Privacy Policy describes the information we collect from you, how we use that information and our legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us.

Who we are?
We are ITIPS TECHNOLOGY LIMITED (“we”, “us”, “our”). We are registered in Cyprus under registered company number HE 425845, and we are located in 25 Martiou, 27, D. MICHAEL TOWER, Flat/Office 105A, Egkomi, Nicosia, Cyprus. We are owners (right-holders) of the iTips software.

What is iTips?
iTips is an IT-solutions that is based on QR-code-powered instant tipping and feedback solution aimed at a wide range of service industries. When you enter into these General Terms you get the right to use the iTips software. The iTips software can be used for persons who want to tip employers and the staff in hospitality, transport & infrastructure, culture & recreation, delivery, shopping, Internet, beauty & medical, fastfood & coffee, and non-profit.
By iTips we give easy way:

• to Customers pay a tip amount;
• to Clients get instantly tips;
• to Employers receive feedback by Customers and statistics by the staff.

iTips is made available to you via our website at https://itips.ai, and our software applications that we may make available.

About Privacy policy
This legal document is public and available at https://itips.ai/privacy.
This Privacy Policy governs all websites, mobile applications, web-apps, and other services that link to, or contain references to this document and are published or made available by ITIPS TECHNOLOGY LIMITED, its parent, subsidiaries and affiliates.

Please read this Privacy Policy carefully. It summarizes the various ways we acquire and treat your Data when you access, visit and/or use the iTips software or get our services. It also governs your Data that we may acquire offline.

This Privacy Policy does not cover information collected on sites, applications, destinations, or services linked from iTips that we do not own or control. If you are going to take registration actions, download, upload, copy or by any other approved manner use the iTips software, including if you begin to participate in the use-process with your Account, then you have to read this Privacy policy and to be agree with that by click-wrap agreement. Every time you access our services by using the iTips software – you confirm your agreement with our Privacy Policy with the last revised.

Please note we will update this Privacy Policy from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Policy, but we encourage you to review this document periodically (before every use iTips) to keep up the date pf the last revision. YOU ACKNOWLEDGE THAT YOU HAVE FULLY READ, UNDERSTAND, ACCEPT AND AGREE WITH OUR PRIVACY POLICY AND OTHER LEGAL DOCUMENTS without the exceptions and qualifications, so you are responsible for their violation.

THE CONDITIONS OF THESE PRIVACY POLICY, AND OTHER LEGAL INSTRUMENTS ALLOWED IN THE TERMS AND CONDITIONS ARE SIGNIFICANT FOR YOUR EXECUTION.

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If you do not agree with all of iTips’ Privacy Policy or a part of it, then please don't use the iTips!

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Definitions



The following words and phrases have the following meanings in these General Terms:

Please note: ]

• all singular words include plural ones and vice versa;
• all references to web-sites, clauses, sub-clauses, sections or appendices are to the ones in these General Terms;
• the term "including" does not exclude anything not listed;
• if there is no term in this section of the General Terms, then such term shall be interpreted in accordance with the designation used in the business environment and the law.

1. Introduction
You can access this Privacy Policy any time at https://itips.ai/privacy or as otherwise indicated depending on iTips you are using. By registering for any aspect of the iTips software, or otherwise accessing, visiting or using iTips, you consent to this Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, you should not access, visit and/or use iTips. We advise that you print or retain a digital copy of this Privacy Policy for future reference.

In addition to reviewing this Privacy Policy, please also review our Terms & Conditions and other legal documents that may be posted elsewhere in at https://itips.ai that are a part of the agreement between you and us:

• Your access to and use of the iTips software is subject at all times to General Terms;
• If you pay Tips to our Clients, your use will be subject to our Customer Terms;
• If you collect Tips by iTips your use will be subject to our Client Terms;
• If you provide permission to your employees to use iTips and you want to receive statistics, reviews, and feedback from Customers so your use will subject to specific agreement.

This Privacy Policy may be modified from time to time, so check back often. So that you are aware changes have been made, we will adjust the “Last Revised” date at the beginning of this document. If we make a significant change in the way we use or share your Personal Data, we may post on the iTips software a prominent notice that a change was made. Continued access of iTips by you will constitute your acceptance of any changes or revisions to the Privacy Policy.

This Privacy Policy must be used only in a case, when you give us Personal Data, not all your Data us or to Third Party by iTips. Please note, that we retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If you have stopped using iTips or your Account has been terminated, we may take steps to mask your Personal Data and Data, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose your Personal Data in accordance with this Privacy Policy.

2. The types of Data acquired about you
In this section of the Privacy Policy, we define a list of the types of data that we collect and use with legal restrictions. We may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use the iTips software and our services:

2.1. Personal Data Registration and an Account. We may collect confirming your identity and that you are engaging in an eligible activity to use iTips. When you as a Client register an Account to use the iTips software and get our agency services, or sign up for notifications or updates at iTips, or participate in our surveys. We may collect your first name, last name, email address, mobile phone number, gender, age, delivery addresses, billing addresses, social media handles, profile picture or avatar, Tips’ details, interests and preferences, and any other information that you provide to us by the iTips software.

Employment Data. If you receive tips with iTips in the course of an employment, we may collect and process data about when and where you have worked

Information from a third party. If you have entered into an agreement with a Third-party or Employer and use iTips to receive Tips from Customers, etc., so the Third party will transfer your Personal Data to us. In this case, the provider of your Data is responsible for the transfer of your Personal Data to us.

Financial Data. We ask some your financial Data to transfer Tips from a Customer to a Client, such as bank account details; and tokenized payment card details. We don't store and process your credit card details directly, cause it is responsibility of the Third-Party who provide Tip transactions.

Geolocation. We can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections - if you allow it us by Device’s settings. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection.

2.2. Anonymous Data
Some of the Data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some Data that could be considered Personal Data when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your Device, but is instead used in an anonymous way, often aggregated with other anonymous Data about other users.

Information maintained on your Device. When you use the iTips software and when you have enabled such collection in your device settings, we may collect certain information maintained on your Device to help us tailor iTips to you.

Behavioral Data. Data relating to your browsing activity or interaction with our emails, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any products you viewed or purchased through the Site.

Technical Data. Data relating to your Device such as IP-address, browser type and operating system, geolocation, to ensure we're showing you the correct notices and information, any other unique numbers assigned to a device.

2.3. Credit/Debit Card and Payment Account Data
When you use iTips a Payment service that integrated into the iTips and provided by the Third Party, need your credit/debit card number or payment account Data to provide and transfer Tips from a Customer to a Client. So, you must read Privacy Policy of that Payment service before take action for a transaction.
Please, notice that we never publicly disclose any your Personal Data or sensitive data related to financial or payment activities or any government (national) identification numbers. We take all necessary measures to ensure the protection of your data, and iTips meets high security requirements.

2.4. Transaction and experience information
Details about payments made between a Consumer and as the Client’s non-exclusive agent. When you access iTips, for example, to receive money from Customers, to process payments - we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid, Data about your activity from Third Party Providers.

2.5. Children’s Personal Data
Protecting the privacy of young children is especially important. iTips is not directed to children under the age of 18, and we do not knowingly collect Personal Data from them without obtaining parental consent. IF YOU ARE UNDER 18 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE PRODUCT AT ANY TIME OR IN ANY MANNER.
If we learn that Personal Data has been collected from persons under 18 years of age - we will take the appropriate steps to delete this information.

3. How we acquire your Data
3.1. Data you provide us
We mostly receive Personal Data because you provide it to us by iTips or your Device by your permission.

3.2. Data automatically collected
The iTips software may also automatically collect Data about you, your online behavior and your Device if you give that permission. The Data collected may include, without limitation:

• Unique device identifier generated from the device MAC/IMEI/MEID;
• An advertising ID;
• IP address;
• Device manufacturer and model;
• The operating system and version running on your system or device;
• Browser type;
• Language;
• Device Specs and computer specifications;
• Current screen resolution;
• Operating system identifier (e.g., Mac, Windows, etc.);
• A checksum of all the data that gets sent to verify that it did transmit correctly;
• Geographic location of you and/or your Device, as well as date/time stamp;
• Pages visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data.

3.3. Publicly available personal data
From time to time, we may collect Personal Data about you that is contained in publicly available sources (including open-source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).
3.4. Data acquired elsewhere
We and Third Party may also acquire your Personal Data or other Data offline or otherwise outside of the iTips software. For example, Third Party may purchase or otherwise acquire such Data from third party data suppliers. We and Third Party reserve the right to merge or co-mingle this other Data with your Personal Data and Data collected on or through the iTips software. A similar process occurs when you as a Client transfer money to your own bank-account from iTips’ Account that located with a third party by the iTips software.

4. How we use your Data
4.1. Register an Account and access to iTips
You may be required to register an Account with us in order to gain access to certain features and functionality of iTips and/or to receive certain offers, benefits, Tips from Customers. It is necessary for us to use your Personal Data to perform our obligations in accordance with any agreements between us.

4.2. Fulfilment of our services
We collect and maintain Personal Data that submit to us for the purpose of Customers providing Tips and gratuities to our Clients and to ensure that tips are treated in the way our Clients decide, which can include sharing those tips with others. We may collect and process your Personal Data whether you are interacting with us on your own behalf or on behalf of any organization you represent.
We process this Data so that we can fulfil the supply of services as a Client's non-exclusive agent, maintain our user databases and to keep a record of how iTips are being used. If you attend one of our locations, we will process Personal Data about you which you volunteer in connection with your visit and any enquiries you may have. It is necessary for us to use your Personal Data to perform our obligations in accordance with agreements between us, or it is in our legitimate interest, or a third party's legitimate interest.

4.3. Processing your requests for iTips
We use your Data to process your request for iTips. For example, if you write to our support or to Privacy Policy Coordinator, we may use your e-mail address to send you an answer and to give a right decision and recommendation.

4.4. Administering the iTips software
We and Third Party (such as a technical services) also use your Data for any lawful business purpose in connection with administering the iTips software, including without limitation for customer service, to help diagnose problems with servers and the iTips software, to improve iTips that we offer by tailoring them to your needs, to gather broad demographic information, to analyze trends, to seek compatible advertisers, sponsors, clients and customers, and to track users' movements around the iTips software and elsewhere on the web or across apps and devices. Your geographic location Data may specifically be used to show you Content (including advertising and sponsored messaging) based on geographic location by us and Third Party.

4.5. Access by Third Party
We may also allow access to your Data by Third Party Providers that provide us with services, such as market research, community and forums management, auction services, e-commerce, personal/job search and other advertising functionality, but only for the purpose of and to the extent necessary to provide those services. We do it only if you give to us explicit your consent for this access for accessing your Personal Data to specific Third Party.
There are also times when you provide Data to us in areas of the iTips software that may be managed or participated in by one or more Third Party. In that case, the Data may be used by us and by such Third-Party, each pursuant to its own policies. While we may seek to require Third Party to follow appropriate privacy policies and will not authorize them to use your Data except for the express purpose for which it is provided, we don’t accept any responsibility for any actions or policies of third parties.
If we provide your Personal Data to Third Party on our initiative, we will notify you about this third party in any way possible (such as by the iTips software or by e-mail) and ask your permission for it.

4.6. Marketing
Third Party may also use your Data to communicate with you about new features or other products offered by Third Party Providers, our advertisers, and other companies and individuals that defined in clause 8.5 Privacy Policy.

4.7. Legal requests
We and Third Party may also provide access to your Data in order to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We and Third Party may also provide access to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and terms of use.

4.8. Employment opportunities
If you provide your Personal Data to us in connection with an employment inquiry, without limiting the applicability of the rest of this Privacy Policy, we will use your Personal Data to evaluate your job application, and for related recruiting, reporting and recordkeeping purposes. We may maintain your Personal Data on file, whether we hire you or not, to administer your relationship with us and/or for job applicant related reporting and recordkeeping for as long as required or permitted by law.

4.9. Transfer or sale of our business
As our business changes, we may buy or sell various assets owned or controlled by us. In the event all or a portion of the assets are sold, assigned, transferred or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Data may be among the transferred assets like a part of the iTips software. In this case, we will notify you about this at least 30 days in advance.

5. Duration of Data storage
5.1. Personal Data that we process in connection with the supply of iTips, we may retain your personal data for up to six years from the date of receive that Data in compliance with our data protection obligations.
Personal data that we receive with your Account registration, we may retain your personal data for up to six years from the date that the relevant Account is terminated in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
Other Personal data that we receive we may retain for up to three years from the date of our last interaction with you in compliance with our data protect obligations.
When the retention period for Personal Data has expired, we may then delete such files without further notice or liability.

5.2. If any Personal data is only useful for a short period (e.g., for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.

5.3. If you have opted out of receiving marketing communications from us, we will need to retain certain Personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future.

6. Your Data protection rights under General Data Protection Regulation (GDPR)
6.1. If you are from the European Economic Area (EEA), our and Third parties' legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
We and Third parties may process your Data because:

• We and (or) Third parties need to perform an agreement with you;
• You have given us permission to do so;
• The processing is in our legitimate interests and it's not overridden by your rights;
• To comply with the law

6.2. If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We and Third parties aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
If you wish to be informed what Personal Data Third parties hold about you and if you want it to be removed from Third parties' systems, please contact them as described at the Section 11.

In certain circumstances, you have the following data protection rights:
a) Your right of access
If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

b) Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we've shared your personal data with so that you can contact them.

c) Your right to erasure
You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

d) Your right to restrict processing
You can ask us to "block" or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we've shared your personal data with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.

f) Your right to data portability
You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.

e) Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else's legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.

g) Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

h) Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the "How to Contact Us" section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

i) Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the "How to Contact Us" section below. Please note that we may ask you to verify your identity before responding to such requests.

7. Cookies and related technologies; Do Not Track (DNT)
7.1. Cookies
We by the iTips software and iTips’ website will at times place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies (including flash cookies), locally shared objects, and HTML5 (collectively, “Cookies”). We and Third Party Providers may use Cookies in connection with iTips for any lawful business purpose, including without limitation to determine whether you have seen a particular advertisement before on the same or different Device and to otherwise control the display of ads, to track the movements of individual users through the iTips software and elsewhere on the web or across apps, devices, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to deliver editorial content, to record registration and personalize information, and to otherwise administer iTips.

We use the following types of cookies:

• Essential Cookies

Essential cookies are those cookies which a website could not operate without. Essential cookies include cookies such as login cookies and shopping cart cookies.

• Functionality Cookies

These cookies recognize you when you return to a website, remember your preferences and provide enhanced, more personalized features. These cookies also help to provide you with content relevant to your locale, for example allowing you to see the Site in your preferred language

• Security, site and product integrity Cookies

These cookies help keep your account, data and the Site safe and secure. Such cookies can help us identify and impose additional security measures when someone may be attempting to access a Site account without authorization, for instance, by rapidly guessing different passwords. These cookies also store information that allows us to recover your account in the event you have forgotten your password or to require additional authorization if you tell us your account has been hacked.

• Analytics/Performance Cookies

Analytics cookies, along with other information, allow websites to calculate the aggregate number of people using a website and which features of a website are most popular. This information is generally used to improve the website and the way visitors are able to move around it.

• Social Media Cookies

These cookies are used to personalize your interaction with social media, such as Twitter, Facebook, Tumblr and YouTube. Such cookies recognize users of those social media sites when you view social media content on the website. They also allow you to quickly share content across social media, through the use of simple "sharing" buttons. Some websites may also contain features that enable you to use your social media account to sign in and create/maintain an account with the website you are visiting and to enable the website operator to store your content. This involves the use of cookies.

• Targeting Cookies

Targeting cookies (also known as advertising cookies) help us to deliver our adverts when you visit other websites, such as news websites. This is known as 'retargeting'. This technique helps to ensure that the ads you receive are more relevant to you and your interests. These cookies help to measure the effectiveness of an ad (for example, by reporting whether you have clicked on it) and can also limit the number of times that you see an ad (for example, if you see it twice but don't click on it, you may not see it again). These cookies are usually placed by advertising networks that we and other advertisers work with to deliver ads. They remember that you have visited a website and this information is shared with other ad networks to show you relevant ads.

7.2. You may disable Cookies
If you do not want use Cookies, your Device or browser may include an option that allows you to not accept it. However, if you disable Cookies, some portions of iTips may not function properly.

7.3. Tracking Technologies
In addition to Cookies, Third Party may use web beacons, web bugs, internet or pixel tags, clear gifs, digital fingerprinting (aka “Machine Identification”) and similar technologies (collectively, together with Cookies, the “Tracking Technologies”) on iTips and in our communications with you, such as within e-mail and text messages and push notifications. Third Party may use Tracking Technologies to determine which of our messages have been opened by recipients, and for all or some of the same lawful business purposes we describe above for use of Local Device Storage.

7.4. Do Not Track (DNT).
Your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online services that you visit. There is no consensus among industry participants as to what DNT means in this context, and some browsers automatically apply DNT signals by default and therefore do not necessarily reflect our visitors' choice as to whether they wish to receive advertisements tailored to their interests. As a result, like many websites and online services, we do not alter our practices when iTips receives a DNT signal from a visitor's browser. As discussed below, you may opt out of the use of your Data for online behavioral advertising by third parties at any time. To find out more about DNT, please learn http://allaboutdnt.com.

7.5. How Online Behavioral Advertising (OBA) works
We or Third Parties Providers will at times also use Tracking Technologies for purposes of «online behavioral advertising» (OBA). OBA allows the serving of advertisements tailored to interests you have shown by browsing on the iTips software and on other sites, applications, destinations, and services, using the same or a different Device. To enable OBA, these Third-Party use Tracking Technologies to collect Data including for example the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of your Device, as well as date/time stamp, IP address, pages visited, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The use of Tracking Technologies by Third Party Providers is subject to their own privacy policies, not this Privacy Policy, and we have no responsibility or liability in connection therewith. You may visit Third Party Providers' sites and discover their own privacy policies in accordance with paragraph 4.3. this Privacy Policy.
You may stop a collection of location information by managing your settings or turning off location services for your Device, if your Device allows you to do so. Please refer to your Device’s settings or user manual for instructions on how to turn off location services.

7.6. Opt-Out of OBA
If you do not want OBA at all, you may be able to opt-out by visiting http://www.aboutads.info, http://www.networkadvertising.org, http://www.youronlinechoices.com/uk аnd by clicking the “Ad Choices” icon that appears in advertising served through OBA. Please note that the option to opt-out applies only to tracking by Third Party Providers across iTips and other sites, applications, destinations, and services.

8. Sharing Your Data for Marketing; Opt-Out; How to Update Your Data
8.1. Sharing your Data for marketing.
Unless otherwise specified on other legal documents, we may use and share your Data (not Personal Data) for our Third Parties in marketing purpose only if we have your permission.

8.2. How to Opt-Out of sharing for marketing
If you do not wish to have Personal Data such as your date of birth name, email address, location or postal address, phone number shared with third parties for their marketing purposes, contact our Privacy Policy Coordinator as described at the end of this document or make the appropriate selection in the iTips software if it is possible. Note that, in order for us to properly administer the iTips software, we must continue to share your Data with Third Party (if you object to such sharing, you should not use the iTips software). Note also that this option to opt-out applies only to Personal Data, and not anonymous Data.

8.3. How to Opt-Out of marketing messages from us
If you do not wish to receive future marketing or other commercial messages from us or Third parties, simply write to us a request about your decision to terminate receiving marketing messages. Note that you may continue to receive certain communications from Third parties that are necessary for the iTips software, such as renewal notifications, invoices, technical notices, updates, security alerts, and support and administrative service bulletins.

8.4. Links to other websites
iTips may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site or application. We strongly advise you to review the Privacy Policy of every website you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

8.5. Sharing Personal Data
This list is non-exhaustive and there may be circumstances where we need to share personal data with other Third parties:

• Third-party suppliers who provide applications/ functionality, data processing or IT services;
• Payment providers and banks who transfer Tips from Customers to us and transfer Tips from us to Clients;
• Delivery and courier companies;
• Advertising partners;
• Third-party post/email marketing and CRM specialists;
• Third-party suppliers who assist us in administering our promotions;
• Event partners and suppliers;
• Employers you have listed by iTips;
• Recruitment agencies and related companies;
• Auditors, lawyers, accountants and other professional advisers;
• Law enforcement or other government and regulatory agencies and bodies;
• Other third parties.

9. Transfer of your Data among jurisdictions
9.1. We are an EU-based company and iTips complies with legal requirements of the EEA. Your Data may be processed, transferred to, and maintained on, servers and databases located within the European Union, and elsewhere where the privacy laws may not be as protective as your jurisdiction.
We reserve the right to transfer your Data to and from any state, province, country or other governmental jurisdiction.
However, when transferring your personal data outside the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws. When transferring your personal data outside the EEA, we will, where required by applicable law. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the EEA.
Your consent to this Privacy Policy followed by your submission or our collection of such Data represents your agreement to any such transfer.

10. Data Security and Notification
10.1. Security Measures.
We take commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, Personal Data that you share with us.
We process sensitive data (such as credit card or payment account) therefore we take measures to protect your Data and Personal Data such as:
1) We have appointed the person responsible for ensuring the security of Personal Data (Privacy Coordinator);
2) Our documents have been developed for the processing and security of Personal Data;
3) We control over the processing of Personal Data;
4) We have identified actual threats to data security;
5) We have identified methods and means are used that prohibit unauthorized access to personal data;
6) We use of algorithms that are hashing all Data;
7) We use application of encryption of requests and data;
8) We use an authentication when you are accessing the iTips software.

10.2. No liability for breach
Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the Data that you send to us or the security of servers, networks or databases, and by using the iTips software you agree to assume all risk in connection with your Data. We are not responsible for any loss of such Data or the consequences thereof.
If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with iTips, your personal data may be compromised. If that happens, please report it to us.

10.3. Breach notification
In the event that we believe the security of your Personal Data in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you by e-mail, push notification, or otherwise.

11. Privacy Policy Coordinator
11.1. Our Privacy Policy Coordinator
If you have any concerns or questions about any aspect of this policy, please feel free to contact our Privacy Policy Coordinator as follows:

Ekaterina Kochneva
25 Martiou, 27, D. MICHAEL TOWER, Flat/Office 105A, Egkomi, Nicosia, Cyprus
info@itips.ai

If you wish to exercise this right, please contact our Privacy Policy Coordinator and state which of these items you wish to opt-out of sharing with third parties. Also, as discussed above, if you have registered the Account and you wish to update or make changes to your Personal Data on file with us, you may contact our Privacy Policy Coordinator too.

11.2. Privacy Policy of Third Party
You can research privacy policies of Third Parties by their web-sites.

Note: Only inquiries about this policy or your Personal Data should be sent to the Privacy Policy Coordinator. No other communications will be accepted or responded to.

For communications on other matters, please contact us through the means described on the iTips software, if available (for example, in the “Contact Us” section). ***

If you don't agree to the terms contained in this Privacy Policy, so you must immediately exit iTips and delete all iTips’ information from your device, and you prohibited to use the iTips software.