Ryoko Translation Privacy Policy

Version applicable from June 10, 2021

  1. Why should I read this Privacy Policy?

This Privacy Policy (“Policy”) describes how UAB Ekomlita (trading as Enence, hereinafter referred to as “the Company”, “we”, “us”, “our”) collects, uses, discloses and stores your personal information and what legal rights you have. We protect your personal information in accordance with the EU General Data Protection Regulation (2016/679) (“GDPR”) and other applicable laws. We may unilaterally modify this policy from time to time. Any such revisions will be effective immediately upon posting, so please visit our website regularly to obtain the latest version of this Policy. We protect your personal information in accordance with the EU General Data Protection Regulation (2016/679) (“GDPR”) and other applicable laws. We may unilaterally modify this policy from time to time. Any such revisions will be effective immediately upon posting, so please visit our website regularly to obtain the latest version of this Policy.

  1. Who is responsible for protecting my information?

We are UAB Viaota, acting as Ryoko’s interpreter;

Our company number is 305710320

Our address: Gedimino g. 45-7, LT-44239, Kaunas, Lithuania

Our email address is support@ryokowifi.com

  1. Why and how do you collect my information?
  1. 1. Process your order in our online store, collect payment and deliver to your door
When does this become relevant to me? What information do you collect about me? What information do you collect about me? What is the legal basis for collecting my information? Am I obliged to provide this information? How long will information about me be stored?
When you buy our products First name, last name, shipping address, phone number, email address, information about the purchase price you paid and the currency, your credit card brand, type, bank identifier code and country of issue, IP address, language, device type, payment history Contract (Article 6(1)(b) GDPR). From yourself This is a necessary condition for entering into a contract. If you do not provide this information, you will not be able to purchase and receive our products. 10 years
  1. 2. Ensuring and improving the security of our website
When does this become relevant to me? What information do you collect about me? What information do you collect about me? What is the legal basis for collecting my information? Am I obliged to provide this information? How long will information about me be stored?
When you use our Ryoko portable WiFi router First name, last name, email address, amount of used information, address, telephone number, IP addresses, data used Contract (Article 6(1)(b) GDPR). From your own

Internet access providers		 It is a contractual requirement. If you do not provide this information, you will not be able to use our services. 10 years
  1. 3. Ensuring and improving the security of our website
When does this become relevant to me? What information do you collect about me? What information do you collect about me? What is the legal basis for collecting my information? Am I obliged to provide this information? How long will information about me be stored?
When you use our website or violate our Terms of Service IP address, device information and ID, web browser information, information about your activity on our website, country/region, information about violations of our terms of service, and blacklisting information Legitimate interest (security and improvement of this website) (Article 6(1)(f) GDPR) From yourself No Your relevant information will be stored for 1 month after your last use of the website; if it is a violation of the terms of service and blacklist information, it will be stored for 10 years
  1. 4. Providing you with customer support
When does this become relevant to me? What information do you collect about me? What information do you collect about me? What is the legal basis for collecting my information? Am I obliged to provide this information? How long will information about me be stored?
When you submit an inquiry or complaint to our customer support department Your name, last name, email address, country, phone number, inquiry subject, inquiry date, inquiry content, inquiry attachments, inquiry reply, customer contact history, order ID Consent (Art. 6 (1) (a) of GDPR) From your own

customer support provider		 No 10 years from the date of receipt of your last inquiry
  1. 5. Introduce our products to you or show you the Internet
When does this become relevant to me? What information do you collect about me? What information do you collect about me? What is the legal basis for collecting my information? Am I obliged to provide this information? How long will information about me be stored?
When we want to inform you or ask for your opinion about our products or show you the Internet Your full name, email, phone number, IP address, order information, country, postback information, the website of the company you are directed to, your interaction with the Internet Consent (Art. 6 (1) (a) of GDPR)) Legitimate interest in

customer relations

(direct marketing and internet supplement) (Art. 6 (1) (f) of GDPR)		 From your own

Social media service provider

Marketing service provider

E-commerce provider		 No Your information will be stored for 5 years unless you opt-out
  1. 6. Interact with you via social media
When does this become relevant to me? What information do you collect about me? What information do you collect about me? What is the legal basis for collecting my information? Am I obliged to provide this information? How long will information about me be stored?
When you interact with our social media profiles (e.g., send messages, follow our profiles, share posts, reply to posts) Your name, email address, gender, country, image, email, time and date of email receipt, email content, email attachments, reply emails, time of reply emails, company rating information, post comments, post sharing, post reply information Consent (Art. 6 (1) (a) of GDPR) From yourself and social media service providers No 10 years from your last interaction with our social media profiles
  1. 7. Select potential employees
When does this become relevant to me? What information do you collect about me? What information do you collect about me? What is the legal basis for collecting my information? Am I obliged to provide this information? How long will information about me be stored?
When we receive your job application, when you consent for us to store your resume, or when we contact you based on information you have publicly disclosed on professional social media platforms Your full name, email, phone number, resume, work experience and other information you provide to us Consent (Article 6(1)(f) GDPR)

Contract (Article 6(1)(b) GDPR).

Legitimate interest (to contact you if you have made your information public) (Article 6(1)(f) GDPR)		 From your own

professional social media service provider

human resources agency		 It is only necessary to conclude a contract if we intend to enter into an employment contract with you. If you do not provide this information, we will not be able to enter into an employment contract with you. 6 months after the relevant recruitment process has ended

5 years after you have given us your consent or publicly disclosed your information on professional social media platforms
  1. 8. Fulfilling statutory accounting requirements
When does this become relevant to me? What information do you collect about me? What information do you collect about me? What is the legal basis for collecting my information? Am I obliged to provide this information? How long will information about me be stored?
When you order our products Your full name, email address, phone number, bank account number, address, signature, invoices, reports, accounting files, payments, amounts paid, other information we are required by law to collect Legal obligations (Article 6(1)(c) GDPR) From your own

audit service provider		 This is a legal requirement and if you do not provide this information you will not be able to purchase goods or services from us. 10 years after transaction
  1. 9. Protecting our rights
When does this become relevant to me? What information do you collect about me? What information do you collect about me? What is the legal basis for collecting my information? Am I obliged to provide this information? How long will information about me be stored?
If we become a party to legal proceedings against you or we are otherwise required by law to collect your information All of the above information, accounting and legal case files, legal documents, other information you provide to us, and other information we are required by law to collect and/or provide Legal obligation (Article 6(1)(c) GDPR)

Legitimate interest (to protect our rights and interests) (Article 6(1)(f) GDPR).		 From the above sources, law enforcement agencies, parties bound by legal procedures, courts Yes, we are legally obliged to collect personal information 10 years after the end of the contractual relationship with us, or during the legal proceedings and 3 years after the final authoritative decision has fully come into force (whichever is longer)
If it happens - information about criminal offences and convictions for the establishment, exercise or defence of legal claims (Article 9(2)(f) GDPR)
  1. Who do you share my information with?

We will share your information with recipients within and outside the European Economic Area (EEA) where necessary for the purposes listed above and where permitted by applicable law.

The information we receive from you in connection with the SMS Services may include your cell phone number, the name of your network operator and the date, time and content of your SMS. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. For more information about how we use your personal information, including phone numbers, please refer to our privacy policy.

Recipients or categories of recipients of information Purpose of information transmission Recipient's Country European Commission decision on whether non-EEA countries have an adequate level of data protection Appropriate safeguards are in place to protect my information when it is transferred to non-EEA countries
Accounting and auditing service providers Fulfilling statutory accounting requirements European Union not applicable not applicable
Archive Service Provider Save our archives European Union not applicable not applicable
Electronic communications service providers Operating our e-newsletter European Union not applicable not applicable
Lawyers, notaries, bailiffs, auditors, data protection officers, consultants Ensure our compliance and safeguard our rights European Union not applicable not applicable
Email and cloud hosting providers Operational IT resources worldwide No EU Standard Contractual Clauses
Banks, payment processors and other financial service providers Processing payments worldwide No EU Standard Contractual Clauses
Marketing and telemarketing service providers Marketing our products worldwide No EU Standard Contractual Clauses
Shipping service providers and fulfillment centers Shipping our products worldwide No EU Standard Contractual Clauses
Customer Support Service Provider Provide customer support worldwide No EU Standard Contractual Clauses
Social media service providers Managing our social media profiles worldwide No EU Standard Contractual Clauses
  1. What are my legal rights regarding my information?

Subject to the conditions and limitations provided by applicable law, you have the right to (i) receive confirmation as to whether we have collected information about you and request access to that information; (ii) have inaccurate or incorrect information corrected or have it supplemented if it is incomplete; (iii) have the information we have about you deleted; (iv) restrict the use of your information where you contest its accuracy, object to its processing or where your information is needed for legal purposes; (v) request your information in a structured, commonly used and machine-readable format (vi) to object to its processing; (vii) withdraw any consent given to us for processing your information; (viii) lodge a complaint with a supervisory authority; and (ix) not be subject to discriminatory treatment when exercising your rights. Please see the following sections for more detailed information about your rights and how they apply to you.

  1. What are my rights to request information?

You have the right to request that we disclose certain information to you about our collection and use of your information. Once we receive and verify your request, we will disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information about you, our business or commercial purposes for collecting that personal information, the categories of third parties with whom we shared that personal information, the specific pieces of personal information we collected about you, and other information we are obligated to provide under applicable law. We have disclosed information to third parties for the business or commercial purposes described in Section 4 of this Policy.

  1. What are my rights to redress?

You have the right to request correction of inaccurate personal information concerning you. Taking into account the purposes of the processing, you have the right to have incomplete information completed, including by providing a supplementary statement.

  1. What are my rights to request deletion of information?

You have the right to request the erasure of your information that we collect and maintain in the following circumstances: (i) the information is no longer necessary in relation to the purposes for which it was collected or processed; (ii) you withdraw consent on which the processing was based and there is no other legal basis for the processing; (iii) you object to processing and there are no overriding legitimate grounds for processing or you object to processing for direct marketing purposes; (iv) the information has been unlawfully processed; (v) the information must be erased to comply with a legal obligation; or (vi) the information has been collected in connection with the provision of Information Age services directly to children and with consent. Once we receive and verify your request, we will delete (and instruct our service providers to delete) your information from our records, unless applicable law does not require deletion in certain circumstances (for example, retaining the information is necessary for us or our service providers to complete the transaction for which we collected the personal information, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activity, comply with legal obligations, or have other lawful internal uses of the information that are consistent with the context in which you provided the information).

  1. What rights do I have to restrict the processing of my information?

You have the right to restrict the processing of your personal information if (i) you contest the accuracy of the personal information; (ii) the processing is unlawful and you oppose the erasure of the personal information and request the restriction of its use instead; (iii) we no longer need the personal information for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing.

  1. What are my rights to data portability?

You have the right to data portability when you seek to receive information you have provided in a structured, commonly used and machine-readable format, or to transmit that information to another controller, where the processing is based on consent or a contract and is carried out by automated means.

  1. What rights do I have to object to the processing of my information?

As set out in Section 3 of this Policy, you have the right to object to the processing of your information where the collection and use of the information is carried out in the public interest or in the exercise of official authority or legitimate interests (including profiling), or where you object to the collection of personal information for direct marketing purposes.

  1. What are my rights to withdraw consent?

As set out in Section 3 of this Policy, you have the right to withdraw any consent for the processing of your information where the processing is based on consent, and you may seek to withdraw that consent at any time.

  1. What are my rights to complain to a supervisory authority?

If you wish to lodge a complaint with a supervisory authority, you have the right to do so, in particular in the Member State of your habitual residence, place of work or in the case of an alleged GDPR infringement.

  1. What rights do I have to be free from discriminatory treatment when exercising my rights?

You have the right not to be discriminated against when you exercise your rights under applicable law. For example, you will not be denied any goods or services, charged different prices, provided with goods and services of different quality, etc., because you exercise your rights under applicable law.

  1. How do I submit my application?

If you wish to exercise the rights set forth above, please submit a request to us via email at support@ryokowifi.com or by calling our toll-free number: +1 (205) 782-7133 (USA).

  1. Can I use an authorized agent?

certainly. You may use an authorized agent to submit an opt-out request on your behalf if you provide us with the authorized agent’s written permission. If this is the case, please provide us with a copy of the above license in accordance with the instructions in Section 18 of this Policy. If this is the case, please provide us with a copy of the above license in accordance with the instructions in Section 18 of this Policy. We may deny a request to authorize an agent if the agent does not submit proof that the agent is authorized by you to act on your behalf. You can also make a request on behalf of a minor child.

  1. Do you engage in automated individual decision-making, including profiling?

No, we do not make decisions based solely on automated processing (including profiling) which would have legal effects on you.

  1. Does your website place cookies on my device?

Yes, our website will place the following cookies on your device

Cookie Name Cookie Description Cookie Duration
Strictly Necessary; Statistics Cookies
_fbp Used to distinguish and track unique users 3 months
_ga This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included with every page request on your website and is used to calculate visitor, session, and campaign data for your website's analytics reports. 2 years
_gat This cookie is used by Google Analytics to throttle the request rate. 1 day
_gid This cookie stores and updates a unique value for each page visited and is used to count and track page views. 1 day
__cfruid Cookie associated with sites using CloudFlare, used to identify trusted web traffic. Only during your session
_fw_crm_v Used to track visitor/user identities and chat sessions performed by users 1 year
_hjid The Hotjar cookie is set when a customer first logs into a page using the Hotjar script. It is used to persist the Hotjar user ID, which is a unique ID for that website on the browser. This ensures that subsequent visits to the same website are attributed to the same user ID. 1 year
_uetvid This is a cookie used by Microsoft Bing Ads to allow us to interact with users who have previously visited our website. 1 year
XSRF-TOKEN This cookie is written to help secure websites from cross-site request forgery attacks. 1 day
enence_session This cookie is used to save information about your current visit to our website. This cookie is essential for the functionality of the website. Only during your visit to the website
c This cookie is used for spam detection and to improve the security of the site. No visitor-specific data is stored. 2 years
soundestID This cookie is used to determine if the visitor has visited the site before, or is a new visitor to the site. Only during your visit to the website
soundtest-views Assign a unique ID to the visitor - this allows the website to determine the number of visits by a specific user for analytical and statistical purposes. Only during your visit to the website
Marketing Cookies
ads/ga-audiences This cookie is used by Google AdWords to re-engage visitors who may convert into customers based on their online behavior across various websites. Only during your visit to the website
REST/webTracking/v1/event This cookie measures the effectiveness of website marketing. The cookie is used to measure the conversion rate between website marketing and telephone responses. Only during your visit to the website
Targeting Cookies
_gat_gtag_UA_136786017_1 This cookie is part of Google Analytics and is used to throttle requests (limit request rate). 1 minute
  1. How to manage cookies?

You can configure your browser to refuse some or all cookies, or to request your permission before accepting a cookie. Please note that by deleting cookies or disabling future cookies you may not be able to access certain areas or features of our website. You can control the use of functional cookies, targeting cookies or advertising cookies by adjusting your browser settings.

  1. How can I contact your data protection officer?

If you have any questions, comments or complaints about how we collect, use and store your personal information, our Data Protection Officer is always available to help you. If you need their help, you can always contact them at support@ryokowifi.com.