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Privacy Policy

Ember Holdings Privacy Policy
Last updated: February 2025

1. Introduction
This Privacy Policy outlines how Ember Holdings (“we”, “our”, or “us”) handles personal information collected through our products, services (“Services”), and website (“Website”). Protecting your privacy is a top priority, and we are committed to safeguarding your personal data.

Our Services and Website may contain links to third-party sites or services, and we are not responsible for their privacy practices. We recommend reviewing their privacy policies before using them.

All information provided to us through our Services is treated as confidential. We utilize appropriate technical, organizational, and security measures to protect your personal data against unauthorized access, loss, destruction, or disclosure.

When you submit personal information on our Website (such as your name, email, phone number, or date of birth), this data is used to verify your identity, provide support, fulfill contractual obligations, and send communications. You can manage your communication preferences and unsubscribe from certain messages at any time.

2. Website Visitors and Users
2.1 General
This section explains how we collect data from visitors (“Visitors”), users (“Users”), and business partners (“Partners”). Personal data includes information like your IP address, name, contact details, and your relationship with us, as per applicable data protection regulations.

2.2 Collection and Use
By visiting our Website, you consent to the collection and processing of your personal data. If you disagree with this, you should refrain from using the Website. We may collect information through page views, IP addresses, cookies, and submitted forms.

2.3 Purpose of Processing Personal Data
We process personal data to improve the Website and our Services, enhance communication, provide support, fulfill contractual obligations, and collaborate with partners. The legal basis for processing may include your consent, performance of a contract, or legitimate interests.

The purposes and legal grounds for processing personal data include:

  • Registration and account creation: Consent; Performance of services or contract obligations
  • Providing Services: Performance of services or contract obligations
  • Operational updates and support: Performance of services or contract obligations
  • Customizing Services, advertising, and marketing: Legitimate interests or consent
  • Improving and offering new Services: Consent and legitimate interests
  • Sending marketing communications: Consent
  • Analyzing marketing effectiveness: Legitimate interests or consent
  • Supporting various activities: Legitimate interests or performance of services
  • Statistical analysis: Legitimate interests
  • Protecting rights, assets, and interests: Legitimate interests or legal obligations

2.4 Sharing Personal Data
We may share personal data with service vendors, partners, and contractors. For Visitors and Users located in the European Economic Area (EEA), all data processing complies with GDPR and relevant data protection laws.

3. Partners
3.1 General
To provide Services, we may collect and process data from our Partners. Partners are responsible for their own data, and we access it through secure channels.

3.2 Processing of Personal Data
We process Partner data based on consent or legitimate interests. Data may be aggregated for research and improvement purposes.

3.3 Controller/Processor
Depending on the data type, we act as a data Controller (for Visitor/User data) or Processor (for Partner data). All data is hosted securely following high-security standards.

3.4 Third-Party Data Protection
When third-party platforms process personal data, we act as a Processor, ensuring compliance with the platform’s instructions and security protocols. We do not subcontract or process data outside the EEA without prior consent.

4. Security
We implement administrative, technical, and organizational safeguards to protect personal data from unauthorized access, disclosure, alteration, or destruction. We ensure third parties we work with adhere to the same high standards for data protection.

While we make every effort to protect your data, we cannot guarantee absolute security from third-party breaches. Users acknowledge the inherent risks involved in data processing.

5. Cookies
For more details on cookies and tracking technologies used on the Website, refer to our Cookie Policy, which explains their purpose and how you can manage your preferences.

6. Links to Other Sites
Our Website may contain links to external sites not controlled by us. We are not responsible for the content or privacy practices of these third-party sites. Please review their privacy policies before submitting any personal data.

7. Retention and Deletion
We retain personal data only as long as necessary to fulfill its purpose. If you wish to delete your data or account, we will comply with applicable laws and our internal policies.

Withdrawing consent for data processing may affect access to some Services, and no further claims will be accepted.

8. Your Rights
You have specific rights concerning your personal data:

8.1 Right of Access
You can request confirmation on whether we process your personal data and obtain details about its processing, including the purpose, categories, and recipients.

8.2 Right to Rectification
You can request the correction or completion of inaccurate or incomplete personal data.

8.3 Right to Erasure
You may request the deletion of your personal data under certain conditions.

8.4 Right to Restriction of Processing
You can ask us to limit the processing of your data in specific circumstances.

8.5 Right to Data Portability
You have the right to receive your personal data in a structured, machine-readable format and transfer it to another data controller.

8.6 Right to Object
You can object to data processing based on legitimate interests or direct marketing. We will cease processing unless there are compelling legal grounds.

8.7 Right to Withdraw Consent
You can withdraw consent for processing personal data at any time.

9. Advertising and Marketing Materials
We may use your personal data to send advertising and marketing materials, but we will always obtain your consent. You can withdraw your consent at any time by contacting us.

10. Acceptance of this Policy
By using the Website and/or Services, you acknowledge that you have read and agree to this Privacy Policy. If you disagree, you should refrain from using the platform. We reserve the right to modify this Policy at any time, and you should check for updates regularly. Continued use after updates means you accept the revised policy.

11. Legal Obligation to Disclose Personal Data
We may disclose personal data without prior consent if required to comply with legal obligations or to establish identity and initiate legal proceedings against individuals suspected of infringing our rights.

12. Data Protection Officer
For any privacy or data protection-related questions, please contact our Data Protection Officer at [email protected]