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Privacy Policy

Privacy Policy

PLEASE READ THIS DOCUMENT CAREFULLY. BY CONTINUING TO USE THIS WEBSITE, APPLICATIONS AND SERVICES YOU WILL BE DEEMED TO HAVE CONFIRMED THAT YOU (A) ARE ABOVE THE AGE OF 18, AND (B) HAVE ACCEPTED THIS PRIVACY POLICY AS AN INTEGRAL PART OF THE TERMS OF SERVICE.

Upon reading this Privacy Policy, you will be informed of the following:

  • what categories of personal data we collect
  • the purposes we use it for
  • the period of use and storage

· third parties to whom the personal data may be disclosed, and relevant safeguards

· options available for you to access, correct or delete your personal data

· the right to lodge a complaint with a supervisory authority

· the kind of security procedures that are in place to protect the personal data under SABA’s control.

If you have any questions, concerns or feel that there are certain problems or issues relating to compliance with this Privacy Policy, please submit a report by emailing at [email protected]

KEY INFO SUMMARY

Who is collecting the data?

Your data is collected by:

SABA LLC.

GABASHVILI ST. N5, VAKE-SABURTALO DISTRICT,

0160 TBILISI, GEORGIA

What data is being collected?

Minimum Identification/ log-in details required:

  • Login name;

And either of:

  • E-mail address OR
  • Social network log in data OR
  • Mobile phone number.

Profile data you choose to provide (totally optional):

  • Name
  • Age
  • Gender
  • E-mail address

· Information received from connected social media: your friends on SABA

· Information received from connected mobile number: your contacts on SABA.

Data we receive from your use of the service:

  • Your uploaded user content

· Information on the books and audiobooks you read/ listen to

  • Your selected quotes, reviews and comments

· Information automatically received from your device: device type, app log-ins, etc.

  • Your country information
  • Subscription type.

We do not:

· collect any sensitive data, such as information about ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or sex life or sexual orientation, etc.

· perform regular and systematic monitoring of your data on a large scale.

What is the legal basis for processing the data?

We process your data on the basis of this Agreement between You and us, formed further to your acceptance of our Terms of Service, including Privacy Policy, to the extent required for the performance of the Agreement.

Your minimum identification data, and the processing of the data you choose to provide to us is necessary to ensure we can provide SABA’s Services properly under the Agreement, which is otherwise impossible. Therefore, your provision of such data and consent to processing thereof is a requirement necessary to enter into the Agreement.

Will the data be shared with any third parties/ transferred abroad?

We may transfer your data within Georgia and abroad to:

  • Third Party Service Providers
  • Corporate Affiliates
  • During a Change of Control
  • To comply with Laws/ enforce our rights.

We make sure your data remains protected by law/ contract with the third party.

How will the information be used?

We will use the data only to ensure the SABA’s Service provided to You under the Agreement is as enjoyable as possible:

· To provide you with SABA’s Service related information

· To connect with you on SABA’s related business only

  • To improve and develop SABA’s Service
  • To provide tailored book recommendations

· To protect our interests under the Agreement, and comply with the laws

  • To create statistics reports.

How long will the data be stored for?

Unless removed by you at any moment you wish, your data is stored until you terminate the Agreement by deleting your SABA account.

What rights do our users have?

As regards your personal data you have the rights to:

· request access to all of your data (in a structured, machine-readable format), and we will provide it within 30 days (we may ask you to pass extra identification, to make sure no one else but you can receive it)

· seek to update or correct your data (you can do it using SABA’s settings or ask us to do it for you at [email protected])

  • object to the processing of your data

· request restriction of such processing and delete your data.

How can the data subject raise a complaint?

Subject to applicable law, you also have the right to (i) restrict our use of information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority.

What measures we take to protect your data?

  • electronic firewalls
  • pseudonymisation
  • encryption
  • access levels, login/password procedures

· confidentiality contracts with employees and service providers

  • backups.

A. INTRODUCTION

Word from SABA

SABA has a strong commitment to providing superior service to all of our customers and visitors and users of this Website and particularly respecting your concerns about privacy. We understand that you may have questions about how this Website collects and uses information and we have prepared this statement to inform you of the privacy principles that govern the Website. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy.

This Privacy Policy contains numerous general and technical details about the steps we take to respect your privacy concerns. We have organized this Privacy Policy by major processes and areas so that you can quickly link to the information of most interest to you. The bottom line is that meeting your needs and expectations form the foundation of everything we do — including protecting your privacy.

Personal information on this Website is collected by SABA and if after reviewing this Privacy Policy you have any questions or privacy concerns please send an e-mail to [email protected]

Changes in Privacy Policy

SABA wants you to be always aware of what personal information we collect, how we use it and under what circumstances we disclose it. All personal information, as further described below, that we collect and maintain will be subject to the version of the Privacy Policy in effect at the time of such collection. SABA reserves the right to change the Privacy Policy from time to time at its sole discretion, and will prominently post any material changes on the home page of the website. You will be given the opportunity to opt-out. If as the result of such changes, you want to alter the ways in which SABA is allowed to use your personal information, you can do so by following the procedure described in the Updating Your Personal Preferences section of this Privacy Policy (below). You will be deemed to have been made aware of, and will be subject to, the changes to the Privacy Policy by your continued use of the Website with the following exception: if at the time you provide personal information to SABA you limit how such information will be used to communicate with you, either by SABA or by third parties, SABA will not change your preference in this regard without your express consent.

Third Party Websites

SABA does not control the information collection and distribution policies on Internet domains other than those Internet domains that are under the control of SABA itself. When you are on the Website, you may be directed to other sites that are beyond our control. SABA is not responsible for any use of the information including click-stream data created when using such third party sites.

The Website may also contain advertising and other links to other web sites. Please be aware that we are not responsible for the privacy practices or content of those other sites. Also we do not send random marketing emails to personal email addresses. The Website may contain hyperlinks to external web sites owned and operated by third parties. SABA has no control over or association with such third party sites and SABA is not responsible for the accuracy, completeness and quality of the information contained within them. Any and all contents on these external web sites do not reflect products, services or information provided by SABA. You should direct any concerns regarding any external link to the site administrator or webmaster of such site.

Third Party and User Content

SABA allows users to upload their content onto the Website hosted on a “cloud” server to share with other users (“User Content”) The hosting of User Content does not imply an endorsement, guarantee, warranty, or representation by SABA as to the legality, originality, or authenticity of the User Content. An owner and/or a user who uploaded the User Content bears all risks associated with such User Content, including, without limitation, its potential legal or other liability to the other users of the SABA’s services and/or SABA.

When you are on the Website, certain content may be served by a third party. These third parties may also drop their own cookies and/or use web beacons, which may be used to identify some of your preferences or to recognize you if you have previously had contact with them. We do not control the use of such technology by third parties, the information they collect, or how they use such information.

Legal Issues

The Services may be subject to the laws of various jurisdictions, including the laws of the GEORGIA (as these Terms of Services are concluded with a Georgian company) and other jurisdiction because the Services may accessed from different jurisdictions.

SABA will disclose personally identifiable information without your permission when required by law, or in good faith belief that such action is necessary to investigate or protect against harmful activities to SABA’s guests, visitors, associates, or property (including this Website), or to others.

As mentioned above, laws related to personal identifiable information vary by country. For example, personally identifiable information collected in the European Union and its Member States is subject to the EU Directives concerning personal data, privacy and electronic communications, including but not limited to Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and the subsequent legislation adopted in the EU Member States.

SABA may be required by law enforcement or judicial authorities to provide personally identifiable information to appropriate governmental authorities. If requested by law enforcement or judicial authorities, we will provide this information upon receipt of the appropriate documentation. SABA may also provide information to law enforcement to protect its property and the health and safety of individuals as permitted by statute.

B. COLLECTED INFORMATION

Browsing

The Website does not collect personally identifiable information from your computer when you browse the Website and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personally identifiable information, we will not know your name, your e-mail address, or any other personally identifiable information. We collect such information in order to make our Service function correctly and provide you the functionality that you see on this Website, as our servers use this information to deliver to you the pages on this Service. We also use this information to better understand how visitors use our Service and how we can better tune our Service, its contents and functionality to meet your needs.

Information We Collect

As a visitor to this Website, you can engage in many activities without providing any personal information as described above in the Browsing section of this Privacy Policy (above). In connection with subscribing to the services available on the Website or other activities, such as utilizing online software applications or purchasing or downloading any of the products and services available on the Website, SABA may ask you to voluntarily supply us with certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities and/or make any purchases. If you elect to engage in these activities or make purchases, however, SABA may ask that you provide us personal information, defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains, including but not limited to your first and last name, mailing address (including ZIP code), e-mail address, and other personal information. This information is requested in conjunction with the purchase and registration of our Products or Services.

In addition, as noted below, minimum information is requested if you choose to subscribe to product updates.

You never have to answer any questions, and you can decline this exchange of information at any time. However, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity or purchase, you will not be able to engage in that activity or make such a purchase. SABA will inform you of the mandatory and/or optional character of the requested and/or required information.

SABA is the sole owner of the information it gathers on the Website. SABA will only share your information with outside parties in ways that are described in this Privacy Policy or if we are required to do so by law or in the good-faith belief that such action is necessary in order to conform to the edicts of the law, cooperate with law enforcement agencies, or comply with a legal process served on the Website and the subsequent legislation.

When you use the Website, SABA or third parties authorized by SABA may also collect certain technical and routing information about your computer to facilitate your use of the Website and its services. When you surf the Internet, your Internet browser (such as Mozilla Firefox, Microsoft Internet Explorer, Safari or other) automatically transmits some information to SABA every time you access content on one of our internet domains within the Website. Examples of such information include the URL of the Web page you were just on (known as the “Referrer”), the IP (or Internet Protocol) address of the computer you are using, or the browser version you are using to access our site. All of this information may be collected by SABA and used to help improve our offerings to you.

We use such data to facilitate and track your use of the Website and its services. SABA also uses such environmental variables to measure traffic patterns on the Website. Without expressly informing you in each particular circumstance, we do not match such information with any of your personal information.

SABA has the right to send you a periodic newsletter, and information about the updated product. This newsletter is a marketing tool that allows SABA to inform you of new Products and Services, as well as other news relevant to the company. You have the right to unsubscribe from this mailing list by following the link given in the letter.

When you submit personal information to SABA through this Website or related applications (e.g. mobile SABA Reader Application), you understand and agree that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which SABA, its affiliates, subsidiaries and third party partners maintain offices. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of your information may be undertaken by trusted vendors of SABA. Such vendors are bound by contract not to use your personal information for their own purposes or provide it to any third parties.

SABA may establish relationships with various service providers whose services may become available to you from this Website or from other websites that are linked to this Website. Typically, these providers would offer services that SABA customers might find useful, such as those that can be used in conjunction with SABA services and products. In order to use those services, you may be required to provide personal information to the providers. Unless expressly provided to the contrary, personal information that you provide while you are visiting a provider's Website will be subject to the privacy policy posted on such site, and personal information that you provide while on this Website in conjunction with a provider's service will be subject to this Privacy Policy. For instance, the credit card information entered as part of the filling out the purchase form or registration process is collected by the third parties’ registration and/or merchant services and subject to their respective privacy policies. You should be aware that our agreements with these service providers often provide that they will share with SABA personal information collected from you. In such instances, SABA may use this information in a manner consistent with this Privacy Policy.

Personal Account

A personal account is required for readings books with preservation of settings of reading; bookmarks; additions of books on the personal shelf; obtaining recommendations, news; accounting of statistical data of reading; citation of books; to share on social networks etc. on the Website. When you create a personal account, some information about your account activity will be provided to other users of SABA. For instance, other users may be able to view which content you have accessed via the Website. You can access, review, update and delete your personal account information online via the Website.

If you wish to delete your personal account, you can use the link “Delete account” at the very bottom of the page with settings. You have the right to delete your personal information in part or in full, or change it at any time by logging into your personal account, where you can view and make changes to your personal information. We cannot guarantee that information in your personal account won’t be accessible to other users either by means of Service or by means of other services including the search engines.

Accessing and Updating Your Personal Information

You have the right to access, correct, delete, or modify the personal information you provided to us and associated with your account by logging into your personal account. You can also access, correct additional account information by emailing us at [email protected]

Updating Your Personal Preferences

As a registered user you have the right to access and change your personal preferences at any time by logging into your personal account.

Deleting Your Personal Information

If you wish to delete your personal information in part or in full, please submit a request by emailing at [email protected] However, if you should choose to delete mandatory information, we may not be able to provide you with some of the services dependent upon the collection of this information.

Keep in mind that search engines and other third parties may still retain copies of your public information, like your profile information and public citations, even after you have deleted the information from our services or deleted your account.

Portability

SABA provides you with a possibility to download your information in a portable, commonly used and machine-readable format (i.e. in an electronic format). You can submit a request by emailing us at [email protected] and we will prepare the file within 30 days.

Information Relating to Children

The Children's Online Privacy Protection Act (COPPA) was passed by the U.S. Congress in November 1998. COPPA provides parents with specific rights regarding their children's privacy. For additional information and resources on COPPA, please visit the Federal Trade Commission Web site at http://www.ftc.gov/. The Website and any products or services available on the Website are not directed at children under 18 years of age. and, therefore, COPPA does not apply.

If a person is under 18, he/she may use the SABA Service only with the involvement of a parent or guardian. However, since it is technically impossible to verify the age of each user, we recognize that children under the age of 18 may access this Website and subscribe to the newsletter or purchase products and services. The collection of this information is covered above. Parents and Legal Guardians may request us to terminate and delete their child’s account. You may do so by contacting us by email to [email protected]

Securing the Transmission and Storage of Information

SABA operates secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information provided by our users. SABA takes steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no data transmission over the Internet can be guaranteed secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us or from our online products or services, and you use these services at your own risk.

We treat the information you provide to us as confidential information; it is, accordingly, subject to our company’s security procedures and corporate policies regarding protection and use of confidential information. After personally identifiable information reaches SABA it is stored on a server with physical and electronic security features as customary in the industry, including utilization of login/password procedures and electronic firewalls designed to block unauthorized access from outside of SABA. Because laws applicable to personal information vary by country, our offices or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected on the sites covered by this Privacy Policy is processed and stored in Germany and possibly other jurisdictions and also in other countries where SABA and its service providers conduct business. All SABA employees are aware of our privacy and security policies. Your information is only accessible to those employees who need it in order to perform their jobs.

C. USE AND DISCLOSURE OF INFORMATION

How Your Personal Information Is Used

SABA collects your information in order to record and support your participation in the activities you select. We will use your e-mail address or phone number to send a confirmation and, if necessary, might use the other information to contact you for help to process the purchase or service you have selected. If you subscribe to a service or upload a content, for example, the information is used to register your rights, if any, to technical support or other benefits that may be made available to registered users. Your personal information is also used to keep you informed about new products, product upgrades, patches, special offers, and other products and services of SABA and selected third parties if you have so opted to receive such communications.

SABA may collect information about the use of the services offered via Website, such as the types of services used and how many users we receive daily. This information is collected in aggregate form, without identifying any user individually. SABA may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.

SABA recognizes and appreciates the importance of responsible use of information collected on this Website. Without your consent, SABA will not communicate any information to you regarding products, services, and special offers available from SABA or its affiliates, although we may find it necessary to communicate with you regarding your use of the services on this Website. Except in the particular circumstances described in this Privacy Policy, SABA will also not provide your name to other companies or organizations without your consent.

Disclosure of Information to Third Parties

SABA does use the services of third parties (e.g. processing of purchase orders) that act as independent contractors on behalf of SABA. You may also use your third party login accounts and passwords (e.g. Facebook, Twitter, Google or other) in order to register and login to the Website and use SABA’s services. These parties are contractually prohibited from using personally identifiable information for any purpose other than for the purpose SABA specifies. We do provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We prohibit the sale or transfer of personal information to entities outside of the SABA’s affiliates for their use without our approval.

SABA may disclose your personally identifiable information if we believe in good faith that we are required to do so in order to comply with applicable law, a subpoena, or other legal process. SABA may also disclose personally identifiable information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating this Privacy Policy, the terms of your agreements with SABA or to protect the safety of our users and the public or under confidentiality and licensing agreements with certain third parties which assist us in developing, operating and maintaining the Website and its content.

In the event that all or substantially all of SABA’s stock and/or all or substantially all assets are transferred or sold to another entity, SABA may transfer personally identifiable information to the acquiring entity. If, as a result of such a business transition, your personally identifiable information will be used in a materially different manner, you will be given choice consistent with our policy regarding notification of changes.

Choices Available to You

You can always choose whether or not to disclose personally identifiable information and that choice will not prevent you from using the Website. Please note, however, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information and you will be given an opportunity to “opt-in” and make your preference choices for any items that are optional and which are not prerequisite for our rendering such services.

You can choose at any time to opt out of receiving emails from SABA or from having your personally identifiable information shared with selected companies. If you want to opt out, you can do so by editing your preferences with respect to email or the sharing of information. If you elect to “opt out” we will not, as applicable, share your personal information with third parties or send you emails. However, we may continue to use your personal information for internal purposes, to enhance your user experience or as necessary to administer the site or comply with applicable law.

We reserve the right to send a one-time registration confirmation email, and infrequent Service Alert messages to users to inform them of specific changes that may impact their ability to use a service they have previously signed up for, regardless of email contact opt-in status. We also reserve the right to contact you if compelled to do so as part of a legal proceeding or if there has been a violation of any applicable licensing, warranty and purchase agreements.

SABA is retaining these rights because in limited cases we feel that we may need the right to contact you as a matter of law or regarding matters that will be important to you. These rights do not allow us to contact you to market a new or existing service if you have asked us not to do so, and issuance of these types of communications is rare.

If you do not wish to receive e-mails with updates and information, please click on the link of any letters sent by SABA. You may also opt-out online by updating your personal account.

If you wish to opt out of receiving emails, the sharing or retention of any personal identification information, or otherwise change your personal preferences, you may contact SABA by email at [email protected]

To ensure that your request is honored, you must provide SABA with information sufficient for us to accurately identify and access your records. The information we require is your full name and the email address you provided to SABA. SABA reserves the right to contact you to verify that we have accurately identified your record.

Cookies

Our Website uses “cookie” technology. “Cookies” are short pieces of data generated by a web server that a website stores on a user’s computer. Certain pages on our Website may require the use of a cookie for purposes of keeping information you enter on multiple pages together. Cookies also enable us to customize our Website and offerings to your needs and provide you with a better online experience with us. In addition, cookies are used to:

1. measure usage of various pages on our Website to help us make our information more pertinent to your needs and easy for you to access;

2. identify and categorize the internet webpages from which the visitor came to the Website and observe the browsing patterns; and

3. provide functionality such as online orders, SABA’s services and other functionality that we believe would be of interest and value to you.

The types of cookies that we use are referred to as “session” cookies and “persistent” cookies. Session cookies are temporary and are automatically deleted once you close your browser. Persistent cookies remain on your computer hard drive until you delete them. We do not use cookies to gather information concerning your visits to other websites, nor ascertain any personally identifiable information about you apart from what you voluntarily provide us in your dealings with SABA. Cookies do not, under ordinary circumstances, corrupt or damage your computer, programs, or computer files.

In addition, the service providers we use to serve and host our advertisements, and/or deliver our e-mails, use session and persistent cookies, to track the number of times the Website is accessed and whether the site was accessed from an advertisement. A cookie is placed on your computer only if and when you click on an advertisement or open the e-mail. The cookie generated from the advertisement or e-mail does not contain any personally identifiable information and will remain on your hard drive until you delete it.

You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our Website.

D. PRIVACY-RELATED INQUIRIES AND COMPLAINTS

SABA takes and addresses its users’ privacy concerns with utmost respect and attention. If you believe that there was an instance of non-compliance with this Privacy Policy with regard to your personal information or you have other related inquiries or concerns, you may write or contact SABA with an address of:

SABA LLC.

GABASHVILI ST. N5, VAKE-SABURTALO DISTRICT,

0160 TBILISI, GEORGIA

email: [email protected]

In your message, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly. Please note that if you provide SABA with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), SABA cannot guarantee that your most recent privacy preference will be honored.