Privacy Policy

This Privacy Policy governs your use of (the “Website”) and describes how and why Chesmint Limited (“we”, “us”, “our”) process your personal data, how it is stored, how that data may be used, with whom it may be shared, and your choices about such uses and disclosures.

“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by an identifier such as a name, an identification number, location data, an online identifier, or by one or more factors that determine the physical, physiological, genetic, mental, economic, cultural or social essence of such a natural person.

"Processing" means any operation or series of operations with personal data or sets of personal data with or without the use of automated means, such as collection, registration, organization, structuring, storage, adaptation or modification, retrieval, review, use, disclosure by transmission, distribution or otherwise making available, arrangement or combination, restriction, erasure or destruction.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.Other terms used in this Policy apply to the meanings given in the General Data Protection Regulation (GDPR).We process your personal data exclusively in the manner described in this Privacy Policy and in compliance with the requirements of legality and legitimacy.Reading this Privacy Policy will help you understand your privacy rights and entitlements. If you do not agree with our policies and practices, please do not use our Website. If you still have questions or doubts, contact us at the email address indicated at the end of the Policy.

1. Personal data controller.
Chesmint Limited, a company established in Cyprus with a company number HE 425003, having its registered address at: Flat/Office 102, Lekorpouzier 12a, Limassol, 3075, Cyprus, will be the controller of your personal data.

2. What personal data do we process?
You provide data about yourself when you register for and/or use the Website, for example, when you sign in on Website (create a user profile), respond to our emails, or report a problem. We also collect data automatically when you use the Website (for example, your IP address, device type).
The data that you give us includes:
Profile data: 
- full name 
- email 
- information about the type of the data subject (by choosing the answer to the question in the «Get started form»: «Who are you?» with the proposed answers)name of the company 
- information about the services for which you are applying (by choosing the answer to the question in the «Get started form»: «What services are you applying for?» with the proposed answers) 
- other personal data that you provide to us in the form of a message in the «Get started form». 

By providing Profile data you agree and understand that you are this data will be publicly available. Please do not provide personal data to your Profile that you would not want to be publicly available. We also recommend to avoid providing email addresses, instant messaging details, phone numbers, credit card details, national identity numbers, or drivers' license details in the publicly available sections of your Profile.

Data we collect automatically:
- Data about how you found us.
We collect data about your referring URL (that is, the place on the Web where you were when you tapped on our ad). 
- Cookies and other similar technologies. As further described in our Cookie Policy, our Website use cookies that record data about the use of our website to distinguish you from other users. You can control cookies through your browser settings. 
- Browser and Device data. We collect data from or about the devices from which you access the Website, depending on the permissions you've granted. We may associate the data we collect from your different devices, which helps us provide consistent Services across your devices Examples of such data include: language settings, IP address, location, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID. 
- We also collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device's operating system (but we do not control this). 
- Usage data. We record how you interact with our Website. For example, we log the features, and content you interact with, how often and long you use the Website, what sections you use, and other interactions.

We only request access to the minimum, technically possible amount of data that is necessary for us to implement the existing functions of our Website.3. How do we get access to your data?Access to your personal data may include filling in a box with a check mark when visiting ourWebsite or filling «Get started form», respond to our emails or report a problem.

4. For what purposes do we process your personal data?
We process your personal data:
- to provide services to you. This includes enabling you to use the Website in a seamless manner and preventing or addressing Website errors or technical issues. For example, we use your data to authenticate you and authorize access to our Website. 
- to research and analyze your use of the Website. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Website and our new products. We conduct surveys, research, and test features in development. We analyze the data we have to evaluate our Website, and conduct audits and troubleshooting activities to improve our Website content and layouts. As a consequence, we often decide how to improve the Website based on the results obtained from this processing. For example, if we discover that users do not often use certain section of the Website, we may focus on improving this section. 
- to customize the Website for you. We select the payment processor available to you; we may also use your data to determine your eligibility for promotions, sweepstakes, and contests. 
- to enforce the Terms and to prevent, detect, investigate, and resolve disputes and/or remediate malicious activities, fraud, other cybercrimes, take legally-required actions, or make sure you are a real person and avoid the creation of fake accounts. We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with the Terms). 
- to communicate with you regarding your use of our Website. We may communicate with you, for example, by email or directly on the Website, including through push notifications.
to show and/or send you marketing communications. We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our Website, features, offers, promotions, contests, and events or provide other news or information about third-party services that may be of interest to you. You can opt out of advertisements and/or commercial emails by clicking here: unsubscribe. 
- to provide you with customer service and support. As a result of such processing, we will send you messages about the availability of our Website security, legal notices, or other Website-related information. 
- to personalize our ads. We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. 
- to comply with legal obligations. We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

If we need to further process personal data for a purpose other than the one for which the personal data was obtained, we will provide you with information about such other purposes and any relevant details specified in the General Data Protection Regulation data (GDPR).

5. Legal basis for data processing (EEA only).
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.
We process your personal data under the following legal grounds:
- your consentto perform our contract with you
Under this legal basis we: Provide the services Customize your experience Communicate with you regarding your use of the Website Manage your account and provide you with customer support - Provide you customer service and support
- for our (or others) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data

We rely on legitimate interests:
- to communicate with you regarding your use of our Website
The legitimate interest we rely on for this purpose is our interest to encourage you to use our Website more often. We also take into account the potential benefits to you.
- to research and analyze your use of the Website
Our legitimate interest for this purpose is our interest in improving our Website so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable, or to introduce and test new features). 
- to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Website in a measured and appropriate way. to personalize our adsThe legitimate interest we rely on for this processing is our interest to promote our Website in a reasonably targeted way.
to enforce the Terms and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Website, and non-compliance with the Terms. 
- to comply with legal obligations
Under this legal basis we, in particular, verify your identity.

6. Do we update your personal data?
We take all reasonable steps to update your data to ensure that inaccurate personal data, having regardto the purposes for which it was processed, is deleted or corrected without delay. You have the right tocontact us to correct your personal data and the right to fill in incomplete personal data, including bysubmitting an additional statement.

7. Privacy Rights of the Residents of Certain States of the U.S. 
If you are a resident of a U.S. state that has enacted applicable consumer data privacy laws, which include, but might not be limited to: California, Colorado, Connecticut, Utah and Virginia, you may be entitled to specific rights, including those regarding access to your personal information. However, please note that such laws usually have certain applicability threshold, and, thus, may not be fully applicable to RiseGuide. For more information, please contact us at the email address indicated at the end of the Policy.

California privacy rights. 
This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California's Shine the Light law. Therefore, this section applies only to residents of California, United States.

For more details about the personal information we have collected, including the categories of sources, please see Section 3 above. We collect this information for purposes described in Section 4 this Privacy Policy. We may also share your information with certain categories of third parties as indicated in Section 9. We do not sell (as such term is defined in the CCPA) the personal information we collect.Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at the email address indicated at the end of the Policy. We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.

Access rights under California's Shine the Light
California also provides its residents with additional access rights. Under Shine the Light law, the residents the right to ask companies once a year what personal information they share with third parties for those third parties direct marketing purposes. Learn more about what is considered to be personal information under the statute.

To obtain this information from us, please send an email to us at the email address indicated at the end of the Policy. Your email should include “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

8. Data retention
We will retain personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We take all necessary measures to ensure that the period during which personal data is stored is reduced to an absolute minimum.Please note that we have a variety of obligations to retain the data that you provide to us, including to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if you disable/delete your Profile, we will retain certain data to meet our obligations.

9. With whom do we share your personal data?
We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

Service providers
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers: cloud storage providers (Google Cloud Platform,; data analytics providers (Facebook, Google, Amplitude); marketing partners (in particular, social media networks, marketing agencies, email delivery services).
Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce the Terms, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

10. International data transfers
We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Website set forth in the Terms and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the EU-U.S. Privacy Shield Framework (details available here), or (iii) the European Commission adequacy decisions about certain countries (details available here).

11. Privacy rights.
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data (right to rectification). You may review, edit, or change the personal data that you had previously provided to us. You control your Profile; thus, you may access your profile data at any time and to correct or update it at any time by logging in to the Website. You may also request a copy of your personal data collected during your use of the Website at the email address indicated at the end of the Policy.
Deleting your personal data. You can request erasure of your personal data by sending us an email at the email address indicated at the end of the Policy. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at the email address indicated at the end of the Policy. 
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request at the email address indicated at the end of the Policy.
You may submit requests through an authorized agent, in which case we will need to verify the agent's identity, your identity, and their authority to act on your behalf before we can process the request.

12. How do we handle “do not track” requests?
Except as otherwise stipulated in this Privacy Policy, the Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

13. How do we store your personal data?
We store your personal data exclusively in compliance with the requirements for their safety, integrity and a special regime of access to them, which excludes the possibility of familiarization, distribution and access to personal data of Users directly or indirectly by third parties. We process personal data exclusively in a way that ensures an appropriate level of security and confidentiality of personal data, including to prevent unauthorized access or use of personal data, as well as equipment necessary for processing and against accidental loss, destruction or damage, using appropriate technical and organizational tools.

14. Do we collect personal data from persons under 18 years of age?
We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at the email address indicated at the end of the Policy.

15. Changes to this privacy policy
We may modify this Privacy Policy at any time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Website after those changes become effective, you agree to be bound by the revised Privacy Policy.

16. Contact us
If you have any questions or concerns about this Privacy Policy or our collection, use, or storage or your data, please do not hesitate to contact us at: