1. WHO WE ARE

1.1. https://robertjarva.com/ (the “Website”) and the Services (as defined below) are provided by Robert Jarva (“Service Provider”, “we”, “our” or “us”) and our subsidiaries.

1.2. This Privacy Policy shall be read alongside, and in addition to, our Terms of Use accessible online here (the “Terms”) and our Cookie Policy accessible online here (the “Cookie Policy”).

1.3. This Privacy Policy sets out how we collect and use your personal information when you (i) use the services offered by Service Provider and its subsidiaries by visiting our Website; (ii) use products and the Website as defined in the Terms; and (iii) registering an account, (an “Account”) and use the mobile, online, and downloadable products (the “Services”) offered by Service Provider and its subsidiaries on the Website, AppStore, GooglePlay and any other application stores.

1.4. Please note that information collected via the Services offered by Service Provider and its subsidiaries is used by Service Provider, responsible for its processing.

1.5. In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

1.6. Please note that if you use other products and Services that Service Provider suggests on the Website, or such products and services are provided by or together with third parties, you may be required to register “extra” accounts, and in that case additional privacy policies shall be applied and accepted by you.

2. THIS PRIVACY POLICY

2.1. By making the Services available, we, acting reasonably and in good faith, believe that you:

(a) have all necessary rights to register an Account, and use the Services;

(b) provide true information about yourself to the extent necessary for the use of the Services;

(с) are aware of and accept this Privacy Policy.

3. INFORMATION WE COLLECT ABOUT YOU

3.1. In order to implement the agreement between you and us, and provide you with access to use the Services, we will improve, develop, and implement new features of our Services, and enhance the functionality of the available Services. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organize, extract, compare, use, and supplement your data (hereinafter “Processing”). We will also receive and pass this data, and our automatically processed analyses of this data, to our affiliates and partners as set out in the table below and in section 4 of this Privacy Policy.

3.2. We set out in more detail the information we collect when you use our Services, why we collect and process it, and the legal basis below.

3.3. General clauses, which shall apply to your use of the Website and the Services related to the Service Provider:

3.4. We may also undertake certain actions to prevent fraudulent activity in our Services, improve our Services and provide you with better user experience.

3.5. Our legitimate interests include (1) maintaining and administrating the Services; (2) providing the Services to you; (3) improving the content of the Services and web pages; (4) processing of the data that was manifestly made public by you where it is accessible by others; (5) ensuring your Account is adequately protected; and (6) complying with any contractual, legal, or regulatory obligations under any applicable law.

3.6. As part of maintaining and administrating the Services, we use the information to analyze user activity and to ensure that the rules and Terms are not violated.

3.7. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body, or agency, or in the defense or exercise of legal claims. We will not delete personal information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.8. In case you provided us with a consent to the sending of marketing information, you may withdraw your consent to the sending of marketing information to you by amending your privacy settings in your Account. An option to unsubscribe will also be included in every SMS or e-mail sent to you by us or our selected third party partners.

3.9. Please note, that if you withdraw your consent to data processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services or register with the web pages of the Website.

3.10. If we intend to further process your data for any other purpose besides those set out in this Privacy Policy, we shall provide you with details of these purposes before we commence data processing.

4. VERIFICATION AND AGREEMENT CONCLUSION

4.1. Verification Procedure. Users are required to undergo a verification procedure as provided by our Services. This verification may include, but is not limited to, the submission of personal data stated above.

4.2. Successful Verification. Upon successful completion of the verification procedure, the Service Provider and you agree to enter into a separate agreement that will define the further terms of interaction. From the moment of the separate contract's conclusion, all relations between the parties will be governed by the terms of this contract. The privacy policy will continue to apply to the extent that it does not contradict the terms of the concluded contract.

5. DATA SHARING

5.1. Sharing with third parties. We may share your personal information with third parties only in the ways that are described in this Privacy Policy. Sometimes we may need to provide your data to affiliated entities, as well as our partners, in order to provide you with the Services offered by the Service Provider and its subsidiaries, to administer the Services, for example, if you choose to administer the billing services or to personalize, adjust and improve our Services or in other cases described in this Privacy Policy and only subject to the purposes described in this Privacy Policy. We do not sell your personal information to third parties. The transmissions of personal data with the recipients (whatever their legal status, subcontractor, processing manager or just recipient) are carried out in a secure manner and in application of an agreement between us and each recipient as may be necessary under applicable law. We undertake to ensure that each recipient knows the directive principles of personal data protection and submit to them in application of the law and/or of a particular contract.

5.2 Confidentiality obligations. In case we share your data with selected third parties, including our third-party contractors, we always ensure that these third parties undertake confidentiality obligations regarding your personal data collected while you use the services or applications they offer. The developers use the information provided to them in order to provide you with additional services, including technical support, if applicable. We will not share your personal data outside the scope of purposes specified in this Privacy Policy without your prior consent.

5.3. Advertising disclaimer. Our ad management and recommendation system are designed so that your information will not be shared directly with our third-party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within some criteria such as location (country, city), type of business or other, or to target communities according to their types. If you fall within one of the target groups, you will receive an advertisement or recommendation of such third-party partners or our affiliates. However, such third-party advertisers or our affiliates may gather some of your information in case you interact in any way with the ads provided by such advertisers.

5.4. Retargeting disclaimer. An advertiser or maker of recommendations may also choose to upload a list of identifiers (e.g., e-mails, phone numbers) and identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.

5.5. Sharing in the general conduct of business. We may also share your data with our affiliates and keep some of your personal information in our business records for the accounting and compliance purposes. As such, we may also disclose your personal information to a third party if we decide to transfer a business to that third party, so you can continue to receive service and information in connection with that business with as little disruption as possible. Similarly, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal information may be transferred to our successor or assignee.

5.6. Disclosure to tax authorities. We reserve the right to disclose your personal information to tax authorities if it's necessary.

5.7. Disclosure required by law. We reserve the right to disclose your personal information as required by law, by court order or in special cases when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action if you or third parties are violating the Terms, any other terms of services provided by us or our affiliates or any applicable law, for the purpose of defense of our rights and interests. We also reserve the right to disclose your personal information if we have a good faith belief that it is necessary to prevent fraud or other illegal activities.

6. PRIVACY SETTINGS

6.1. The Services may contain links to websites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services, and you shall ensure that you review the relevant third party’s privacy statement, which will govern your data privacy rights.

6.2. We bear no liability for the actions of third parties, which, as the result of your use of the Internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you.

6.3. We bear no liability for the consequences of the use of the information that, due to the nature of the Services, is available to any Internet user. We ask you to take a responsible approach to the scope of the information posted on the Website.

7. INTERNATIONAL TRANSFERS

7.1. We may transfer and maintain some of your personal information on our servers or databases outside the European Economic Area (EEA).

7.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g., Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

8. RETENTION PERIODS. DATA DELETION

8.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

8.2. You are entitled to withdraw your consent to process your personal data under this Privacy Policy at any time by removing the data from your Account or alternatively by deleting your Account through your Account settings and following the instructions provided by the Service Provider after your sending such a deletion request.

8.3. You may request to remove your Account and data on our Services by contacting the Service Support (see section 11 for details). Please note that such withdrawal does not have any impact on the validity of the consent before withdrawal, and we reserve the right to process your personal data on another lawful basis if permitted by applicable law.

Please also note that uninstalling our game (or any application related to our Services) from your device does not automatically result in consent withdrawal or any deleting your personal data from our servers.

8.4. We may remove your Account or the information you post, as provided by the Terms.

9. YOUR RIGHTS

9.1. You have the following rights, in certain circumstances, in relation to your personal information:

(a) Right to access your personal information.

(b) Right to rectify your personal information: you can request that we update, block, or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received, or no longer relevant for the purpose of processing.

(c) Right to restrict the use of your personal information.

(d) Right to request that your personal information is erased if:

- it is no longer required in relation to the purposes for which it was gathered or processed in another way;

- you withdraw your consent concerning processing subject to consent;

- you are justifiably opposed to the processing;

- it has been subject to illicit processing; or

- it is imposed by law.

(e) Right to object to processing of your personal information.

(f) Right to data portability (in certain specific circumstances).

(g) Right not to be subject to an automated decision.

(h) Right to lodge a complaint with a supervisory authority.

(i) For processing based upon your consent, the right withdraws that consent at any time.

(j) You may have other rights under your legislation of your country of residence, including the right to define the instructions relative to the outcome of your personal data after your death.

9.2. You also have the right to independently remove personal information on your Account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you.

9.3. If you would like to exercise these rights, please contact us via mail or e-mail. We will aim to respond to you within 30 days from the date of receipt of your request, unless another, shorter term, is prescribed by applicable laws. We will need to verify your identity before we are able to disclose any personal data to you.

10. SECURITY MEASURES

10.1. We take technical, organizational, and legal measures, including, where suitable, encryption, to ensure that your personal data is protected from unauthorized or accidental access, deletion, modification, blocking, copying, and dissemination.

10.2. Access to the Services is authorized using your login and password. You are responsible for keeping this information confidential. You shall not share your credentials with third parties, and we recommend you take measures to ensure this information is kept confidential.

10.3. If you forget your login details, you can request us to send you verification information as agreed in the Terms.

10.4. To reduce the probability of third parties gaining unauthorized access, if you login to your Account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your Account. You will then need to contact Service Support and provide certain additional information to verify your credentials and gain access to your Account.

11. CHANGES TO THIS POLICY

11.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation archive. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to them.

12. CONTACT US

12.1. If you have any questions, please send inquiries to Service Support at hello@robertjarva.com or through Account settings/functionality provided via Services (if applicable). Please quote this Privacy Policy so we can deal with your enquiry efficiently. We will aim to respond to you within 30 days from receipt of your request, unless another, shorter term, is prescribed by applicable laws.

12.2. All correspondence received by us from you (written or electronic enquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for responding to the enquiry, except as expressly provided by law.

This is an agreement between you (“Client”, “You” and “Your”) and Robert Jarva (“Service Provider”, “we”, “our” or “us”) and our subsidiaries.

Terms “Party”, “Parties”, or “Us” refer to both the Client and ourselves.

This terminology applies to these Terms, Privacy Policy and all other agreements between the Parties.

These Terms of Use (“Terms”) outline the rules and regulations for the use of Service Provider's products which may include any applications and other services (“Services”) provided by Service Provider via the https://robertjarva.com/ (“Website”) and AppStore, Google Play and other application stores if applicable (“Stores”).

By using, downloading and accessing our Services we assume you accept these Terms. Do not continue to use our Services, if you do not agree to take the Terms stated on this page.

All terms refer to the offer and acceptance necessary to undertake the process of our assistance to the Client in the most appropriate manner for the express purpose of meeting the Client’s needs in respect of provision of the Service Provider’s stated Services, in accordance with and subject to, prevailing law of Cyprus. Any use of the above terminology or other words in the singular, plural, capitalization and/or he/she or they, are taken as interchangeable and therefore as referring to the same.

(1) Account

To leverage Services offered on our Website, Users are required to establish an account (“Account”). During this process, it is imperative to provide precise, current, and complete information and pass the verification. The accuracy and truthfulness of the information provided by you during the registration of your Account and completion of the profile (questionnaire) will determine the decision made by the Service Provider (see section 2).

Safeguarding your account password is crucial. Refrain from sharing it with any external parties. Should You become aware or have reasons to believe that your password has been compromised or misused, please alert Us immediately at: hello@robertjarva.com.

Please be informed that all actions and activities initiated from your Account are your responsibility. We urge you to exercise caution and ensure the security of your Account.

Users are strictly prohibited from selling, buying, renting, exchanging, or giving away their Accounts associated with the Website, regardless of compensation or intent.

OWNERSHIP DISCLAIMER. WHILE USERS MAY HAVE ACCESS TO AND THE ABILITY TO USE THEIR ACCOUNTS, THEY DO NOT POSSESS ACTUAL OWNERSHIP OF THESE ACCOUNTS. THE SERVICE PROVIDER MAINTAINS FULL OWNERSHIP AND THE RIGHT TO MANAGE, MODIFY, OR DELETE ANY ACCOUNT AS NECESSARY.

The Service Provider retains the unreserved authority to disable or terminate your Account whenever deemed necessary.

The primary reasons for potential Account deactivation include:

• Failing to adhere to any provisions of our Terms;
• Engaging in activities on your Account that, in the sole judgment, might jeopardize or hamper Our Services;
• Engaging in activities that infringe or violate rights of third parties;
• Any activities that contravene applicable local, state, national, or international laws and regulations.

Specific Terms Pertaining to Account Deletion:

Your Account may be subject to deletion if the Service Provider decides to cease its Services either on a global scale or within specific territories or regions. There may be additional specific grounds for account deletion as defined by the Service Provider or as stipulated in separate agreements or provisions.

Clients desiring to end their use of our Services and seeking Account deletion should contact Us at hello@robertjarva.com. Upon reaching out, Our dedicated team will provide comprehensive guidance and walk You through the necessary steps for Account deletion.

Once you finalize the decision to delete your Account, reactivation is not possible. All content, data, and information associated with your Account will be permanently erased and cannot be retrieved. The Service Provider holds no obligation to provide compensation, refunds, or any form of reimbursement if a User decides to delete its Account or if the Service Provider initiates the deletion for any of the aforementioned reasons.

(2) Contractual Acceptance

After successfully completing the profile form and receiving approval from the Service Provider, you may have the opportunity to enter into an agreement with the Service Provider for the provision of the Services. The decision to enter into an agreement remains at the discretion of the Service Provider.

The Service Provider reserves the right to refuse to enter into an agreement without providing reasons. The Client agrees that the Service Provider is not liable for such decisions and is not obligated to provide explanations.

This clause does not limit the Service Provider's rights to conduct additional checks and analysis to make a decision regarding the contract, and such decisions are made in accordance with the Service Provider's internal procedures and criteria.

Once an agreement is entered into, the relationship between you and the Service Provider is exclusively governed by the terms and conditions outlined within the agreement.

(3) License

Unless otherwise stated, Service Provider and/or its licensors own the intellectual property rights for all material related to the Services provision, including, but not limited to, all materials uploaded and displayed on the Website, as well as materials placed in the Stores (the “Content”). All intellectual property rights are reserved. you are provided a limited, royalty-free, revocable, and non-exclusive license to access and use our Services/Content for your own personal use subjected to restrictions set in these Terms. Any deviation or violation of these Terms can result in the termination of the license.

You must not:

• Republish the Content;
• Sell, rent or sub-license the Content;
• Reproduce, duplicate or copy the Content;
• Redistribute the Content.

These provisions shall begin on the date hereof.

(4) Hyperlinking to our Content

The following organizations may link to our Content/Services without prior written approval:

• Government agencies;
• Search engines;
• News organizations;
• Online directory distributors may link to our Website/ placement in Stores in the same manner as they hyperlink to the Websites/ placement in Stores of other listed businesses; and
• System wide Accredited Businesses except soliciting non-profit organizations, charity shopping malls, and charity fundraising groups which may not hyperlink to our Web site/placement in Stores.

These organizations may link to our home page, to publications or to other Website information, as well as our branded pages in the Stores, so long as the link: (a) is not in any way deceptive; (b) does not falsely imply sponsorship, endorsement or approval of the linking party and its products and/or services; and (c) fits within the context of the linking party’s site.

We may consider and approve other link requests from the following types of organizations:

• commonly-known consumer and/or business information sources;
• dot.com community sites;
• associations or other groups representing charities;
• online directory distributors;
• internet portals;
• accounting, law and consulting firms; and
• educational institutions and trade associations.

We will approve link requests from these organizations if we decide that: (a) the link would not make us look unfavorably to ourselves or to our accredited businesses; (b) the organization does not have any negative records with us; (c) the benefit to us from the visibility of the hyperlink compensates the absence of the Service Provider; and (d) the link is in the context of general resource information.

These organizations may link to our home page/ branded pages in the Stores so long as the link: (a) is not in any way deceptive; (b) does not falsely imply sponsorship, endorsement or approval of the linking party and its products or services; and (c) fits within the context of the linking party’s site.

If You are one of the organizations listed in paragraph 2 above and are interested in linking to our Website/ branded pages in the Stores You must inform us by sending an e-mail to hello@robertjarva.com. Please include Your name, your organization name, contact information as well as the URL of your site, a list of any URLs from which you intend to link to our Website/branded pages in the Stores, and a list of the URLs on our site to which you would like to link. Wait 2-3 weeks for a response.

Approved organizations may hyperlink to our Website/branded pages in the Stores as follows:

• By use of our corporate name; or
• By use of the uniform resource locator being linked to; or
• By use of any other description of our Website or Services being linked to that makes sense within the context and format of content on the linking party’s site.

No use of the Service Provider's logo or other artwork will be allowed for linking absent a trademark license agreement.

(5) Frames

Without prior approval and written permission, you may not create frames around our Webpages that alter in any way the visual presentation or appearance of our Website or branded pages in the Stores.

(6) Content Liability

We shall not be held responsible for any content that appears on your website and in your products. You agree to protect and defend us against all claims that are rising in retaliation to your products and services. No link(s) should appear on any website/product that may be interpreted as libelous, obscene or criminal, or which infringes, otherwise violates, or advocates the infringement or other violation of, any third party rights.

(7) Cookies on the Website

On our Website we employ the use of cookies. By accessing Website, you agreed to use cookies in agreement with the Service Provider's Cookie Policy accessible via the link.

Most interactive websites use cookies to let us retrieve the user’s details for each visit. Cookies are used by our Website to enable the functionality of certain areas to make it easier for people visiting our website. Some of our affiliate/advertising partners may also use cookies.

(8) Your Privacy

Please read Privacy Policy accessible via the link.

(9) Reservation of Rights

We reserve the right to request that you remove all links or any particular link to our Website/ branded pages in the Stores. You approve to immediately remove all links to our Website/branded pages in the Stores upon request. We also reserve the right to amend these Terms and its linking policy at any time. By continuously accessing and using our Services, you agree to be bound to and follow these linking Terms.

(10) Removal of links from our Services

If you find any link or Content in our Services that is offensive for any reason, you are free to contact and inform us any moment. We will consider requests to remove links or Content but we are not obligated to or so or to respond to you directly.

We do not ensure that the information provided by our Services is correct, we do not warrant its completeness or accuracy; nor do we promise to ensure that the Services remain available or that the materials are kept up to date.

(11) Disclaimer

To the maximum extent permitted by applicable law, we exclude all representations, warranties and conditions relating to our Website and the use of this Website. Nothing in this disclaimer will:

• limit or exclude our or your liability for death or personal injury;
• limit or exclude our or your liability for fraud or fraudulent misrepresentation;
• limit any of our or your liabilities in any way that is not permitted under applicable law; or
• exclude any of our or your liabilities that may not be excluded under applicable law. The limitations and prohibitions of liability set in this Section and elsewhere in this disclaimer: (a) are subject to the preceding paragraph; and (b) govern all liabilities arising under the disclaimer, including liabilities arising in contract, in tort and for breach of statutory duty.

As long as the Website and the information and Services on the Website are provided free of charge, we will not be liable for any loss or damage of any nature.

(12) Contact Details

If you have any comments or questions about these Terms, please contact us at hello@robertjarva.com

This document is posted by Robert Jarva, a Service Provider of the services at https://robertjarva.com/, hereinafter named “we”, “our” or “us”, to assist our website users with knowing our cookies policy.

We believe in being clear and open about how we collect and use data related to you. In the spirit of transparency, this policy provides detailed information about how and when we use cookies.

1. How do we use cookies, tags and similar technologies?

1.1. Please review this Cookie Policy carefully. This policy describes our information practices relating to using our website https://robertjarva.com/ and all of our online products and services (together "website").

2. Cookies

2.1. A cookie is a small text file which includes a unique identifier that is sent by a web server to your computer, mobile phone or any other internet enabled device when you visit a website or mobile app. Cookies are widely used to make sites work efficiently and to collect information about users' online preferences. For simplicity, this Policy refers to cookies but we may use other similar technologies in the same way.

3. How do we use cookies?

3.1. We use cookies to record session information and provide our services to you. We use this information to make decisions about ways to improve the services we offer you by making browsing easier, providing a more personalised service, tailoring the recommendations and advertising that you see on our site, and our own analysis which helps us develop and improve our site.

3.2. We use all or some of the following categories of cookies on our website:

(a) Essential cookies. These cookies are essential for parts of our website to operate. They enable you to move around our website and allow us to recognise you within our website so that we can provide you with the service that you have asked for such as remembering your sign-in details.

(b) Functionality cookies. These cookies help us customise our site content based on your preferences. They remember choices you make, your language and the country you visit our website from. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

(c) Performance cookies. These cookies collect information on how you use our website in order to help us improve areas such as navigation and to help us fix technical issues or errors. For example, we use these cookies to help us understand how you arrive at our website, browse or use our website and highlight areas where we can improve. The information stored by these cookies never shows personal details from which your identity can be established.

(d) Targeting cookies. These cookies collect information about your browsing habits in order to make advertising, and the content we deliver, more relevant to you and your interests. These cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers.

3.3. We may engage third party providers to act on our behalf to ensure safe browsing, enrich user experience, track and analyse your usage of our website through the use of cookies, pixel tags / web beacons, and similar technologies. These third parties collect, and share with us, usage information about visits to our website, measure and research the effectiveness of our advertisements, track page usage, help us target our recommendations and advertising, and track use of our recommendations and advertisements.

3.4. Some of the cookies we commonly use are listed below:

4. How can you reject cookies?

4.1. At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete or disable any cookies, please consult your browser's 'Help' or 'Support' section. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website.

4.2. Please consult the following links for information on cookie management and blocking according to your browser:

(а) Explorer

(b) Firefox

(c) Chrome

(d) Safari

4.3. You can opt out of third party tracking networks using these tools:

• Click here to opt out of Google Analytics
• Click here to opt out of AddThis

4.4. You can find general information and opt-out resources at youronlinechoices.eu.

5. Changes to this Policy

5.1. From time to time, we may change and/or update this Cookie Policy. If this Cookie Policy changes in any way, we will post an updated version on this page. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such. Any changes to this Cookie Policy will go into effect on posting to this page.

6. Contact Details

6.1. If you have any comments or questions about this policy and our use of cookies please contact us at hello@robertjarva.com.