Privacy Policy 

Valid from __.__.2020

This Privacy Policy describes the general principles on how Surge Socials  (registry code 16487719) address Harju maakond, Tallinn, Kristiine linnaosa, Keemia tn 4, 10616, Estoniahereinafter Surge Socials processes Users’ Personal Data and is applicable to any person who uses, has used or has expressed intent to use the Services of  Surge Socials. Surge Socials is responsible for Processing your Personal Data. All of the definitions used in and all circumstances not covered by this Privacy Policy shall be regulated by the Terms and & Conditions of  Surge Socials and/or Regulation (EU) 2016/679.

Please read this Privacy Policy before using the Site and/or Services or submitting your Personal Data.  

Here you can find the meanings of the most important terms in this Privacy Policy to help you understand who and for what we are Processing your Personal Data.

• Agreement - service agreement concluded with the Merchant, i.e. our client.
• Cookie(s) - small pieces of information stored by the Visitor’s browser on the hard disk of the computer of any other device of the Visitor.
• Personal Data - means any information whichSurge Socials  directly relates to you (a legal or natural person or an organization legally engaged in business activities or any other business). In particular by reference to an identifier such as a name, date of birth, contact information, location data, an online identifier etc. Processing may be done manually or using automated systems.
• Privacy Policy - this privacy policy.
• Processing means any operation carried out with Personal Data (collection, recording, storing etc.).
• Visitor - is any person using the Services of Surge Socials
• Website - surgesocials.com.

By agreeing to this Agreement or using the Services and/or the Website, you agree that the [company name] will use, disclose and process your personal information in accordance with this Privacy Policy:

1. Surge Socials Terms of Service and present Privacy Policy applies to communication between you and  Surge Socials (incl. emails, phone calls, etc.) and to your use of the Website and Services and establishes the policy on which Personal Data will be processed by Surge Socials.
2. Surge Socials may process any information submitted, shared or exchanged to provide the Services.  Surge Socials collects information by email, phone calls or by questionnaire or any other means. Some information may also be collected via automatic means, e.g. Cookies.  Surge Socials may also collect information from third parties. Surge Socials  shall do all that is reasonably possible to ensure the confidentiality of the Personal Data that Surge Socials has collected.
3. Surge Socials processes Personal Data only if it has your consent to do so, or if it is necessary for providing you the Services, or  Surge Socials has the legitimate interest to do so, or if it is required by applicable legislation.
4. Surge Socials mainly processes data to comply with applicable laws, regulations and instructions, to manage the relationship between  Surge Socials and you, to provide additional Services, to prevent illegal activities and misuse of the Service and Website, to ensure to quality of the Service and Website, etc.
5. You are required to provide your real name, address, nationality, telephone number, e-mail address, as well as other information as required by applicable laws and regulations. You can also choose to fill in additional information. By providing the previously mentioned information you understand and agree to that  Surge Socials, will access your Personal Data (including but not limited to mobile phones, electronic mail, etc.) to send you relevant notices and other commercial electronic information to provide you with new Services and opportunities.  Surge Socials will not share your Personal Data without your previous consent unless, we are legally obliged to.
6. Surge Socials collects some of the information automatically. Information that is collected automatically is associated with your use of the Services and/or the Website.  Surge Socials may collect information (incl. IP address, operating system, browser ID, location, language settings, demographic information, Personal information, and other information about the interaction of you and the Website) about your usage or the Service and/or the Website.  Surge Socials may use authorised processors and Services provided by third parties to collect and process data.
7. In order to ensure the safety of your use of the Services and the Website and to continuously improve the quality of service, Surge Socials  will record and keep
    information about your login and use of the Service and the Website, but  Surge Socialsundertakes not to provide such information to any third party (unless otherwise agreed upon by both parties, or other laws and regulations).
8. Surge Socials will keep tight security of all the complete comprehensive statistics regarding identity data of  Surge Socials users and will not use and/or disclose them for sale and reward. Surge Socials  reserves the right to transmit the Personal Data to law enforcement institutions, state authorities and financial institutions if it should be required to comply with valid laws. 

Surge Socials only processes your Personal Data on your consent, if there is a legitimate interest to process data or if it is required by valid legislation. In order to provide you with a more efficient service, you agree that  Surge Socials shall have the right to provide your registered information which you have furnished to Surge Socials  in the course of your registration and use of the Service. At the same time, Surge Socials reserves the right to require you to submit identity information (including but not limited to identity card, bank account book, passports, and other certificates or other documents). Except as otherwise provided in Terms of Service or present Privacy Policy,  Surge Socials does not disclose or provide your information to third parties except in the following cases:

1. with your explicit authorization;
2. only to disclose your Personal Data in order to provide you with required products and/or Services;
3. disclosure in accordance with the requirements of this Privacy Policy;
4. according to the provisions of applicable laws and regulations;
5. in accordance with the instruction and requirements of applicable laws
    and Authorities etc;
6. for the maintenance of [company name] legitimate rights and interests;
7. to verify the authenticity of the identity of you or your representative company.

We shall store your Personal Data for as long as required by law or in accordance with the law, or for the purposes stated in this Privacy Policy. Your Personal Data will be processed no longer than necessary. The retention period of your Personal Data may be based on the applicable law (e.g. Money Laundering and Terrorist Financing Prevention Act, etc.) or legitimate interest of [company name] or Agreements signed between you and  Surge Socials.

After the expiration of the Personal Data storage period, we shall anonymize or permanently erase your Personal Data.

Cookies are small files text files placed on your device when you visit a Website. We use Cookies on our Website, that you can accept if you choose to use our Website.  Surge Socials places on your device only a session-ID cookie. The cookie is used to ensure that the source of a request to a server is the same as the one through which log-in occurred. Cookies allow us to recognize whether you have used the Service before and it helps us to store your preferences and other information.

Most of the web browsers allow Cookies. Without fully allowing Cookies, not all of the functions of the Website are available to a Visitor. The allowing or prohibiting Cookies and other similar technologies shall be under the control of a Visitor via the settings of the Visitor’s own web browser. Most browsers allow you to control cookies, including turn off their acceptance by your device, through their settings’ preferences. However, if you turn off the ability of your device to accept cookies, you may lose access to this Website and the Services provided via it.

If you prefer that your Personal Data will not be Processed on our Website, you can activate the private browsing feature of your web browser. 

If you access this Website without changing your browser settings, Surge Socials  will assume that you agree to receive the cookies whichSurge Socials or third parties place into your device when you use this Website.

If you have any questions or comments about this Privacy Policy, or if you would like to review, delete or update information we have about you or your preferences, please contact us at the following address:  business@surgesocials.com