Privacy Policy

1. INTRODUCTION

Thank you for choosing IQ TESTER ("the Supplier", "we", "us", "our"). We are delighted to introduce our IQ certification system to you for the first time. However, in order to provide you with services that live up to your expectations, we will ask you to provide us with some personal information if you decide to buy something from us or register on our website.

2. By registering on our website https://my-iq-tester.com and creating your own personal profile and/or purchasing any services from us, you will be asked to familiarize yourself with and consent to the following rules governing how we use and process your personal information. Please read this Privacy Policy carefully before expressing your consent. If after thorough examination of this Privacy Policy you find provisions with which you do not agree, please do not use our services or purchase from us.

3. The purpose of this Privacy Policy is to regulate the principles and procedures for the collection, processing and storage of users' personal information, as well as to establish users' rights, and the regulation of other related matters.

4. The terms of this Privacy Policy, as well as the data processing practices we use, are set forth in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 regarding the General Data Protection Regulation, the Federal Trade Commission Act (15 U.S.C. §§41-58) and the Children's Online Privacy Protection Act (COPPA) (15 U.S.C. §§6501- 6506). However, some of the provisions listed in this Privacy Policy, as well as the rights and obligations established by applicable law, may apply differently to residents of member countries of the European Union, the United States of America, or other countries.

5. We would like to inform you that information regarding your main rights and how to exercise them can be found in the following sections of this Privacy Policy:

-Right to be forgotten (Clause 7.6)

-Right to receive your personal information (Clause 7.2 and 7.3) o Right to object to the processing of personal information (Clause 7.4)

-Cookie policy (Clause 9)

-Right to be informed about information leaks (Clause 12).

6. If you have any questions about the provisions of this Privacy Policy, or want to inquire about how we handle your personal information, please write to our support team ([email protected]) and we will do our best to respond to you as soon as possible.

TERMS USED IN THIS PRIVACY POLICY

1. Unless the context indicates otherwise, the terms specified below shall have the meanings indicated:

Data controller IQ TESTER - contact e-mail: [email protected]; website: https://my-iq-tester.com

Privacy Policy - means these privacy policy rules governing the use of personal information and the security procedures to which the Data Controller adheres when performing any activity relating to the use, control, transfer, etc. of any information deemed personal.

Personal information - means any information relating to a natural person that enables that person to be identified, directly or indirectly, in particular by reference to an identifier such as that natural person's name, identification number, location information, online identifier or social identity.

Processing - means any operation or set of operations performed on Personal information, such as: collecting, recording, organizing, storing, classifying, grouping, combining, altering (supplementing or correcting), transferring, publishing, using, logical and/or arithmetic operations, searching, disseminating, destroying or any other operation or set of operations.

Data Processor - means a natural or legal person, public authority, agency or any other entity that processes Personal Information on behalf of the Data Controller.

Characterization - means any form of automated processing of Personal Information consisting of the use of Personal Information to evaluate certain personal aspects relating to a natural person.

Consent - means freely given, voluntary indication that the Data Subject accepts this Privacy Policy and provides permission to the Data Controller to Process, Characterize and/or use the Data Subject's Personal Information in other ways as described in this Privacy Policy.

Direct marketing - means the activity of offering goods or services to Data Subjects by e-mail, mail, telephone or any other means of direct contact.

Services - means recreational services, consisting of various IQ tests, vision tests, reaction tests, mathematical tests or other similar tests that are specifically designed to determine Data Subjects' IQ or other cognitive abilities provided by the Data Controller.

Cookies - means small files that collect and store information as described in this Privacy Policy. Cookies are downloaded to a Data Subject's computer only if the Data Subject has provided his or her Consent regarding the use of cookies.

Data Subject - means a natural person who uses the Website and/or purchases Services from the Data Controller. Website - means an internet site whose address is https://xxxxx.com .

Profile - means an individually prepared profile of a Stakeholder's Personal Information, accessible through a special link on the Website.

Third Party - means the natural or legal person who has the authorization to perform any Processing action by the Data Controller, pursuant to a service contract signed between the Third Party and the Data Controller. Specifically, this Third Party may provide legal, accounting, hosting or other services, which would require the communication of any Personal Information to the service provider.

3. GENERAL PROVISIONS

IQ TESTER only processes Personal Information provided by the Data Subject in order to provide the Services and to execute all payment procedures for the Services. IQ TESTER does not collect any Personal Information without the prior Consent of the Data Subject.

IQ TESTER processes Personal Information only for the following purposes:

1. Provide Services to Data Subjects under the IQ TESTER Terms of Service

2. To make the content of the Website more relevant to the Stakeholder by ensuring smooth operation of the Website (through the use of Cookies).

3. For the fulfillment of the duties of the Data Processor requested by the legislation.

4. To contact the Interested Party for the purpose of direct marketing;

3. IQ TESTER processes Personal Information only if at least one of the following conditions is met:

1. If the Stakeholder is purchasing any type of Services or goods from IQ TESTER or

2. the Data Subject has expressed his or her Consent in relation to the Processing of his or her Personal Information; or

3. the Processing of Personal Information is mandatory by the applicable legislation for the Data Processor.

4. IQ TESTER processes Personal Information in accordance with the following data processing principles:

1. Personal Information should be collected only for legitimate purposes and as defined in this Privacy Policy.

2. Personal Information must be processed accurately and conscientiously.

3. Personal Information must be constantly updated.

4. Personal Information should not be stored longer than necessary.

5. Personal Information should only be processed by employees and Third Parties who are fully aware of the provisions of this Privacy Policy and are properly authorized by the Data Processor.

6. The Personal Information of the Data Subjects must be considered confidential and the Data Processor must protect it against illegitimate use.

4. PROCESSING OF PERSONAL INFORMATION

IQ TESTER processes Personal Information by manual and automated means.

2. For the purposes defined in this Privacy Policy, IQ TESTER will collect, store and Process only the following Personal Information:

1. Name and surname.

2. E-mail address.

3. Address.

4. Telephone number.

5. Profile picture, if the Interested Party wants to publish it. 5. History of tests performed and the results.

3. IQ TESTER receives and collects Personal Information in the following ways:

1. Directly from Data Subjects, when they provide information during their registration on the website or when making their first purchase.

2. Directly from Data Subjects, when Personal Information is captured in Cookies used on the Website.

4. IQ TESTER processes only such Personal Information that is necessary for the Processing in order to provide Services and to carry out the obligations imposed by this Privacy Policy and applicable law. The list of Personal Information specified in Clause 4.2 of this Privacy Policy is an exhaustive list of all Personal Information processed by IQ TESTER, however in individual cases IQ TESTER may choose to Process less Personal Information of a particular Data Subject.

5. IQ TESTER processes Personal Information only as necessary to carry out its obligations to the Data Subject, in accordance with the Terms of Service or with the Consent of the Data Subject.

6. IQ TESTER does not Process any Personal Information from Data Subjects who are under the age of 18. Data Subjects under the age of 18 may use the Services and provide their Personal Information to the Data Processor only with a written and electronically signed Consent from their parent or guardian.

5. PERSONAL INFORMATION AND THIRD PARTIES

IQ TESTER does not exchange or share any Personal Information with Third Parties that are not based in any member state of the European Union, except those Third Parties that are not based in the European Union but carry out their activities in the European Union and fully comply with the requirements of the EU General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).

IQ TESTER transfers Personal Information for Processing only to those Data Processors or Third Parties that are authorized to provide services to IQ TESTER by a contract signed between the service provider and IQ TESTER. In all cases, when transferring Personal Information to Third Parties, IQ TESTER will ensure that the Data Processor or any other party receiving the Personal Information is able to ensure adequate protection of the Personal Information according to the requirements of applicable law.

3. IQ TESTER transfers Personal Information only to the extent to the minimum extent necessary to perform the obligations set forth in the service agreements between the Data Processor and IQ TESTER.

4. IQ TESTER does not transfer any Personal Information to any Data Processor or Third Party with whom IQ TESTER has not entered into an agreement covering the provisions relating to the Secure Processing of Personal Information under this Privacy Policy.

5. IQ TESTER may transfer Personal Information to the following groups of Data Processors or Third Parties:

1. Payment processing parties (banks, electronic payment processors, etc.).

2. Service providers (server hosting, software development support, data analysts, marketing specialists).

3. Administrative service providers (lawyers, accountants).

4. Authorities which have the right to receive Personal Information by law, and which have provided an issued and valid document in accordance with the procedures established by the laws of the Republic of Lithuania, which undoubtedly confirms the right of the recipient of the information to collect and Process Personal Information.

6. TERMS FOR THE STORAGE OF PERSONAL INFORMATION

1. IQ TESTER stores and processes Personal Information while:

1. The Interested Party is using the Services provided by Lúdico Business and Entertainment, S.L.

IQ TESTER may exercise its rights or obligations for which the Personal Information is necessary.

3. The Consent of the Stakeholder is valid and has not been cancelled by the Stakeholder.

2. In other cases Personal Information may be stored and Processed for a maximum of 24 months after the last purchase of Services or the Stakeholder's activity on the Website cancellation of Consent. If the specific Data Subject's Personal Information becomes irrelevant to IQ TESTER before the 24-month period specified in this Clause, IQ TESTER may delete the Personal Information before the end of the 24-month period.

If the Data Subject requests that IQ TESTER permanently delete all Personal Information provided to IQ TESTER (right to be forgotten), this request must be complied with within 20 days of receipt and IQ TESTER must delete all Personal Information of the Data Subject who provided the request. However, IQ TESTER may stop the execution of such request or refuse to permanently delete all Personal Information if the Personal Information subject to the deletion request is necessary for IQ TESTER to exercise its rights or obligations imposed by law.

4. Non-personalized and aggregated Personal Information, i.e., data that does not allow to identify a specific Stakeholder, as well as other information that cannot be linked to a specific person, may be stored for statistical purposes in IQ TESTER's database for an indefinite period of time, depending on IQ TESTER's needs.

7. RIGHTS OF DATA SUBJECTS

1. Data Subjects possess the following rights:

Receive complete information about Personal Information Processed by IQ TESTER.

Receive in a customary computer-readable format all copies of the Personal Information that you have provided to IQ TESTER.

3. Request amendment, deletion or limitation of the scope of Personal Information Processed by IQ TESTER.

4. Require the cessation of all Processing actions involving the Personal Information of the Data Subject.

5. Cancel your Consent to the Processing of Personal Information.

6. Demand the permanent deletion of all Personal Information Processed by IQ TESTER (right to be forgotten).

2. The Data Subject shall have the right at any time to ask IQ TESTER about the Personal Information of the Data Subject that is being processed. Upon the Stakeholder's request, IQ TESTER will, by mail or e-mail, within 20 calendar days thereafter, provide the Stakeholder with the requested Personal Information in IQ TESTER's possession.

3. The Data Subject, when exercising his or her right to receive all Personal Information provided to IQ TESTER, shall receive the Personal Information in a widely used, regular and systematized computer-readable format (png). This data must be provided to the Data Subject free of charge once every 6 months. If the Data Subject requests information more frequently, this request may be subject to additional charges.

4. The Data Subject shall have the right to demand rectification of his or her false, incomplete and/or inaccurate Personal Information and/or to suspend the Processing of such data, provided that the Data Subject determines that his or her Personal Information is false, incomplete and/or inaccurate and the Data Subject is unable to rectify such information himself or herself, or if he or she determines that the Personal Information is being processed unlawfully and not in good faith.

5. The Data Subject shall have the right to object to the Processing of Personal Information for the purpose of direct marketing. The right to object may be exercised by notifying IQ TESTER by e-mail or in the preferences of the Data Subject's Profile.

6. The Data Subject has the right to object to the processing of Personal Information and/or request the erasure of Personal Information (right to be forgotten). Upon receipt of the Data Subject's request for deletion of all Personal Information, IQ TESTER will destroy within 20 calendar days all of the Data Subject's Personal Information and delete the Data Subject's Profile on the Website.

7. IQ TESTER has the right to refuse to comply with a request for erasure of Personal Information by the Data Subject, or restriction of the Processing of Personal Information, if it is unable to terminate the Processing of Personal Information and erase Personal Information due to obligations established by applicable law or due to legal instructions from the relevant authorities.

8. The Data Subject may exercise all of his or her rights set forth in these Rules by notifying IQ TESTER by regular mail or by e-mail (by post: Calle O'Donnell, 16, 28009, Madrid, Spain; or by e-mail: [email protected]). The Data Subject must provide a copy of his or her personal identification document with his or her request, which will enable IQ TESTER to identify the Data Subject. If the Stakeholder does not provide his/her personal identification document, IQ TESTER may refuse to consider the request. In some cases, requests may be denied if the Personal Information cannot be erased or its Processing stopped due to IQ TESTER's legitimate interests and/or specific obligations imposed on IQ TESTER by applicable law.

9. IQ TESTER shall ensure all other rights, guarantees and interests of the Stakeholders provided by applicable laws.

10. The rights of Stakeholders specified in Sections 7.2 and 7.3 of this Privacy Policy are only applicable to users residing in the European Union or using the Services while logged in from any European Union country.

8. DIRECT MARKETING

1. IQ TESTER may use the Stakeholder's email address and telephone number for direct marketing in the form of informational emails and newsletters.

2. The Data Subject may restrict the use of Personal Information for direct marketing by withdrawing his or her Consent to the use of Personal Information for direct marketing at any time. IQ TESTER will stop using Personal Information for direct marketing immediately upon receipt of the withdrawal of Consent by the Data Subject.

9. COOKIES

IQ TESTER uses cookies on the Website. Cookies are used to improve the functionality of the Website and to optimize the activities of the Website, tailoring it to the needs and interests of Users and Stakeholders.

2. The Data Subject has the right to object to the use of cookies on his or her computer, phone, tablet or any other device. The Data Subject may at any time disable the use of cookies by deleting all cookies from his or her browser and refusing to give his or her Consent to the use of cookies if asked again. If the Interested Party does not agree to the use of cookies, some of the functions of the Website may no longer work properly.

3. IQ TESTER uses the following cookies:

1. Account-related cookies. If the Stakeholder creates an account or Profile on the Website, then IQ TESTER will use cookies for the management of the registration process and general administration. These cookies will normally be deleted when the Stakeholder logs off. However, in some cases, they may remain after that to remember your site preferences when you log out.

2. Cookies related to login. IQ TESTER uses cookies when you are logged in, so that the Website can remember this fact. This prevents the Data Subject from having to re-enter the login details each time he/she visits the Website. These cookies are usually deleted or cleared when the Stakeholder logs out to ensure that features and areas can only be accessed when logged in.

3. Cookies related to order processing. The IQ TESTER Website offers payment or e-commerce facilities and some cookies are essential to ensure that your order is remembered as you move from page to page, so that IQ TESTER can process it properly.

4. Form-related cookies. In order to provide an excellent experience for Stakeholders on the Website, IQ TESTER provides the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be retrieved whenever your preferences affect your interaction with a page.

4. IQ TESTER may use cookies provided by Trusted Third Parties to collect and transfer Personal Information. IQ TESTER uses Third Party cookies of the following type:

1. Google Analytics - this cookie is an analytics solution to help IQ TESTER understand how users of the Website use the Website and ways in which IQ TESTER could improve the user experience.

2. Google AdSense - this cookie is used to serve advertisements with higher relevance to the Stakeholder across the website and limit the number of times an advertisement is shown to the Stakeholder.

3. Affiliate tracking cookies that allow IQ TESTER to see if a customer has come to the website through one of its affiliate partners' websites or links.

4. OPEND advertising technology cookies - these cookies allow targeted advertising communications to be sent to Stakeholders. However, no Personal Information is transferred through cookies that would allow a specific Stakeholder to be identified as an individual.

10. PERSONAL INFORMATION PROTECTION IMPLEMENTATION MEASURES

IQ TESTER implements appropriate organizational and technical measures to protect Personal Information from destruction, alteration, disclosure or any other unlawful, accidental or unlawful processing. To ensure the protection of Personal Information, IQ TESTER implements or attempts to implement the following Personal Information protection measures:

Administrative (secure processing of documents and computer data and their archiving, as well as regularization of work organization for different areas of activity, training employees in the requirements of Personal Information security before and after their employment or in similar relations, etc.).

Hardware and software security (administration of servers, information systems and databases, maintenance of IQ TESTER's work areas and offices, maintenance of security standards for the servers where the databases are hosted, etc.).

3. Communications and computer network protection (use of common information, software, firewalls) and etc.

IQ TESTER stores all Personal Information on Google Cloud Storage data storage servers, or other secure remote servers. IQ TESTER ensures that security of the remote server where the Personal Information is stored is ensured by the following measures:

1. Access to the data cache where the Personal Information is stored is accessible through the use of two-factor authentication technologies, where the person logging in has to submit their unique password and additionally confirm their identity using another device attributed to them (e.g., with electronic signature). Access to server information is only granted to IQ TESTER employees or authorized persons.

1. All Personal Information stored on servers or data storage devices is encrypted.

2. Back-up copies of Personal Information are made periodically, every 24 hours.

3. The servers maintain a log of all logins and a history of Data Processing operations.

4. IQ TESTER uses only those remote server service providers that can ensure proper compliance with Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 regarding the General Data Protection Regulation and can provide evidence to prove it.

All Personal Information processed by IQ TESTER that is not in digital format (i.e., in the form of physical documents) is stored in accordance with the following security rules:

1. Documents containing Personal Information are only released to those IQ TESTER employees who need those documents to perform their job functions or to carry out specific tasks involving the use of Personal Information.

IQ TESTER shall not assign any Processing function to any employee or persons who are not properly familiar with this Privacy Policy and other mandatory local legal legislation governing the security of IQ TESTER's internal information and have not signed the non-disclosure of confidential information agreement.

3. Documents containing Personal Information may under no circumstances be stored in IQ TESTER's offices that are intended for common use or in offices with unrestricted access.

4. UAB "Rebilita" employees or authorized persons may not, under any circumstances, leave documents containing Personal Information in a single room with other persons who have not been instructed by IQ TESTER to perform Personal Information Processing actions.

5. Employees of IQ TESTER are not allowed to take documents out of IQ TESTER's offices, which contain Personal information or copies of such data, unless it is necessary for the proper performance of work functions or to carry out IQ TESTER's obligations under existing contracts.

4. IQ TESTER employees who perform Personal Information Processing functions are obliged to properly safeguard documents and data files and to avoid making copies of any Personal Information. Copies of IQ TESTER documents containing Personal Information may only be made if unavoidable due to security requirements and in accordance with the objectives of this Privacy Policy, and must be destroyed immediately once the copies of the documents become redundant. Copies or storage devices of documents must be destroyed in such a way that they are impossible to recover.

5. IQ TESTER personnel, who process Personal Information, may only perform these Personal Information processing actions using computers or smart devices that are owned by IQ TESTER and are intended to perform work tasks, and which have licensed and secure software installed on them. All computers and smart devices, used for Personal Information Processing by IQ TESTER employees, must be protected by passwords that must be changed at least once every 3 months, and must consist of a combination of at least 8 symbols including lowercase letters, uppercase letters and numbers.

6. IQ TESTER performs testing of managed IT systems at least once a year, including databases, which tests the reliability, resistance to overload, resistance to cyber-attacks, viruses and other threats to system reliability of IQ TESTER's servers and information systems. During the testing of the systems controlled by IQ TESTER, no Personal Information of actual Stakeholders is used.

11. PERSONAL INFORMATION OF CHILDREN

1. The processing of a child's Personal Information will be lawful as long as the child is at least 18 years of age. If the child is under 18, such processing will be lawful only if and to the extent that Consent has been provided by the holder of parental responsibility for the child.

IQ TESTER Processes Personal Information of children under the age of 18 only when Consent has been given by the child's parental responsibility holder in the appropriate manner, as provided under applicable law.

If UAB "Rebilita" determines that the Data Subject, who is under the age of 18, has submitted Personal Information without the Consent of the holder of parental responsibility for the child, or by indicating an incorrect age, UAB "Rebilita" will, upon discovery of such information, take reasonable steps to immediately delete the Data Subject's Personal Information. In such case, IQ TESTER may delete the Stakeholder's Profile.

12. DATA PROTECTION INCIDENTS

Breach of security of Personal Information - means an act or omission that results or may result in undesirable consequences, as well as conflict with the stipulations provided by the legislation regarding the security of Personal Information. The degree of impact, damage and consequences of the breach of Personal Information protection in each case shall be determined by IQ TESTER or by a commission established by an authorized person.

2. In the event of a breach of security of Personal Information, IQ TESTER shall immediately notify, no later than 48 hours after becoming aware of the breach of security of Personal Information, the State data protection inspectorate and the Stakeholders whose Personal Information has been breached. IQ TESTER may not inform the Stakeholders about the breach of security of Personal Information if it does not pose any real risk to the rights and freedoms of the Stakeholders.

3. In cases where the breach of the protection of Personal Information is not the result of force majeure (lightning, flood, fire, etc.) and is a direct consequence of human action, from the moment IQ TESTER becomes aware of the breach of the protection of Personal Information, it shall immediately notify the appropriate law enforcement authority regarding the possible crime committed.

13. FINAL PROVISIONS

1. Oversight of compliance with this Privacy Policy is performed by the CEO of IQ TESTER or a person authorized to act as the Personal Information Protection Officer. This Privacy Policy will be renewed and, if necessary, updated at least annually. Updates or amendments to this Privacy Policy will take effect from the same time of their publication, i.e. from the date on which they are published on the Website. In the event that the Data Subject does not agree with the amendments to this Privacy Policy, he/she shall have the right to refuse IQ TESTER's Services and/or exercise the rights granted by this Privacy Policy and applicable legislation.