Cytaka Privacy Policy
Last Revised: August 26, 2021
Globus Research and Development Ltd. and its affiliates d/b/a Cytaka (“Cytaka”, “we”, “our” or “us”) respects the privacy of the users (“User(s)” or “you”) of our website at: https://cytaka.com/ (and its subdomains) (the “Site”), and the "CyTaka" mobile application (the “App”). We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Site and/or App. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use available at: [insert link], into which this Privacy Policy is incorporated by reference (the “Terms”).
1.Your acknowledgment of this policy
This Privacy Policy (“Privacy Policy”) details how your Personal Information collected via the Site and/or App is used and processed by Cytaka.
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR APP, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED) TO THIS PRIVACY POLICY AND CYTAKA’S PRACTICES DESCRIBED THEREIN, INCLUDING THE PROCESSING (INCLUDING COLLECTING, USING, DISCLOSING, RETAINING OR DISPOSING) OF YOUR INFORMATION UNDER THE TERMS OF THIS POLICY. FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.
2.Who we are
In this policy, references to Cytaka, or to "we" or "us" are to Globus Research and Development Ltd. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at info@cytaka.com.
3.Which information we may collect on our Users?
We may collect two types of data and information from our Users:
3.1.Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).
Like most online services, when you access and use the Site and/or App we passively collect certain Non-Personal Information from your devices (depending on whether you access our Site or App), including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site or App, the activities of the User on the App and/or Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may use third-party service providers to obtain detailed analytics on the device and the User's behavior on the Site and/or App. Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain tracking technologies, such as cookies, as further detailed below.
3.2.Personal Information. The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.
Personal Information which is provided voluntarily:
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Communications: Personal Information is collected from the details that Users may provide as part of any communications with Cytaka, by any means, including by e-mail, telephone, social media or otherwise. Such Personal Information may include your name and contact details and any other information which you may voluntarily provide to us.
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Mailing list: You may voluntarily provide us with your contact details in order to subscribe to our newsletter and to receive commercial materials from Cytaka and our partners.
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Registration to the App: Personal Information is collected from the details the Users provide in the registration form available on the App (which enables the Users to open an Account), which includes, inter alia, name (including username), email and profile photo. Additional information may be requested in the future.
Important note: Users’ names and nicknames may be made publicly available via the App, including to other Users. Please act with caution when selecting your nickname.
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User Content: Personal Information includes any data and/or content, including User Generated Content, that you may upload or generate through use of the App, including without limitation comments, information derived from your interactions with other Users, your achievements in the App, in-App purchase, your ranking, Stars and Points obtained, etc.
Please note: if the Personal Information you provide us includes information about others, you are fully and solely responsible for providing all necessary information notices to affected data subjects and obtaining the required consents under applicable privacy law from data subjects for the use, processing, sub-processing and storing of their information in accordance with these Terms.
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Competitions: if you are eligible to participate in our Competitions (as described in the Terms), we will collect any information that is relevant to your participation in the Competitions, including without limitation your contact details, accommodation and travel arrangements, photos, your achievements in the competition, any award or prize that you may have received in the Competition, and any other relevant information. Please note that your name, photos and achievements may be made publicly available and used for Cytaka’s marketing purposes.
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Contact Us: we collect any information that you may provide via the “Contact Form” on our Site and/or App.
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Payments: payments for our Services, including collection of awards and prizes and conversion of CT to currency via the App and/or Site, use certain Online Payment Processors which will require you to fill out a billing form wherein you will be required to provide to such Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information). We will not store such information on our servers. We only keep token information that such Online Payment Processors provide us with and we will keep such information strictly secured.
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CT Conversion: when converting CT (as detailed in our Terms), we may require any information we deem reasonably necessary to effectuate the transaction, including you photo, contact details, links to social media pages, etc.
Personal Information is collected also via technology:
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IP/MAC Address: users of the App and Site may automatically provide their IP address (or Mac Address, as applicable) and/or advertiser identifier (when available on a device) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.
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Geolocation data: while using the Site and/or the App we will access, collect, process, monitor and/or remotely store “geolocation data”, including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes.
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Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 3.1 will be linked to or associated with a specific individual, then such information will be considered as Personal Information.
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Identifiers: we process certain online identifiers, such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or another unique identifiers, for geo-location, targeted advertising and security purposes. In addition, when using the Site and/or the App, our authorized third-party service providers may collect your advertising identifiers, as further detailed below.
Please note that we use third-party tracking services and usage logs, to track and analyze data from Users of the Site and/or the App for purposes of security and fraud prevention. We may also use cookies to gather information regarding your use of the Site and/or the App and the information for which you searched and accessed.
4.How Do We Collect Information on our Users?
There are a few methods that we use:
(a)We collect information through your entry and use of the Site and/or the App. In other words, when you are using our Site and/or our App and/or our Services, we are aware of it and may gather, collect and store the information relating to such usage (such as the Non-personal Information detailed above and your IP address), either independently or through the help of our authorized third-party service providers as detailed below.
(b)We collect information which you decide to provide us voluntarily. For example, we collect Personal Information when you register for a user account and when you contact us via our e-mail address.
We may gather, collect and store such information either independently or through the help of our authorized third-party service providers, as detailed below.
5.What are the Purposes of the Collection of Information?
(a)Non-personal Information is collected and processed by us in order to:
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Use it for statistical, analytical and research purposes and for customization, developing and improvement of the Site and/or App.
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Enhance the User's experience while using the Services.
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Keep the Site and/or the App safe and secured and for prevention of fraud.
(b)Personal Information is collected and processed by us in order to:
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Enable the provision of our Services.
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Respond to your inquiries, requests, comments and suggestions.
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Provide support and technical assistance.
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Display ads and send you offers. We may also use your Personal Information in delivering third party advertisements to you. This may include "targeted ads" on third party platforms and across devices, based upon your interactions with our Site and App.
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Send you by email, SMS, phone, through App notification or through the post updates, notices, announcements, and additional information related to Cytaka including with respect to changes made to our Terms and updated information regarding our Services.
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To conduct online surveys to better understand your needs, and how we can modernize, innovate and improve our Services.
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Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes.
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Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
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Keep the Site safe and secured and for prevention of fraud and crime.
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Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve our services.
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Maintain our data processing records and general administrative purposes.
Note to our Users in the EU:
In order for Cytaka to process your Personal Information, as detailed herein, such processing must be justified by a "basis" for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:
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the processing is based on your consent - where you provide us with your consent to contact you for marketing purposes, you will be asked to consent to such activities before we can process such information. If you choose not to give us your consent for such processing activities, or if you decide later to remove your consent, this may affect our ability to provide you with Cytaka's marketing materials;
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the processing is necessary for performance of a contract - generally your Personal Information will be provided to us because you are interested in using the App in accordance with the Terms or in order to receive certain services from Cytaka or in order to participate in a Competition in accordance with the terms of each Competition. As such, we rely on this basis for processing activities that are required in order to enable you to use the App, to provide our Services (including Competitions and currency conversions) and to let you know of changes to our App' terms of use and privacy policy;
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the processing is necessary to comply with a legal obligation - we may process your Personal Information for disclosure of information to authorities and to apply with our legal obligations (e.g., paying taxes); and
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the processing is in our legitimate commercial interests - subject to your interests and fundamental rights, under our legitimate interest in marketing our products and services via the App and offering the public comfortable and safe access to our App, we shall perform the Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the App, assisting us to prevent crime and fraud, manage our internal operations and marketing. Where we rely on legitimate interests as a lawful basis, we carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
Note to non-EU Users:
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR APP, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.
6.Sharing Information with Third Parties
Cytaka respects its Users’ privacy and will not disclose, share, rent, or sell their Personal Information to any third-party, other than as permitted under this Policy. Notwithstanding, the Company may share Personal Information in the following cases:
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Cytaka’s Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of Cytaka for the sole purpose of enabling the provision of our Services and to contact you. Please note that all of Cytaka’s personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
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Service Providers: We may share Personal Information with commercial software providers, consultants and data processors who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and host services.
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In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User's support requests; (e) to respond to claims that any content available on the Site and/or App violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of the Company, its Users, or the general public; (h) when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (i) cooperate with third parties for legitimate business purposes, including without limitation, enhancing the User's experience; and/or (l) pursuant to your explicit approval prior to the disclosure.
For avoidance of doubt, Cytaka may use Non-personal Information and transfer and disclose it to third parties at its discretion.
7.Data subjects’ rights
The Company acknowledges you may have the right under applicable law to access, change and delete the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: info@Cytaka.com and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:
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Right to access: you may have the right to request a review of your Personal Information held by Cytaka. We may refuse to comply with your access request if the request is manifestly unfounded, excessive or repetitive in nature.
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Right to rectification: if the Personal Information processed by Cytaka is incorrect, incomplete or not processed in compliance with applicable law or this Privacy Policy, you may have the right to have your Personal Information rectified.
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Right to erasure: under certain conditions, you may be entitled to require that Cytaka will delete or "block" your Personal Information (e.g. if the continued processing of those data is not justified).
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Right to portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity). The right to data portability only applies where your Personal Information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
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Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either "public interest" or "legitimate interests", those lawful bases are not absolute, and you may have a right to object to such processing. Where you object on grounds of legitimate interest, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
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The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
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Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
To exercise these rights, where applicable, please contact us by sending an email to: info@Cytaka.com
8.Location of your data
The information collected from you, as detailed in this Privacy Policy, may be transferred to, processed and stored by the Company and/or its service providers on servers and by staff which may be located in countries outside of your jurisdiction, including without limitation in the European Union, in Israel and in the United States.
The Company is committed to protecting your Personal Information and will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Such steps include putting in place data transfer agreements or ensuring our third-party service providers comply with our data transfer protection measures.
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE APP AND/OR SITE, YOU ACKNOWLEDGE, AND CONSENT, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.
Note to our Users in the EU:
If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries.
In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:
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Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel; and
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Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information.
9.Minors
The use of our Services are intended for Users over the age of seventeen (17). Therefore, Cytaka does not intend and does not knowingly collect Personal Information from individuals under this age. We reserve the right to request proof of age at any stage so that we can verify that minors under this age are not using our Services.
10.Security
We take reasonable measures to maintain the security and integrity of your Personal Information and prevent unauthorized access to your Personal Information or use thereof through generally accepted industry standard technologies and internal procedures. Your Personal Information is hosted on third parties’ servers, which provide advanced strict security standards (both physical and logical). In the event of any breach of the security, confidentiality, or integrity of your Personal Information we will inform you of such breach as required by applicable law. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur. CYTAKA SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.
11.Third-Party Service Providers
While using our Services and in order to provide our Services, we may use third-party service providers, who may collect, store and/or process the information detailed herein. Such third-party service providers may include without limitation the following categories of service providers:
• [Please advise whether you may retain any personal data via service providers and if so, specify]
Please read the third-party service providers' terms of use and privacy policies to understand their privacy practices.
12.Cookies
When you access or use the Site and/or App, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, "Cookies") which may enable us, amongst others, to recognize your device from those of other Users of the Site and/or App, to improve the Site and/or App 's performance, to deliver a better and more personalized service according to our Users' individual interests and the device or browser used, to track Users' use of the Site and/or App, to gather information about the Users' approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our Site and/or App and to serve targeted advertisements.
Cookies may locally store certain Technical and Behavioral information and other Personal Information on your device and we and/or our authorized third party service providers may access such information for the purposes detailed under this Privacy Policy. We and/or our authorized third party service providers may use both session Cookies (which expire once you close the web-browser) and persistent Cookies (which stay on the User’s device until he/she deletes them).
Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a Cookie is stored on your device. However, if you block or erase Cookies, your experience of the App and/or Site may be limited.
For detailed instructions regarding the blocking of Cookies, please refer to your browser's 'help', 'tool' or 'edit' sections or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers: Chrome, Internet Explorer and Microsoft Edge, Mozilla Firefox and Safari.
It is possible to opt-out of having your browsing activity within the App and/or Site recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users' activities on the Site and/or App, including by use such services' persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.
You can opt out of receiving interest-based advertising on your device by visiting the following sites: www.aboutads.info/choices/, www.networkadvertising.org/choices/, choices.ghosteryenterprise.com/global-opt-out.html, and preferences-mgr.truste.com/. If you wish to opt out of receiving interest-based advertising on your mobile device, please see the advertising preferences information on support.apple.com for iOS devices or support.google.com for Android devices.
13.Links to Third-Party Websites
Certain links provided in the Site and App permit Users to leave our Site and App and enter non-Cytaka sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of Cytaka and it is not responsible for the availability of such external sites or services, and does not endorse and is not responsible or liable for any content advertising, products, services or other information on or available from such linked sites and services or any link contained in a linked site or service. Cytaka reserves the right to terminate any link at any time. You further acknowledge and agree that Cytaka shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such linked sites or resource. Most of such linked sites and services provide legal documents, including terms of use and privacy policies, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.
14.Direct Marketing
You hereby agree that we may use your contact details you provided us with (including, without limitation, e-mail address and phone number) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future products and services. You may withdraw your consent by sending a written notice the following email address: info@cytaka.com or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.
15.Data Retention
The Company will retain the Personal Information for as long as your Account to use App is active and for a period of 7 years thereafter, for archiving purposes, to defend against potential legal claims and to comply with our legal obligations. Personal Information collected via the Site, shall be retained for as long as it is relevant and accurate. Personal Information which is no longer required for the purpose for which it was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.
16.Payments
We accept certain online payment methods, using our Online Payment Processors, which enable Users to send and receive payments securely online using a credit card or bank account. We may add or change the Online Payment Processors at our sole discretion. Cytaka is not affiliated with such Online Payment Processors (for more information see our Terms), as each is an independent contractor, and neither is the agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Online Payment Processors is at the User's discretion and sole liability and risk. It is the User's responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.
17.Changes to the Privacy Policy
The terms of this Privacy Policy will govern the use of the Site, the App and any information collected therein and/or provided to us voluntarily. Cytaka may, at its sole discretion, change this Privacy Policy from time to time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the Site and/or the App and/or will send you an e-mail (to the extent that you provided us with such e-mail address) regarding such change. Such material changes will take effect seven (7) days after such notice was provided on the Site and/or the App or sent via e-mail, whichever is the earlier. Otherwise, all other Changes to these Terms are effective as of the stated “Last Revised” and your continued use of the Site and/or the App on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.
18.Got any Questions?
If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: info@cytaka.com.
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