Privacy policy

GEONIX  (hereinafter referred to as "GEONIX," "Us," "We," and "Our") recognizes the importance of maintaining the confidentiality and inviolability of individuals' Personal Data, thus GEONIX has reached an agreement with you (hereinafter referred to as the "Policy"). The Policy explains how GEONIX  can receive, store, process, use, and disclose your Personal Data when you use GEONIX's Services and our website located at https://geonix.com  (hereafter "Website"). 


You agree to this Policy, any other annexes to the Policy, and any other documents referred to in this Policy by using the Website and/or utilizing GEONIX’s Services. If you do not agree to the terms of this Policy, you may not use the Website or GEONIX  Services. 


You must immediately exit the Website and cease using GEONIX's Services if you have not properly read, do not completely understand, or do not agree with this Agreement.


This Policy relates to the individuals, collectively known as "Personal Data Subjects" (hereinafter referred to as "Subjects"). In this Agreement, you may be referred to as "you" or the "Subject." 


GEONIX defines "Customer" as a person who uses the GEONIX  Services, and "Visitor" as a person who visits our Website for the purposes of this Privacy Policy. 


1. MEANINGS 

1.1 Form “Order Form” (hereinafter referred to as “Order Form”) - is an online form that allows a Customer to place an order for GEONIX's Services on the Website, specifying the country of proxy servers, the purpose of their use, the version of Internet protocol, the number of proxy servers, the rental period, as well as the method of authorization and form of payment.

1.2 “Ordering” - an online order for GEONIX's services that are placed by filling out the "Order Form" on the Website and then paying for the order.

1.3 “Personal Account” refers to the Customer's account on the Website, which allows him or her to use the Services. The Customer's Personal Account allows him or her to keep track of the Services' expiration dates, renew them, and order new ones. 

1.4 “Personal Data”  – refers to information about a living individual who may be identified. 

1.5 “ GEONIX” - INTERNET CONNECTION BROKER LTD, whose registered address is Vitosha boulevard 15, fl. 4, apt/office 2, Sofia, Bulgaria, 1000 and whose services are available on the Website.

1.6 “ GEONIX’s Services” or “Services” - refers to the provision of exclusive access to the Services, which are made available to the Customer in the Personal Account within 24 hours of the Customer placing an Order and paying for the Services. 

1.7 “Subject” - is any whose personal data is collected, held or processed by the GEONIX. For the purposes of this Privacy Policy, the following categories are recognized as subjects:

1) Customer is 1) an individual over the age of 18 who accepts this Agreement on his or her own behalf, or 2) a legal entity represented by an individual who accepts this Agreement on behalf of such a legal entity, who has placed and paid for an order intending to utilize the Services. When the Subject places and pays for an order to use the Services, the Subject becomes the Customer* 

2) The visitor is someone who comes to the website but does not use the GEONIX services.


2. THE AGREEMENT'S OBJECTIVE 

2.1 The GEONIX can acquire, store, process, use, and disclose Personal Data submitted by the Subject while using the Website and/or Service, as defined by this Policy.

2.2 The Subject authorizes GEONIX the right to receive, store, process, use, and disclose the Subject's Personal Data in accordance with the terms of this Policy by using any aspect of the Website and/or Service.

2.3 GEONIX collect, store, process, and use the Subject's Personal Data to allow Subjects to use the Site and/or Services, as well as to defend the rights and legitimate interests of the Subjects of Personal Data as set forth by law.

3. DATA PROCESSING PRINCIPLES 

3.1 To secure your Personal Data, GEONIX adheres to all relevant principles. To protect your privacy, GEONIX follows the following principles, which are based on existing Bulgarian legislation and Art. 5 of the EU General Data Protection Regulation (GDPR):

3.1.1 The principle of purpose limitation means that GEONIX only collects personal data for specific, explicit, and legitimate objectives, and GEONIX doesn't process it in ways that are incompatible with those goals.

3.1.2 Data accuracy is a principle that GEONIX follows to ensure that personal data is accurate and, where necessary, kept up to date. GEONIX takes every reasonable precaution to guarantee that erroneous personal data is promptly destroyed or corrected, taking into account the reasons for which it is collected.

3.1.3 Principles of lawfulness, fairness, and transparency - GEONIX processes Personal Data about the data subject in a lawful, fair, and transparent manner.

3.1.4 The principle of data minimization states that GEONIX gathers only as much personal data as is essential for the reasons for which GEONIX is processing personal data.

3.1.5 Storage limitation principle - GEONIX maintains personal data in a form that allows data subjects to be identified for no longer than is necessary for the purposes for which the personal data are processed.

3.1.6 GEONIX processes personal data in a way that provides appropriate security of the personal data, including protection against unauthorized or unlawful processing, as well as accidental loss, destruction, or damage, by employing appropriate technical or organizational measures.

4. PERSONAL DATA GEONIX COLLECT AND PROCESS 

4.1 GEONIX may ask for your Personal Data in order to fulfil our obligations to provide you with the ability to utilize the Website and Services.  Visitors.  Visitors to our Website may be collected, recorded, and analyzed by GEONIX.

4.2 GEONIX only gathers the visitor's email addresses if they want to contact us in order to use our services. The Visitor does so by using the GEONIX support service's online chat (hereinafter referred to as "Online Chat" and "Support Service") and/or writing to the Support Service's e-mail address.

4.3 GEONIX only uses the Personal Data GEONIX collects to connect with you. Please do not use our Online Chat and/or contact our Support Service if you do not want us to collect your Personal Data.

4.4 GEONIX relies on your consent to process your Personal Data for the purpose of communicating with you when processing the Personal Data of our Visitors. GEONIX utilizes such Personal Data in ways that you would expect and that have a minimum impact on your privacy. You can withdraw your consent at any time by sending us an email with your withdrawal request to [email protected], and your Personal Data will be erased within 72 hours.

4.5 If you contact us through our Website's Online Chat, GEONIX may save your request and our response in order to improve the effectiveness of our Support Service's organization. GEONIX preserves personally identifiable information related to your messages, such as your name and email address (if you submitted it to us), so that GEONIX can track our communications with you and provide you with excellent service.

4.6 GEONIX also keeps track of your Usage Data. It's data acquired automatically through our website (or third-party services used by GEONIX), and it could contain things like:

4.6.1 the numerical code indicating the status of the server’s answer (successful outcome, error, etc.);

4.6.2 the method utilized to submit the request to the server;

4.6.3 the country of origin;

4.6.4 the IP addresses or domain names of the computers utilized by the Visitors who use the Website;

4.6.5 the URI addresses (Uniform Resource Identifier);

4.6.6 other parameters about the device operating system and/or the Visitors’ IT environment;

4.6.7 the size of the file received in response;

4.6.8 the features of the browser and the operating system utilized by the Visitor;

4.6.9 the various time details per visit (e.g., the time spent on each page) and the details about the path followed with special reference to the sequence of pages visited; and

4.6.10 the time of the request.

4.7 GEONIX uses this data in the aggregate to measure the attractiveness of our Website's web pages and how well GEONIX provides the content to you. Even if you are not signed in to our Website, the data could be used to identify you individually when combined with other information GEONIX knows about you from previous visits. To evaluate data, GEONIX use Google Analytics, Google Tag Manager, and LinkedIn Analytics. The information gathered in this manner is only kept for a year.

4.8 By clause 3.15 of the Public offering, you may be required to provide the following data: personal information extracted from a Customer’s identity document, for example, name, document number, date of birth, nationality, type of document, issuing country, expiration date, information embedded in barcodes, QR codes, security chips and features (which will vary depending on the type of document), and the image metadata associated with the image or video of the document. GEONIX does not receive or process this data. Processing is carried out by the policies of the service as a third party that conducts the KYC process. Please ensure that you have carefully reviewed and agreed to the service’s policy before submitting your data.

4.9 Usage Data processing is based on our reasonable interests. It is required for efficiently and successfully managing and running our business, delivering quality services such as website assistance, developing and enhancing products, and assessing who would be interested in them.

4.10 GEONIX strives to gain your explicit agreement to process your Personal Data whenever possible.

4.11 Customers. GEONIX acquires personally identifiable information from our customers in order to provide services to them.

4.11.1 A contract is formed between you and us when you accept our Terms of Use. GEONIX must process the information you provide in order to fulfil our contractual commitments.

4.11.2 You supply us with your email address when you create an account on our Website. GEONIX uses this information to identify our customers and provide services, billing, mailings, notifications, and support to them.

4.11.3 GEONIX may ask you to submit scan copies of your papers to verify your identity. GEONIX processes this information because GEONIX has a contract with each other and our legitimate interests are aligned (prevention of fraud and infringements of intellectual property rights). GEONIX uses this information to identify our customers, prevent and detect unauthorized use of intellectual property items on the Website, respond to customer complaints, and comply with all applicable laws and regulations. GEONIX utilizes your information in ways that you would expect and that have a minimum impact on your privacy.

4.11.4 GEONIX may get your Personal Data through third parties whose services GEONIX utilizes, such as payment service providers. Your name, phone number, and shortened payment information may be sent to us (4 last digits of your card number).

4.11.5 GEONIX treats this data taking into account that GEONIX has a contract or that you have requested that GEONIX uses it before GEONIX enter into a formal agreement.

4.11.6 GEONIX never takes or sends the payment information to us, whether through our Website or otherwise. You are redirected to a secure page on the payment service provider's website at the time of payment.

4.11.7 The consent received from you is also used to process Personal Data for marketing purposes. GEONIX uses data in ways you'd expect and that have a minimum impact on your privacy.

4.11.8 GEONIX may keep your Personal and other data for as long as is necessary to achieve the goals outlined in this Policy, or until you request deletion, whichever comes first. GEONIX may retain your Personal and other data to the extent and for the time necessary to achieve the purposes set forth in this Policy, or until you request deletion of this data, whichever comes first. GEONIX may retain your Personal and other data to the extent and for the time required to attain the objectives established forth in this Policy, or within the period limit set by current Republic of Bulgaria legislation, international law, or the laws of the country in which you reside, or until you request deletion of this data.

4.11.9 If your Personal Data changes, you must update your Personal Account on the Website and provide us with the new information.GEONIX will not be accountable for any negative effects resulting from the processing of such Personal Data if you do not comply with this requirement.

5. PROCESSING DATA ON A LEGAL BASE 

5.1 We process your Personal Data in compliance with the Republic of Bulgaria's current legislation, the rules that apply to you, and internationally recognized standards and norms.

5.2 As an Operator, we process Personal Data in accordance with Art. 4 GDPR. 

5.3 The Subjects' personal data is treated in compliance with generally accepted international law, the laws of the Republic of Bulgaria, and the rules that apply to you, including but not limited to:

5.3.1 If you live in the European Union (EU), you have privacy rights and all Personal Data processing is governed by regulations and rules that follow 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, also known as the General Data Protection Regulation ("GDPR").

5.3.2 If you are located in the United Kingdom, all Personal Data processing is carried out in compliance with the Data Protection Act 2018 ("DPA 2018") and the UK General Data Protection Regulation ("UK GDPR").

5.3.3. If you are based in Australia, all Personal Data processing is done in line with the Privacy Act 1988's norms and rules.

5.3.4. If you are located in Canada, all Personal Data processing is carried out in compliance with the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) ("PIPEDA").  If you live in New Zealand, all Personal Data processing is done in compliance with the Privacy Act 2020's regulations and procedures.

5.3.5 If you live in California, all Personal Data processing is done in accordance with the California Consumer Privacy Act, Cal. Civ. Code 1798.100 et seq. ("CCPA") standards and procedures.

5.3.6 If you are located in Brazil, all Personal Data processing is done in line with the Lei Geral de Proteço de Dados ("LGPD") legislation and rules.

5.4 The Children's Online Privacy Protection Act («COPPA») governs the online collecting of personal information about minors under the age of 13 by persons or businesses subject to US jurisdiction, including children outside the US (affected person). Before providing Personal Data on the Site, Data Subjects must get parental approval. You may consent to the collection and use of your COPPA affected individual's information if you are the parent or guardian of that person. By emailing us at [email protected] you can withdraw your consent, inspect your COPPA Personal Data of your subject, request that it be deleted, and/or refuse to enable continued collection or use of your COPPA data subject at any time.


6. DATA PROCESSING'S PURPOSE

6.1 In order to provide you with the ability to use the Website and our Services, GEONIX receives stores, processes, and uses the Personal Data of the Subjects.  GEONIX may use the information GEONIX gathers from you for a variety of purposes, the most common of which is to provide our Services and information about them. GEONIX may also use the information for any other legal purposes that are permitted by law. Your personal information may be used for a variety of reasons, including but not limited to:

6.1.1 tracking purchases and usage data;

6.1.2 to process payments;

6.1.3 to detect, investigate, and prevent illegal activities or conduct that may violate the Terms of Use of GEONIX and this Privacy Policy;

6.1.4 to conduct internal research and development and to improve, test, and enhance the features and functions of our Service;

6.1.5 to properly fulfil tax-related and accounting obligations imposed by applicable laws;

6.1.6 to handle your orders and requests, including requests for technical support and assistance;

6.1.7 to contact you concerning, and conduct, surveys or polls you choose to take part in and to analyze the data collected for market research purposes;

6.1.8 meet our internal and external audit requirements, including our information security obligations;

6.1.9 to provide access to our Website and the Services;

6.1.10 to personalize your experience with our Service;

6.1.11 any other purpose as GEONIX determines, in our sole discretion, to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, public, and/or our Services,

6.1.12 or to comply with requirements of any applicable law.



7. CONSENT TO THE PROCESSING OF PERSONAL DATA

7.1 Before GEONIX processes your personal data, GEONIX gets your permission. Consent to the Processing of Personal Data 

By accepting this Privacy Policy, you acknowledge that you have achieved the age of majority or the legal age in your jurisdiction (usually 18 or older), that you are solely responsible for your conduct, and that you have read and completely understand the statements made in this Privacy Policy. 


7.2 EU Persons Consent to the Processing of Personal Data 

7.2.1 If you are an EU Person and GEONIX needs your consent to process your Personal Data, as required by GDPR, GEONIX will only process your Personal Data if you give us a freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data ("Consent"). 


7.2.2. When you register for an account with our Service, you can give your consent by checking the appropriate box. If you check the appropriate box, you irrevocably and unconditionally approve and agree that GEONIX may treat your Personal Data in the manner specified by your Consent. 


7.2.3 Your Consent applies to any and all processing actions involving your Personal Data that are carried out for the same or similar reasons. When there are numerous purposes for the processing, your Consent should be considered provided for all of them. 

7.3 Non-EU Persons Consent to the Processing of Personal Data

7.3.1 If you are not an EU Person, by transferring your Personal Data to Us via the Software or otherwise, you irrevocably and unconditionally consent and agree that, in line with this Policy, GEONIX shall be right to: 
  • to process your Personal Data provided to Us in any way, including collecting, storing, using, disclosing, sharing, and transferring (including cross-border) it, as well as your Personal Data collected from your use of the Service (i.e. your Personal Data which GEONIX collect automatically and/or from other sources); and 

  • to collect your Personal Data using cookies and web beacons (pixel tags). 


8. THE SUBJECTS' RIGHTS 

8.1 Please take your time reading this chapter. To use any of the above-mentioned rights, you must first contact our Customer Support Service. GEONIX may need to ask for further information to verify your identity. Requests that are excessively repetitious, exorbitant, or plainly unwarranted may be rejected. The right to access information. You have the option of contacting us to confirm whether or not GEONIX is processing your personal data. When GEONIX processes your personal data, GEONIX will notify You of the types of personal data GEONIX to collect about you, the processing purposes, the categories of recipients to whom personal data has been or will be shared, and the storage period or criteria used to calculate that period.

8.2 Right to revoke consent. If our processing is based on your consent, you may withdraw your consent at any time by contacting us or using the Website's capabilities. Your Personal Data will be destroyed instantly if you withdraw your consent at any time by replying to the email with your withdrawal. If you withdraw your consent, you may have fewer options for using the Website and/or Services.

8.3 Right to raise objections. You have the right to object to our processing at any time if it is based on a legitimate interest to run, maintain, and develop our business. GEONIX will no longer process your personal data unless GEONIX needs it to provide our services or if GEONIX can show that GEONIX has other compelling legitimate grounds for doing so that outweigh your interests, rights, and freedoms, or if GEONIX has legal claims. You have the right to stop us from processing personal data for direct marketing purposes, notwithstanding any prior consent given for such purposes, by contacting us or by utilizing the Website's functionality or unsubscribe options in connection with our direct marketing messages. 

8.4 Right to data processing limitations. You have the right to request from us that GEONIX restricts the processing of your personal data, as permitted by applicable data protection law, for example, to allow us to verify the accuracy of personal data after you contest the accuracy, or to prevent us from erasing personal data when personal data are no longer necessary for the purposes but are still required for your legal claims, or when our processing is unlawful. Processing restrictions may limit your ability to utilize the Website and/or the Services. 

8.5 Data portability is a legal right. In the event that our processing is based on your consent and carried out by automatic methods, you have the right to get your personal data from us in a structured, frequently used, and machine-readable format, as well as the right to independently transfer those data to a third party. 

9. DELETION AND STORAGE OF DATA 

9.1 GEONIX keeps your Personal Data on file for as long as GEONIX needs it to provide you with our Service and/or access to our Website. GEONIX may keep Data for a longer period of time, but only in a fashion that cannot be traced back to you. When Personal Data is no longer required, GEONIX securely deletes it while taking reasonable precautions to prevent unauthorized access or use. 

9.2 The territory of the European Union. GEONIX keep Personal Data for as long as it is required to provide our Services and/or access to our Website. When traffic information is no longer needed for transmission or, in the case of paid Services, until the end of the period during which the bill may be legitimately contested or payment pursued, it is wiped or made anonymous. Direct marketing and the provision of value-added Service information (including traffic information used for these purposes) are maintained for as long as they are required to provide these services, or until a User opts out of such usage under this Privacy Policy. Other information is kept for as long as GEONIX believes it is required for the provision of our service and/or access to our Website. This Section does not prohibit technical storage or access to information for the sole purpose of transmitting a communication or as strictly essential for us to offer the Service you requested. GEONIX attempts to anonymize data whenever possible, as stated in the GDPR statement. If you want to exercise your right to erasure, GEONIX will also request that all of your data be deleted from our suppliers.


9.3 The territory of the United States of America. Unless applicable legislation requires or permits a longer retention time, GEONIX will keep gathered information for as long as it is needed to fulfil the purposes mentioned in this Privacy Policy.

9.4     The amount of time GEONIX keeps information varies based on where GEONIX collects it and the laws in place, but GEONIX always tries to keep it for as long as GEONIX need it to offer, improve, or personalize our service.


9.5 GEONIX do not knowingly collect or store information from children under the age of thirteen. If GEONIX discovers that GEONIX has unintentionally collected personally identifiable information from a child under the age of 13, GEONIX will take reasonable steps to remove the information from our records. Please contact our Support Service at [email protected] if you believe GEONIX have any information regarding minors under the age of 13.


10. SECURITY OF DATA


10.1 GEONIX protects the information supplied to Us by adhering to generally accepted industry standards, both during transmission and once GEONIX receive it. To offer reasonable protection for your Personal Data, GEONIX maintains technical, physical, and administrative security measures. GEONIX or our contractors protect your information from unauthorized access, loss, manipulation, falsification, destruction, or disclosure while GEONIX or our contractors process it. This is accomplished using administrative, technical, and physical procedures that are appropriate.

10.2 You acknowledge that there is no 100 per cent secure method of Internet transmission or computer storage. As a result, GEONIX cannot guarantee its complete safety.


10.3 Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data processed solely to identify a human being, health-related data, data concerning a person's sex life or sexual orientation, and criminal offence data are never processed by us.


11. CONTRACTORS


11.1 GEONIX collaborate with third-party service providers who help us with website creation, application development, hosting, maintenance, and other tasks. They could be based outside of the European Economic Area. As part of delivering those services for Us, these contractors may have access to or handle Personal Data on our behalf. GEONIX only supplies these Service providers with the information that is reasonably necessary for them to execute their tasks.

11.2 All data transfers are carried out in compliance with the most stringent security standards. Transfer of Personal Data to countries outside of the European Union may be feasible only if you have given us your consent.


11.3 All data processed by the Us is exclusively stored in secure hosting facilities in the European Union.

11.4 To aid in the safe processing of your payment information, GEONIX use a third-party payment processor, presently Paddle, Stripe> ("Payment Processors"). If you pay by credit card, the payment information you enter on the Services is encrypted and sent directly to the Payment Processor. GEONIX does not keep your payment information on file, and GEONIX has no control over or responsibility for the Payment Processors' acquisition or use of your data. Access the Payment Processors Privacy Policy to learn more about how the Payment Processors keep and utilize your Payment Information.


11.5 In conjunction with the services they provide to us, GEONIX may share your personal data with our insurers and professional advisers (lawyers, bankers, auditors, corporate financiers, and brokers). GEONIX shall require the recipient of your personal data to maintain it secret and secure if GEONIX shares it with those processors. GEONIX may provide personal data to the courts, lawyers advising the other parties to an issue, or other experts in order to provide you (or your company) with our services (such as overseas law firms, patent agents, forensic accountants, or barristers).


11.6 To measure and improve the performance of our advertising activities, GEONIX uses Facebook. Please see Facebook's Privacy Policy at https://www.facebook.com/business/m/privacy-and-data for additional information on the company's privacy practices.


11.7 To compile thorough information on website visitors, GEONIX uses Google Analytics. The statistics are collected on Google's server, and the User is only responsible for placing JS code on his or her website's pages. When the User opens the page in his or her web browser, the tracking code is activated. Visit the Google Analytics Privacy Policy at https://policies.google.com/privacy?hl=en-US%20s-privacy-policy/ for additional information about the company's privacy practices.


11.7 Yandex Metrika is used to study user behaviour and evaluate website traffic. Please see the Privacy Policy at https://metrica.yandex.com/about/info/privacy-policy for more information about Yandex Metrika's privacy practices.



12. ADDITIONAL PROVISIONS


12.1 Make sure you don't miss anything by looking over our other provisions. If you have any questions, please contact our Support Service, and GEONIX will gladly respond.  This Policy's Implementation The Website is covered by this Privacy Policy. This Policy is no longer valid once you've been referred to another website.


12.2 This Policy has been accepted. GEONIX presumes that all Users have read and agreed to the contents of this page. This Website should not be used by anyone who does not agree with this Privacy Policy.


12.3 Our Policy has been changed and updated. This Privacy Policy may be updated. GEONIX encourages You to review this Privacy Policy on a regular basis so that You are constantly aware of what data GEONIX collect, how GEONIX use it, and with whom GEONIX  share it.

12.3.1 GEONIX reserve the right to change or augment the Policy at any moment without prior notice to you. The revised version of the Policy takes effect as soon as it is made available on the Website.


12.3.2 You automatically accept and agree to such amendments and/or supplements to the Policy if you continue to use the Website and/or the Services after such amendments and/or supplements to the Policy.


12.4 Liability Limitation. GEONIX are not liable for any injury or damage you or a third party may incur as a result of an incorrect interpretation or misunderstanding of the provisions of this Policy. Any Subject has the opportunity to contact GEONIX for clarification on the terms of this Policy before accepting them.

12.5 Severability. If a court of competent jurisdiction finds any provision of this Policy to be illegal, that provision will be declared null and void, and the remaining parts of this Agreement will continue in effect.

12.6 Resolution Of disputes and Jurisdiction

12.6.1 Any claims and disputes relating to it and/or GEONIX, its interpretation or violation, termination or validity, and relations arising out of or pursuant to the Policy shall be governed, construed, and interpreted in accordance with the laws of Bulgaria. The Subjects' personal data will be saved and handled in line with the law that applies to them. 

12.6.2 All issues or conflicts between the parties over the Policy's execution must be handled through dialogue. If the parties do not reach an agreement within 40 (fourty) days, the matter may be brought before a court in INTERNET CONNECTION BROKER LTD's jurisdiction.