Privacy Policy

This Privacy Policy provides an overview of all information regarding the processing of personal data by Ptolemay LLC, a company registered under the laws of the State of California, at 340 S Lemon Ave #9750, Walnut 91789 CA, US, hereafter referred to as Ptolemay, we or us.

Ptolemay is strongly committed to protecting your privacy and complying with your choices. You will be in full control of all data relating to yourself. Both personal and non-personal data and information collected is safeguarded according to the highest privacy and data protection standards adopted worldwide. We strive to make you feel safe when we collect or share your data and therefore, we want to be transparent on how we collect, use, share and store the information about you and the choices available to you as data subject.

By visiting the website or using our the Ptolemay services (the “Services”), you are accepting the practices described in this Privacy Policy to the extent permitted by law. We process your personal data in compliance with the California Consumer Privacy Act 2018 (CCPA).

We reserve the right to make changes to this Privacy Policy at any time. We will notify you when updates are made to give you an opportunity to withdraw previously given consent or to deny further use of your data. We may have to update the Privacy Policy in case of new developments, activities, online services or when applicable legislation changes.

Categories of personal data collected

The personal information that Ptolemay collects, or has collected from consumers in the twelve months prior to the effective date of this Privacy Policy, fall into the following categories established by the CCPA.

  • identifiers such as your name, alias, email address, phone numbers, or IP address;
  • personal information, such as a credit card number;
  • internet or other electronic network activity information, including content interaction information, browsing history, and search history; and
  • professional information, for example data related to your company and the information shared with Ptolemay under any agreement for services.

Use of Personal Information

We obtain information about you through the means discussed below through our Services or our Website. Certain types of information are necessary for us to provide the Services to you. For example, you are required to provide information including your name, email address, mailing address, telephone number, credit card number, and billing information when you contract with us for the performance of Services or otherwise use the features of the website.

  1. To process payments

Given the nature of our business, we establish contractual relationships with our clients, and we need to be able to perform our legal obligations under the applicable terms and conditions. We process your personal data to execute a payment by or to you, as well as for administrative purposes. We process personal data for this purpose based on our contract with you and our legitimate interest. Our legitimate interest in processing your data stems from our intention to comply with applicable law. For this purpose, we process your contact details such as your address, telephone number and e-mail address, personal data such as name and payment and credit information.

  1. To offer you the functionalities of the Website and for the technical and functional management thereof

When you access the website, we automatically record and store certain information about your system by using Cookies and other similar technologies. Cookies are small text files containing a string of alphanumeric characters that are sent to your browser. Cookies automatically collect information such as the Internet Protocol Address (“IP Address”), a unique user ID, device and browser types and identifiers, referring and exit page addresses, software and system type, and information about your usage of the website. Upon visiting our website, you will be prompted to consent to the use of Cookies. For this purpose, we process all personal data that you have entered on our website or that is generated by the use of our Cookies.

  1. For answering your questions and handling complaints

If you contact us at our office or through a contact form on our website, we will use your personal information to answer your question or to handle a complaint. We process your personal data based on consent and legitimate interest. Where possible, we will ask for you consent before you contact us, such as through the contact form. In any other case, our legitimate interest is formed by our intention to handle your complaints and questions carefully in order to properly run and improve our business. For this purpose, we process your name, contact details, your correspondence with us about your question or complaint and all other personal information that is required to answer your question or handle your specific query and/or complaint.

  1. For relationship management and marketing

We use the information in the contractual relationships database to provide customer service and marketing services. We also use your personal data for the development, execution and analysis of market research and marketing strategies. We may use your email address and/or telephone number to communicate with you, including notifying you of major Services updates, or for customer service purposes. We may occasionally send promotional materials or notifications to you related to the Website Services. We process your personal data for this purpose based on your consent. You can withdraw your consent at any time, without this having consequence for the lawfulness of processing based on permission before withdrawal. For this purpose, we process your contact details such as your address and e-mail address and personal details such as your name, contact preferences, payment information, order history and correspondence with us.

Retention

Ptolemay maintains data related to your usage of Ptolemay for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required (or permitted) by law such as for tax and accounting purposes, or as otherwise communicated to you. In any case, we will not retain your data for longer than 10 years. Once you have asked us to delete your personal information, we will delete all information that we are not required or permitted to retain by law.

Cookies

Ptolemay uses cookies on the website. A cookie is a small and simple file that can be stored on the hard drive of a computer. The cookies from Ptolemay are only temporary, not permanent.

  • Functional Cookies

Ptolemay uses a cookie to see whether a visitor to our website accepts the cookies on our website or not. This functional cookie registers your consent. The functional cookies used by Ptolemay are session and storage cookies.

  • Analytics Cookies

Analytics cookies are used by Ptolemay to collect information about how our visitors use the website. Our website keeps visitor records and metrics, such as most visited pages. This allows Ptolemay to optimize the layout of its website(s). To this end, we use Google Analytics, and we use this data to improve our website(s), to compile statistics, and to measure the popularity of different aspects of our website(s). Ptolemay uses this data in an aggregated form and therefore this cannot be traced back to any computer or individual. To prevent this from happening, you can install the ‘Google Analytics Opt-out Browser Add-on’ to prevent our websites from informing Google Analytics about your visits.

Overview of cookies:

Cookie Name

Type

Description

Owner

Expiry

_ga

Analytical

To distinguish users

Google

2 years

_gat_gtag_UA_187043082_1

Analytical

 

Google

 

_gid

Analytical

To distinguish users

Google

24 hours

_ym_d

Functional

To store first visit

Yandex Metrica

1 year

_ym_isad

Functional

 

Yandex Metrica

24 hours

_ym_mp2_substs_73518226

 

 

 

 

_ym_mp2_track_73518226

 

 

 

 

_ym_uid

Functional

 

Yandex Metrica

2 years

_ym_visorc

 

 

 

 

metrika_enabled

 

 

 

 

quform_session_

 

 

 

 

i

Functional

Differentiates users

Yandex.ru

1 year

yandexuid

Analytical

Internal analysis and website optimization

Yandex.ru

1 year

ymex

Analytical

 

Yandex.ru

1 year

yuidss

Analytical

Collects information on visitor behaviour on multiple websites. This information is used on the website to optimise the relevance of advertisement.

Yandex.ru

1 year

 

You can set your browser to inform you as soon as you receive a cookie or to deactivate cookies. This might mean that our Website may not function optimally.

We give you the possibility to give your consent to the use of cookies when you first access the Website. If you, at a later point in time, wish to disable these cookies, you can follow the instructions below.

Here we offer some specific information about cookies for the most commonly used browsers, and more specifically, how to disable these:

Cookies and Internet Explorer, see: https://privacy.microsoft.com/en-us/privacy#maincookiessimilartechnologiesmodule

Cookies and Firefox, see: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Cookies and Google Chrome, see: https://policies.google.com/technologies/managing?hl=en

Cookies and Safari, see: https://www.apple.com/legal/privacy/en-ww/cookies/

Cookies and Opera, see: https://help.opera.com/en/latest/web-preferences/

When We Disclose Personal Information

We take every effort to protect your personal data and has taken the necessary steps to this end. Our employees may have access to personal data, but only to the extent necessary to properly perform their individual tasks. We further only share personal information with third parties if it is necessary to serve the applicable purpose as set out above. When a third party processes your personal data, this is only possible according to the instructions given by us. They therefore act as our data processor. In all cases, we will ensure that third parties with access to your personal information have implemented appropriate technical and organizational measures to maintain our intended level of privacy and security. We conclude the necessary agreement with the data processor(s), whereby we include obligations to ensure that your personal data is only processed so that the data processor can fulfil his duty to provide services to us.

Under these conditions, we share such information as described below:

  • We disclose personal information to service providers working on our behalf, including to provide website hosting, maintenance, and security services; offer certain functionality; or assist Ptolemay in improving the website services and creating new services/features.
  • Information regarding your purchases and payments is shared with billing and payment processing services, fraud detection and prevention services, accounting and financial advisors.
  • We may disclose user information if we believe in good faith that such disclosure is necessary to comply with U.S. state and federal laws or other applicable laws around the world, or to respond to a court order, judicial or other government request, subpoena, or warrant in the legally required manner.
  • We reserve the right to disclose information that we believe, in good faith, is appropriate or necessary to protect Ptolemay from fraudulent or unlawful usage, investigate and defend ourselves against third-party claims or allegations, protect the security and integrity of Ptolemay, or to protect the rights, property or safety of Ptolemay and our users.

Other than as set out in this Privacy Policy, you will receive notice when personal information about you might be shared with third parties and you will have the opportunity to choose not to share this information.

In all other cases, your personal information will not be provided to third parties, unless required by law. We will never sell your personal data.

Third-Party Services and Websites

Our website may link to third-party websites or services. The privacy practices of those third parties are not governed by this Privacy Policy. You are encouraged to review the privacy policies of the third-party websites and services to better understand their practices.

Data Security

Ptolemay uses a variety of technical and physical measures to protect the integrity and security of your information. We value the protection of your privacy. As such, we ensure that the personal data is only ever accessible to those specific persons who are authorized based on their function, and therefore only used for the intended purpose as set out above. In addition, we have implemented measures to guarantee your safe visit to and use of our website, in order to prevent misuse of your data. These measures include computer security and protected files and facilities. We have also ensured that your connection to our website is safe by activating Secure Socket Layer (SSL). The server is protected by a firewall, and we use digitalocean.com as a VPS provider.

We have furthermore taken the necessary technical and organizational measures to prevent, identify, report, and deal with data protection breaches. However, no security precautions can be completely secure. We cannot ensure or warrant the security of any information you transmit to Ptolemay, and you transmit this information at your own risk. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical or technical safeguards.

Children’s Privacy

IF YOU ARE UNDER 13 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS OUR WEBISTE SERVICES AT ANY TIME OR IN ANY MANNER.

We are committed to protecting the privacy of young children, and for that reason Ptolemay does not knowingly collect or maintain personal information from persons under 13 years of age. If we learn that personal information of persons under 13 has been collected on or through our website and/or Services, we will take all available steps to delete this information.

If you are the parent/legal guardian of a child under 13 who has become a user on our website, please contact us to have the child’s personal information deleted.

Merger or Sale

In the event that Ptolemay, or some or all of the assets related to the website and/or the Services are acquired or merged with a third-party entity or in connection with a contemplated change of ownership transaction, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from users as part of that merger, acquisition, sale, or other change of control event, including in the course of diligence.

International Data Transfers

Information collected by Ptolemay may be stored and processed in your region, in the United States, or in any other country where Ptolemay or its affiliates, subsidiaries, partners, or service providers are located or maintain facilities. If we provide any information about you to any such entities, we will take all appropriate measures to ensure such companies provide adequate protection for your personal information in accordance with this Privacy Policy and applicable law. Notwithstanding the location where your personal data is processed, we will adhere to the CCPA provisions and the local privacy regulations that may be in force.

Your rights

California’s “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge. However, we do not disclose personal data protected under the “Shine the Light” law to third parties for their own direct marketing purposes.

The California Consumer Privacy Act (“CCPA”) provides our users who are California residents the following additional rights:

  1. Right to Know: You have the right to request that we disclose certain information to you about the personal data we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:
  • The categories of personal data collected about you;
  • The categories of sources from which we collected your personal data;
  • The categories of personal data that we have sold or disclosed about you for a business purpose;
  • The categories of third parties to whom your personal data was sold or disclosed for a business purpose;
  • Our business or commercial purpose for collecting or selling your personal data; and
  • The specific pieces of personal data we have collected about you.
  1. Data Portability: You have the right to request a copy of personal data we have collected and maintained about you in the past 12 months.
  2. Right to Deletion: You have the right to request that we delete the personal data we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your personal data, we may deny your request or may retain certain elements of your personal data if it is necessary for us or our service providers.
  3. Right to Opt-Out/In: You have the right to opt-out of the sale of your personal data. You also have the right to opt-in to the sale of personal data. However, we do not sell your personal data.
  4. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

To exercise your California privacy rights described above, please submit a verifiable request to us by emailing Ptolemay.

Only you or, if you are applying under the CCPA, a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes and Updates to this Privacy Policy

Ptolemay reserves the right to change, modify, add or remove parts of this Privacy Policy at any time. You will be notified of major changes. Please check this Privacy Policy periodically for any such changes. Your continued use of the website and/or the Ptolemay services after the posting of any changes constitutes your binding acceptance of such changes.

Contact Information

Please contact Ptolemay with any questions or comments about this Privacy Policy by email at privacy_policy@ptolemay.com. We will respond to your inquiry within 90 days of this receipt.