PRIVACY POLICY

Last update: July 1, 2024

RELIZ LTD (legal entity location address: 2 office 1, Trejqet Huggiega, Triq Victor Scerri, Naxxar, Nxr 1032, Malta) (“RiseUp” “us”, “we”, and “our”) understand that your privacy is important to you and are committed to being transparent about the technologies it uses. We are pleased to provide users with certain websites, software, applications, content, products, and services (collectively, “RiseUp Services”).

This Privacy Policy (“Policy”) describes how we collect and use the personal data you provide through the website via the link https://intimate.guru/ (hereinafter “Website”) and/or the mobile application (“Application”). It also describes the choices available to you regarding our use of your Personal Data and how you can access the information. We respect your privacy, and we take protecting it seriously.

PLEASE READ THIS POLICY CAREFULLY BEFORE PROVIDING ANY KIND OF YOUR PERSONAL DATA AND/OR USING RISEUP SERVICES. THIS POLICY GOVERNS THE PROCESSING OF YOUR PERSONAL DATA BY US IN GENERAL. BY CONSENTING AND PROVIDING US WITH YOUR PERSONAL DATA TO USE THE RISEUP SERVICES, YOU AGREE TO BE BOUND BY THIS POLICY.

This Policy should be read with our Terms of Service and Refund Policy as it constitutes an Entire Agreement between Reliz LTD and User.

TABLE OF CONTENTS

  1. General Information
  2. Terms and Definitions
  3. Data Controller
  4. Principles of Data Processing
  5. Types of Personal Data We Collect and Process
  6. Personal Data Collected in an Automated Way
  7. Lawful Basis of Data Processing
  8. The Purpose of Data Processing (Use of Collected Personal Data)
  9. Consent to Personal Data Processing
  10. Compliance with Data Protection Laws in Applicable Jurisdictions
  11. The Rights of Users
  12. Data Storing and Deletion
  13. Data Security
  14. Cookie Section
  15. Contractors
  16. Links to Third-Party Websites
  17. Information Relating to Children
  18. Application of this Policy
  19. Acceptance of this Policy
  20. Changes and Updates
  21. CONTACT US!

  1. GENERAL INFORMATION

  1. This Policy applies to the following people:
  1. people who use the Service (for this Policy, We define the term “User”, “you”, and "your" as a person who has access to the Service);
  2. people who make complaints to us by email.

  1. We do not sell your Personal Data to third parties. A “sale” of Personal Data under the CCPA is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal data of a Consumer to another business or third party “for monetary or other valuable consideration”. If we decide to sell the RiseUp Services, we will inform you about this, so you can forbid us to transfer your Personal Data together with our business. If so, we will delete your Data from the databases prior to a business transfer.

  1. TERMS AND DEFINITIONS

  1. The following terms shall have the following meaning:
  1. “RiseUP Service” or “RiseUp Services”— access to our website https://intimate.guru/ as well as to our application as Users’ subscription to and any Order of our services, products, applications, tools, offline components, and features, provided by our company Reliz LTD, together with its affiliates, officers, directors, employees, agents, and subsidiaries;
  2. “Application” — a mobile application, created by Reliz LTD and made available to the public for download from a third-party platform Google Play Market and Apple App Store;
  3. “User” — any person having an account allowing access to our RiseUp Services;
  4. “Website User” — any person visiting our Website.

  1. DATA CONTROLLER

  1. RELIZ LTD (legal entity location address: 2 office 1, Trejqet Huggiega, Triq Victor Scerri, Naxxar, Nxr 1032, Malta) is the data controller that is responsible for the personal data collected and used within the scope of this Policy.

  1. PRINCIPLES OF DATA PROCESSING

  1. According to Art. 5 of the EU General Data Protection Regulation (GDPR), we adhere to the following principles to protect your privacy:
  1. principle of lawfulness, fairness, and transparency — we process personal data lawfully, fairly, and transparently concerning the data subject;
  2. principle of purpose limitation — we collected personal data for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  3. principle of data minimization — we collect adequate personal data, relevant and limited to what is necessary concerning the purposes for which we process personal data;
  4. principle of data accuracy — we have accurate personal data and, where necessary, keep it up to date. We take every reasonable step to ensure that inaccurate personal data, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. principle of storage limitation — we keep personal data in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
  6. principle of integrity and confidentiality — we process personal data to ensure appropriate security of the personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical or organizational measures.

  1. TYPES OF PERSONAL DATA WE COLLECT AND PROCESS

  1. To fulfill our obligations on the provision of a license for RiseUp Services for you and applicable Terms of Service, we are entitled to ask you to provide us with your Personal Data, including (but not limited):
  1. First and Last names;
  2. Email address;
  3. Age range;
  4. Marital status.

  1. We may collect Personal Data from you in a variety of ways and circumstances, including, but not limited to, access to the RiseUp Services, a subscription to a newsletter, filling out a form, and providing us with feedback. We shall be entitled to combine Personal Data collected in the course of your interaction with different sections of the RiseUp Services with any other relevant available information.

  1. PERSONAL DATA, COLLECTED IN AN AUTOMATIC WAY

  1. We may also automatically collect data about the devices you use to interact with our RiseUp Services. Personal Data automatically collected by or transmitted to us in the course of accessing, interacting, and operating the RiseUp Services may include, without limitation, the following Personal Data:
  1. device information, which may include (but is not limited to) information about the personal computer or laptop you use to access the RiseUp Services including the hardware model, operating system and version, the RiseUp Service you use, and other device identifiers;
  2. server log information, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at the RiseUp Service;
  3. information collected by cookies and other similar technologies. We and our service providers use various technologies to collect information when you interact with RiseUp, including cookies and other similar technologies. Cookies are small data files stored on your device when you visit a Website, enabling us to collect information about your device identifiers, IP address, web browsers used to visit the Website, pages or features viewed, time spent on the Website, and links clicked. Where required, you will be asked for consent to our use of cookies. Please review our separate Cookie Section in this Policy to view more information on what cookies we use and how we use them.

  1. LAWFUL BASIS OF DATA PROCESSING

  1. Under Art. 6 of the GDPR, we only process personal data, where we have a lawful basis for doing so.
  2. The processing of Personal Data, described in p. 5.1 of this Policy is based on consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Policy — to personalize your experience with our RiseUp Services and to meet your request concerning the RiseUp Services.
  3. The processing of Personal Data, described in p. 5.2 of this Policy is based on consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Policy — to personalize your experience with RiseUp Services and for marketing and promotion of RiseUp Services or related products, including those of a third party’s products which are related to RiseUp Services.
  4. The processing of Personal Data, described in p. 6.1.1 and 6.1.2 of this Policy is based on a legitimate interest (Art. 6 (1) lit. (f) GDPR) and is performed only for the purposes specified in this Policy — To contact you about, and conduct, surveys or polls you choose to take part in and to analyze the data collected for market research purposes.
  5. The processing of Personal Data, described in p. 6.1.3 of this Policy is based on consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Policy —to provide a greater and better experience with us and other related purposes, which is described in detail in the Cookie Section in this Policy.

  1. THE PURPOSE OF DATA PROCESSING (USE OF COLLECTED PERSONAL DATA)

  1. We may use the data, collected from you for a variety of purposes, primarily, relating to providing RiseUp Services and information about RiseUp Services. We may also use the information for such other purposes as otherwise allowed by law. We may use your personal data for such purposes, including, but not limited to:
  1. Provide license and access to RiseUp Services;
  2. Complying with or fulfilling the reasons Users have given for providing data to the Reliz LTD;
  3. Providing support and assistance for the RiseUp Services;
  4. Improving the RiseUp Services, including testing, research, internal analytics and product development;
  5. Personalizing the RiseUp Services, website content, and messages based on Users' preferences;
  6. Fraud protection activities, providing security and bug fixes;
  7. Creating and managing User accounts or other User profiles;
  8. Displaying advertisements to Users;
  9. Respond to User correspondence, contact Users when necessary or requested, and send Users information about the Reliz LTD or RiseUp Services.
  10. Send emails and other communications according to User preferences or display content that you think Users will be interested in;
  11. Fulfilling Reliz LTD's legal obligations under applicable law, regulation, court order, or other legal processes, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities;
  12. Protecting the property rights of Users, Reliz LTD, or another party.
  13. Enforcing any agreements with Users;
  14. Responding to claims that any publication or other content violates the rights of third parties;
  15. information security obligations;
  16. tracking purchases and usage data;
  17. any other purpose as we determine, in our sole discretion, to be necessary or required to ensure the safety and/or integrity of our Users, employees, third parties, public, and/or RiseUp Services, or to comply with requirements of any applicable law.

  1. CONSENT TO PERSONAL DATA PROCESSING

  1. Consent to Personal Data Processing
  1. By accepting this Policy, you approve to have reached the age of majority or the legal age in your jurisdiction (generally 18 or older), and are solely responsible for all your actions, and fully understand the statements, outlined in this Policy.
  1. EU Persons Consent to Personal Data Processing
  1. If you are an EU Person and to process your Personal Data we need to receive your consent, as prescribed by GDPR, we will process your Personal Data only in the case we have received from you a freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data (“Consent”).
  2. You may consent by ticking the respective box when you register for an account with RiseUp Service or by filling out and proceeding with the form on our Website. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that we shall be entitled to process your Personal Data as indicated by your Consent.
  3. Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, your Consent should be deemed given for all of them.

  1. Non-EU Persons Consent to Personal Data Processing
  1. If you are not an EU Person, by transferring to us your Personal Data via the RiseUp Service, you irrevocably and unconditionally consent and agree that we shall be entitled, in accordance with this Policy:
  1. to process in any manner, including to collect, store, use, disclose, share, and transfer (including cross-border), your Personal Data so provided to Us, as well as your Personal Data collected from your use of the RiseUp Services (i.e. your Personal Data which we collect automatically and/or from other sources); and
  2. to use cookies and web beacons (pixel tags) to collect your Personal Data.

  1. COMPLIANCE WITH DATA PROTECTION LAWS IN APPLICABLE JURISDICTIONS

  1. If you are located in the European Economic Area (EEA) privacy rights are granted, and all processing of Personal Data is performed by regulations and rules following Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”).
  2. If you are located in California, all Personal Data processing is performed per regulations and rules following the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”).
  3. If you are located in the United Kingdom, all processing of Personal Data is performed in accordance with regulations and rules following the Data Protection Act 2018 (“DPA 2018”).
  4. If you are located in Australia, all processing of Personal Data is performed in accordance with regulations and rules following the Privacy Act 1988 (“Privacy Act 1988”).
  5. If you are located in Canada, all processing of Personal Data is performed in accordance with regulations and rules following the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”).
  6. If you believe Our Policy does not comply with the laws of your jurisdiction, we would like to receive your feedback. Ultimately, however, it is your choice whether or not you wish to use our Website or Application.

  1. THE RIGHTS OF USERS

  1. Subject to possible restrictions under national law, as a data subject under the GDPR, you may have certain rights regarding the Personal Data that we collect on you.
  2. Under Chapter 3 of the General Data Protection Regulation (GDPR), the rights of the data subjects include the following:
  1. Right to access. You may contact us to get confirmation as to whether or not we are processing your personal data. When we process your personal data, we will inform you of what categories of personal data we process regarding You, the processing purposes, the categories of recipients to whom personal data have been or will be disclosed, and the envisaged storage period or criteria to determine that period;
  2. Right to withdraw consent. In case our processing is based on the consent granted, you may withdraw the consent at any time by contacting us or by using the functionalities of the Website. You can withdraw your consent at any time by replying to the email with your withdrawal, and your Personal Data will be deleted immediately. Withdrawing consent may lead to fewer possibilities to use RiseUp Services;
  3. Right to object. In case our processing is based on a legitimate interest to run, maintain, and develop our business, you have the right to object at any time to our processing. We shall then no longer process your personal data unless for the provision of RiseUp Services or if we demonstrate other compelling legitimate grounds for our processing that override your interests, rights, and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, you have the right to prohibit us from using personal data for direct marketing purposes, by contacting us or by using the functionalities of the Website, or unsubscribing possibilities in connection with our direct marketing messages;
  4. Right to restriction of the processing. You have the right to obtain from us restriction of processing of your personal data, as foreseen by applicable data protection law, e.g. to allow our verification of the accuracy of personal data after you contest the accuracy or to prevent us from erasing personal data when personal data are no longer necessary for the purposes but still required for your legal claims or when our processing is unlawful. Restriction of processing may lead to fewer possibilities to use the Website;
  5. Right to data portability. You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format and to independently transmit those data to a third party, in case our processing is based on your consent and carried out by automated means;
  6. Right to complain. You have the right to complain to any relevant Data Protection Authority, in particular in the Member State of your residence, place of work, or the place of processing your personal data. If you wish to exercise any of the aforementioned rights, please Contact us via support@intimate.guru.
  7. How to use these rights. To exercise any of the above-mentioned rights, you should primarily use the functions offered by the Website or Application. If such functions are however not sufficient for exercising such rights, please send us a letter or email to the address set out below under the Policy, including the following information: name, address, phone number, and email address. We may request additional information necessary to confirm your identity. We may reject unreasonably repetitive requests, excessive, or manifestly unfounded.

  1. DATA STORING AND DELETION

  1. We store your Personal Data for as long as needed to provide you with RiseUp Services. We may store Personal Data longer, but only in a way that it cannot be tracked back to you. When Personal Data is no longer needed, we delete it using reasonable measures to protect the Personal Data from unauthorized access or use.
    EU Territory. We store Personal Data as long as it is needed for the provision of RiseUp Services. Traffic information is erased or made anonymous when it is no longer needed for the transmission or, in the case of payable Service, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Direct marketing and provision of value-added Service information (including traffic information used for these purposes) are stored as long as the same is necessary for the provision of these activities, or up to the time when a User opts out from such use under this Policy. Other information is stored for as long as we consider it necessary to provide RiseUp Services. This Section shall not prevent any technical storage or access to information for the sole purpose of transmitting a communication or as strictly necessary for us to provide the RiseUp Services you requested.
  2. As the GDPR statement explains, we strive to anonymize the data when possible. If you decide to exercise your right to erasure, we will also inform our providers to delete all your personal data.
  3. US Territory. We will retain collected information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by applicable legislation.
  4. Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed to provide, improve, or personalize RiseUp Services.

  1. DATA SECURITY

  1. We care to ensure the security of Personal Data. We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once we receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When we or our contractors process your information, we also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is done through appropriate administrative, technical, and physical measures.
  2. There is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, we cannot guarantee its absolute security.
  3. We may not process any kind of sensitive data or criminal offense data. Also, we never undertake to profile personal data.

  1. COOKIE SECTION

  1. Cookies can be used to store your passwords or other identification data, Website and Application browsing settings, as well as for other purposes such as collecting statistics and marketing.
  2. Cookies help you to use the Website and Application more conveniently, and also help us learn more about your preferences and offer you personalized RiseUp Services. Cookies saved from our Website are read every time you visit the Website again, and can provide certain conveniences, for example, you no longer need to re-enter passwords, etc.
  3. Most browsers automatically accept cookies, but you can change these settings. You can find a more detailed description of how to do this on the Internet, on the website of the developer of your browser, or via other official resources. Unfortunately, if you disable cookies, certain functionality of web pages will (or may) not be available to you through our Website.
  4. Types of Cookies used by the Website:
  1. «Strictly necessary/Technical Cookies» are essential for the proper functioning of our Website, and its main functions, and are used for technical purposes, such as to remember your cookie settings or access secure areas of the Website, etc. Such cookies cannot be disabled, they are always active and will be placed without your consent;
  2. «Functional Cookies» — allow our Website to store your login, language choice, location, etc., for more convenient use of the Website by you and personalization of your experience on the Website;
  3. «Marketing Cookies» — help personalize your preferences and offer only those RiseUp Services that may interest you;
  4. «Session Cookies» — certain cookie files can be sessional, they allow us to synchronize the User's interaction during the browser session (record information viewed on the Website, etc.). Session Cookies expire when the browser session ends, so they are not stored after it is closed.
  1. To the extent that information processed in connection with cookies should qualify as personal data, the legal ground for that processing is your consent (Art. 6 (1) lit. (a) GDPR).
  2. So, by clicking “Yes” on the cookie banner, you give your consent to RELIZ LTD to place and/or read several types of cookies from the Website or Application you are visiting.

  1. CONTRACTORS

  1. We work with third-party services providers, who provide website, application development, hosting, maintenance, payment processing, and other services for us. They may be located outside of the EEA. These contractors may have access to, or process Personal Data on our behalf as part of providing those services for Us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions.
  2. All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the European Economic Area may be possible only in the case when we have obtained your consent for it.
  3. All data we process is stored exclusively in secure hosting facilities provided by Amazon AWS.
  4. We use a third-party payment processor, currently Paddle (“Payment Processor”) to assist in securely processing your payment information. If you pay with a credit card the payment information that you provide through the RiseUp Services is encrypted and transmitted directly to the Payment Processor. Please, be aware that your payment data, provided to Paddle for payment processing to use RiseUp Services will be shared with Reliz LTD for product fulfillment.
  5. We may share your personal data with our insurers, and our professional advisors (lawyers, bankers, auditors, corporate financiers, and brokers) in connection with the RiseUp Services they provide to us. If we share your personal data with those processors, we will require the recipient to keep it confidential and secure. To provide you with RiseUp Services, we may provide personal data to the courts, to lawyers advising the other parties to a matter, or to other professionals (such as overseas law firms, patent agents, forensic accountants, or barristers).

  1. LINKS TO THIRD-PARTY WEBSITES

  1. This website may contain hyperlinks to third-party websites. We are not responsible for the content of such websites, or for how those websites collect, hold, use, and distribute any personal information you provide.
  2. When visiting a third-party website from hyperlinks displayed on this Website, we encourage you to review the Privacy Policies of those websites so that you can understand how the personal information you provide will be collected, held, used, and distributed.
  3. We use TikTok for Developers to help develop features in our application such as sharing videos straight from our application to TikTok, embedding the TikTok videos onto our website, uploading or downloading videos, and so on. For more information on the privacy practices of TikTok, please visit https://developers.tiktok.com/.
  4. We use Mixpanel. Mixpanel processes the personal data of our Users to enable us to learn how our Users and other individuals use our Applications, Websites, or web properties. For more information on the privacy practices of Mixpanel, please visit the Privacy Policy: https://mixpanel.com/legal/privacy-policy/.
  5. We use Facebook pixel to measure and increase the effectiveness of our advertising campaigns. For more information on the privacy practices of the Facebook pixel, please visit the Privacy Policy: https://www.facebook.com/business/m/privacy-and-data.

  1. INFORMATION RELATING TO CHILDREN

  1. We do not intentionally collect or maintain information from persons under the age of 18.
  2. If we determine upon collection that a User is under this age, we will not use or maintain the Personal Data of such person with or without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 18, we will make reasonable efforts to delete such information from our records.
  3. We also recommend that parents monitor their children’s Internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian’s preferences.

  1. APPLICATION OF THIS POLICY

  1. This Privacy Policy applies to the Website and Application. This Policy is no longer applicable once redirected to another website or mobile application.

  1. ACCEPTANCE OF THIS POLICY

  1. By accepting the checkbox on the Website or App, you agree with the uploaded Privacy Policy.
  2. We assume that all Users have carefully read this Policy and agree to its content. If one does not agree with this Privacy Policy, please do not use this Website and/or App.

  1. CHANGES AND UPDATES

  1. From time to time, we may update this Privacy Policy. We encourage you to periodically check back and review this Policy so that you always know what data we collect, how we use it, and with whom we share it.

  1. CONTACT US!

  1. If you have any questions, suggestions, or comments, please contact us via email at support@intimate.guru