in relation to Personal Information (as deEned herein). This Privacy Policy provides you with information about:

● Information collected and how it is used
● Direct marketing and how you can manage your preferences
● Cookies, sites and third party services
● How we use Personal Information
● The legal basis for using your Personal Information
● Transfers of Personal Information
● How we protect and store your information
● Your rights
● How to contact us

PRINCIPLES OF THE POLICY
The Policy shall be drafted, interpreted, complied with and executed subject to the following principles:
Proportionality Principle. Any measure by the Company, the Company Parties and/or its authorized officials that affects any existing or potential Client is to be appropriate in order to achieve the objective, intended, i.e. there are no less severe means of achieving the objective, and reasonable, i.e. the Client concerned can reasonably be expected to accept the measure in question.
Non-discrimination and Equality Principle. The same approach shall be implemented to all existing or potential Clients, regardless of race, nationality, religion, social status, ownership of a legal entity, citizenship of an individual, place of origin of capital, without prejudice to the restrictions contained herein and in other documentation of the Company and/or the Company Parties (i.e. Terms of Use of Website, Privacy Policy, etc.) and those prescribed by pertinent legislation and international standards.
Neutrality Principle. Development and realization of the Policy in a manner that does not affect the increase or decrease of existing or potential Clients competitiveness.
On-going Enhancement Principle. Constant monitoring, current screening of existing Clients which have already established the Business Relationship with the Company, and regular update of the Policy in order to keep up with legislation developments and local and global best practices must be implemented and maintained.
Supremacy of Law Principle. The Policy shall be developed and executed in compliance with and governed by local and international legal standards, and all the interpretations and applications hereof shall be enforced due to the letter and spirit of the law.
Timely Risk Management Principle. On-going control measures must be implemented and maintained for the purposes of tracking and exposure of all and any breaches, violations, misuses and other acts of malicious interference committed by the Clients by making operations and transactions by means of the Company Parties' Infrastructure, as well as for the purposes of prevention thereof. This principle also implies establishment of measures to react urgently and in due course where any concerns, doubts or suspicions as to the nature and intent of the operations and transactions performed as well as to the identity of the Client arise.

BASIC POLICY INFORMATION
This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated in the “Last updated:” date at the bottom of the policy. If there will be any significant changes made to the use of your Personal Information (as defined herein) in a manner different from that stated at the time of collection, we will endeavor to notify you by posting a notice on our Website.
There may also be external links to third party websites and services on our Website. This Privacy Policy does not apply to your use of a third party site or service. To End out more about external links, including any Personal Information (as defined herein) that may be collected by third parties.

§2. Personal Information

We collect information that identifies an individual or may with reasonable effort allow the identification of an individual, or may be sensitive in nature (“Personal Information“) when you:
register with or use our Website or one of our Products;
use our free tools either to try our Products or consult with a member of our sales team;
commence direct communications with us either in relation to a query or complaint;
We will ask you to provide certain Personal Information if you choose to create a account or use our services. This may include your name, personal and work email, work or home address, employer, payment information, and phone number. We collect this information, only if voluntarily provided by you, in order to create and authenticate your account and provide you access to our Products and services. Where you try to consult with a member of our sales team, we will also collect Personal Information that you voluntarily provide about your work and your company.
We also collect Personal Information when you commence direct communications via our Website enquiry form, by telephone or writing to us. When you commence direct communications with us, we may retain such communications and the accompanying Personal Information in order to process your inquiries, respond to your requests and improve our services.

§3. Web Server Information

Like most website operators, we also collect web server log information of the sort that web browsers and servers typically make available (“Web Server Information”). This Web Server Information includes non-personally-identifying information such as browser type, language preference, and the date and time of each visitor request, as well as potentially personally identifying information like Internet Protocol (IP) addresses. In either case, we do not use such Web Server Information to identify visitors to our Website, and we do not disclose any Personal Information included in such Web Server Information to third parties, other than under the specific circumstances described below in this Privacy Policy where Personal Information may be disclosed. Our purpose in collecting this Web Server Information is to better understand how our visitors use the Website in order to improve the Website and our Products.
We may use your Personal Information, voluntarily provided by you in the circumstances described herein, to let you know about our Products and services that we believe will be of interest to you. In all cases, we will respect your preferences for how you would like us to manage such marketing activity with you:

we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
you can ask us to stop direct marketing at any time – you can ask us to stop sending email marketing, by following the ‘unsubscribe’ link you will End on all the email marketing messages we send you. Alternatively, you can contact us at e-mail. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g., email);
you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below in the “Cookies, Sites and Third Party Services” section.

We recommend you routinely review the privacy policies and preference settings that are available to you on any social media platforms you use.

COOKIES, SITES, AND THIRD PARTY SERVICES

§1. Use of Cookies, Web Beacons, Pixels and other Technologies

Our Website uses certain monitoring and tracking technologies (such as cookies, web beacons and pixels).

A cookie is a small text file that is stored in a web browser directory by a website or an advertisement related action. Our Website uses two types of cookies: session cookies and persistent cookies. Session cookies are created temporarily in your web browser directory while you are visiting a website and are deleted once you leave the website. Persistent cookies remain in your web browser and are activated again once you visit the website that created that specific cookie. A web beacon is a small file used by a website or an advertisement-related action to keep track of your navigation through a single website or a series of websites. A pixel is a small line of code which is used by a website or an advertisement-related action to assign online activities to a computer or browser.

We use these technologies in order to ensure proper operation of our Products and Website, collect information and ensure information security. Although our collection of such information is not used to personally identify users, we are still committed to giving you the opportunity to exercise your choice of opting out from our collection of such information. For removing cookies and other technologies used on our Website, please refer to the “Opt-Out Option” sub-section below.
We will not use the above technologies to collect Personal Information without obtaining your permission, unless where we are permitted to do so under applicable privacy laws.

§2. Opt-Out Option

Please note that your browser enables you to disable all cookies (if you do not know how to do this, check out the “Help” file of your browser), however, this may interfere with your use of the Website or other internet websites.
In order to disable cookies or otherwise adjust your cookies preferences, please adjust the settings on your browser. Please note that if you disable certain cookies on your browser, some parts of our Services may not fully work or may otherwise be limited or affected.

If you use a new computer, upgrade or change web browsers or take any action which results in the deletion of the “opt out” cookie, you will need to perform this opt-out process again upon any such change.
§3. Third Party Websites and Services

Our Products may recommend third party websites which the Product determines may be of interest to you (“Sites“). Additionally, there may be links on our Website to third party websites and services such as Google Analytics, KeenIO, and others (“Third Party Services”). We do not have control over such Sites or Third Party Services, including their information collection and use practices. We are not responsible for their privacy practices or policies. We therefore recommend that you review the privacy policies of Sites and Third Party Services before providing them with your Personal Information.
We may use certain third-party service providers to monitor and analyze the use of our Website and/or Products.

§4. How We Use Personal Information

We will use Personal Information solely in order to provide you with our Products and services, process your inquiries, respond to your requests and improve our services.
We may share some or all of your Personal Information with our current or future subsidiaries, joint venture partners or other companies with whom we are under common control, provided such parties undertake to protect your privacy in at least the same manner as set out in this Privacy Policy.
In addition, we may share some or all of your Personal Information in the manner and for the purposes described below:

with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any Personal Information we share with them solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems;
with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order; and
we may collect and share Personal Information if required to do so as part of any legal proceedings conducted between you and the Company.

THE LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION
We will only collect, use and share your Personal Information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

you have provided your consent to us using the Personal Information (e.g. where you provide us with marketing consents or opt-in to optional additional services or functionality);
our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. providing you with our Products, and services, creating your user account);
our use of your Personal Information is in our legitimate interest as a commercial organisation, subject to your interests and fundamental rights. In these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in “your rights” section below;
our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have (e.g., the disclosure of information to law enforcement or tax authorities).

If you would like to End out more about the legal basis for which we process Personal Information, please contact us.
§2. Transfers Of Personal Information

Please be aware that your Personal Information may be transferred, stored and processed in countries outside your country of residence from which the information was collected, including the country where our servers and central database are located. This means that your personal information will be subject to different data protection standards than those applicable in your country of residence. We take the necessary steps to ensure that the transfer of personal information is carried out in accordance with the following provisions applicable laws and carefully managed to protect your privacy rights and interests.
HOW WE PROTECT AND STORE YOUR INFORMATION

§1. Security

We have implemented and maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. Note that, although we take measures to secure the information we collect and reduce the risk of unwanted disclosure, we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. However, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect your user IDs and passwords, please take appropriate measures to protect this information.
We will store your Personal Information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy Policy. In some circumstances we may store your Personal Information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.
In specific circumstances we may store your Personal Information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
USE BY CHILDREN
We do not offer our products or services for use by children. If you are under 18, you may not use the Website, our Products or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.
YOUR RIGHTS
You can change your personal information by editing your account information. You also have the right to ask us to change any personal information about you that is inaccurate or misleading by writing to our Data Protection Officer at our Company email address.
You have a right to access information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
You have a right to restrict the processing of your Personal Information, for example in case we no longer need your Personal Information for the initial purposes for which it was collected but it is required by you for the establishment, exercise or defense of legal claims.
You have a right to object to processing which has our legitimate interests as its lawful basis. We will no longer process your Personal Information upon your request, unless we have compelling legitimate grounds for the continuation of the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims. You may also object to our use of your Personal Information for direct marketing purposes.
You have a right to obtain a portable copy of Personal Information which is processed on the basis of your consent, or which is necessary for the performance of a contract between us. You have a right to have such portable copy of Personal Information transferred to another data controller in a structured, commonly used and machine-readable format.
You also have a right to request details of the basis on which your Personal Information is transferred but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
HOW TO CONTACT US
If you have any questions or comments regarding this Privacy Policy or our Terms of Service, please feel free to contact us by e-mail at info@1mlndrops.com.
We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place of work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority.