Your privacy is important to us. This Privacy Policy governs the manner in which www.siila.org (the “Siila”,”Platform”, “Website”, “we” “us” or “our”) Website, (Owned and Operated by “Equanimity Partners SL”), collects, uses, maintains and discloses its user’s Personal Data. The purpose of this Privacy Policy is to assist you in understanding the purpose for which we collect, use, disclose and process the Personal Data you have provided to us or we collect in accordance with The Spanish Data Protection and Digital Rights Act 3/2018 (the “Data Protection Act”), the Spanish Organic Law 15/1999, about protection of personal data, General Data Protection Regulation (EU GDPR), California Consumer Privacy Act (CCPA) and other applicable international data privacy laws. We are devoted to protecting your privacy. Please take a moment to check our privacy practices. “Siila” uses and makes all attempts to protect all information when you use our Website or use any of our services.

By interacting or submitting any Personal Data or any other information to “Siila” for any events, it is deemed to be your full consent to permit us to collect, use and disclose such Personal Data and other information to our authorized service providers and relevant third parties in accordance with this Privacy Policy.

For the purpose of this Privacy Policy using of any term such as, “You”, “Your”, “They”, “Their”, “Seeker”,” Service Provider” etc. will be deemed to be the representation of Users or Members of the www.siila.org.

1. WHO WE ARE:

“Siila” is a global interactive and collaborative vertical platform including a Social Media Module, which offering its users to access Comprehensive resources from religious, philosophies, indigenous and tribal as well as networks of Teachers, Corporates, NGOs’ and practicing places for Mediation and yogic communities.

The “Siila” platform including a Social Media Platform module specially designed for the many type of users, including but not limited to Seekers, Spiritual Guide, Teacher, Academy, Center, Author, Corporate, Organizer, NGOs etc. (the “Service Providers”) who are interested to provide different Yoga and Meditation relevant coaching, training, consultation, guidance, Techniques etc. (the “Services”) services and Seeker (The “Client”) who desire to receive the services offered by the Service provider etc. All type of registered user will deem to be Member of our Platform. And the Public Figures are the general member who can use our platform for any purpose including sharing their spiritual paths.

“Siila” is a collaboration base platform where the seeker will be treated as a service provider if they provide any services through our platform and the service providers will be treated as a Seeker/Client if they desire to purchases any services offer by the Service Providers.

2. HOW AND WHAT TYPE OF INFORMATION WE COLLECT FROM YOU:

While using our Platform, we may ask you to provide us with certain Personally Identifiable Information (PII) that can be used to contact or identify you. Personally identifiable information (PII) may include, but is not limited to your Full Name, Email, Phone Number, Address, City, State, Religion, preference ofyoga and meditation practices, Age, Dateof Birth, Language, Country, Zip Code, Social Media Profile Link (“Personal Data”). For the purpose of this Privacy Policy, Personal Information (the “Personal Data”) means any information relating to an identified or identifiable individual. We may obtain or collect (User’s voluntarily provided information and our automatically collected information from the User) Personal Information relating to you from various sources described below.

2.1 User-Provided Information:

1. Registration with Siila.

   You may not require to register as a general user or to provide Personal Data to visit our website and peruse its general contents. But you must need to register and provide certain Personal Data in order to use our Platform and its services. You may just Sign Up/Register using your Full Name, email address and password to get the access in the Dashboard. Upon access to the Dashboard you will have option to setup and fulfill your account by completing the Personal info section of the Dashboard and you will have all the options and tools there to fulfill your purpose to register and use our Platform. Please see the Terms and Conditions for more information on the registration process and requirements. We hereby disclaim, and you hereby release “Siila” from any and all liability arising from any unauthorized registration and from any related claims, losses or damages alleged, arising from or relating to any unauthorized user registration and/or collection of Personal Data in connection with an unauthorized registration.

2. Account Information.

   Upon registration and access to the Member dashboard you will have option to complete your account by providing certain of your Personal Data in the Account option under the “Personal Info” section of the Dashboard, which may include your full name, email address, profile picture, and a phone number, mailing address, City, State, Country, Province, Zip Code, Website and social media profiles/pages including but not limited to Facebook, Twitter, Instagram, YouTube, LinkedIn etc.etc.

3. Profile Information.

   To use certain features within the ”Siila”, Categorizes and understanding your purpose of use of our platform, we may also ask you to complete your profile with us by providing certain of your Personal Data in the Profiling option under the “Personal Info” section of the Dashboard, which mayinclude your Date of Birth, Gender, Language, Religion, Professional Certificate, Date of Birth of your Kids, Your photo as a profile picture, Banner for your profile and other information or data as needed to fulfill your purpose to use our platform If you have any question or concerns regarding thispersonal data collection process please contact us at contact@Siila.org

4. Plug-In:

   “Siila” may have optional o-authorization registration option with “plug‐in” tools or platforms like Facebook, Google etc. The tool may allow an automatic registration and a direct connection with those tools or platforms servers through your browser and the registration information will be transferred to us by those tools or platforms. If you register with us using the login credentials of such tools or platforms or if you otherwise agree to associate your “Siila” account with a tools or platforms, you are also subject to the “Terms and Conditions” and “Privacy Policy’ of such tools or platform’s. We use the “OAuth" (open authorization) protocol to enable us to access this information without collecting your password when you agree to allow another tools or application to access your account information.

5. Payment Information.

   We don’t locally process any payments and we don’t collect any payment information by us or transferred to us either through our Platform. All payments will be handled through the secure gateway system either through our Website and or otherwise. We are using “Stripe” as our payment getaway and no payment data will be collected by “Siila” itself. At the point of payments through the secure gateway system, you are transferred to a secure page of “Stripe” payment service provider and any data collected through the Stripe will be conduct by the Privacy Policy of “Stripe” you can find here https://stripe.com/privacy

6. Communications with “Siila” Via Live Chat or Other ways.

   When any user or member communicates with “Siila” using our support contact form, support email or live chat option or with a phone call we may collect personal information through such communications.

7. Social Media:

   We may collect your social media profiles/pages ( i.e. Facebook, Twitter, Instagram , YouTube, LinkedIn etc. ) and Website links. We may collect embedded content from your social media profile and we may receive personal information about you from such social networking platform subject to the Terms and Conditions and Privacy Policy of those social networking sites.

8. Feedback or Review:

   We also may collect Personal Information if included in any Feedback or comment provided by our users. Please see the Terms and Conditions for more information on Feedback. Feedback and similar communications from our users allow us to measure areas of interest, improve the efficiency and offerings on the “Siila”, provide users with important information, and build features and functionality that will enhance your use of the “Siila” Platform and its services. You are not obligated to provide us with Feedback or comment.

9. Other Information.

   The user may otherwise choose to provide us information when you fill our Service inquiry form, Landing Page from, conduct a search, update or add information to your”Siila”or interest with your social media account.

2.2 Information Collected via Technology:

To make our Platform and Services more useful to you, our servers which may be hosted by a third-party service provider called web server or Hosting service provider, Analytic tools and widegate? ; which may collect information from you, including Online Identifiers, , such as operating system type and version number, manufacturer and model; browser type; screen resolution; IP address; unique device identifiers etc., that is automatically assigned to your electronic devices including but not limited to Computer, Mobile, Tab or other similar devices, when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We may collect Non-Personal Information through the use of General Tracking Information and Click Path Tracking (cookie technology) described in the Cookies Policy below.

We may keep track of the pages visited by each user. Our web server automatically collects some information about you when you request pages from our server, including your IP address. Your IP address is a number that is used by computers connected to the Internet to identify your computer so that data (such as the web pages you request) can be sent to you. We aggregate this data with data on the pages visited by other users to track overall visitor traffic patterns. We use this information to improve our Site by making it more responsive to the needs and preferences of our users. This information does not identify you personally.

We use technologies such as cookies, beacons, tags and scripts to analyze trends, administer our Platform and its services, track users movements around the Platform and its services, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We may gather some certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically generated log information with Personal Information and Non-Personal Information we collect in order to improve the services offered on the “Siila” and to help improve Site functionality.

3. THIRD PARTY SERVICE PROVIDERS WE MAY USE:

To make our Platform more useful to you and to fulfill your purpose to use our platform, we may use the following Third party service provider, tools and widget

1. Amazon Services:

   Amazon Web Services (AWS),Amazon Simple Email Service, Amazon Glacier; Amazon Appstore; Amazon Advertising, Amazon Mobile Ads; Amazon Omakase; Amazon Payments

2. Google Services:

   We may use Google Services i.e API Google Map, Google Optimize, Google Optimize 360; Google analytics(Including Google Analytics with anonym zed IP; Google Analytics Advertising Reporting Features; Google Analytics Demographics and Interests reports, Google Analytics for Firebase ,YouTube Analytics and Reporting API, Google Ad Manager; ; Google Ad Manager Audience Extension), LinkedIn’s and Facebook's ad tracking feature and remarketing pixels and other third-party vendors to collect information anonymously and report website trends without identifying individual visitors. Google, LinkedIn and Facebook use its cookie to track visitor interactions. Website owners can view a variety of reports about how visitors interact with their website so they can improve their website and how people find it.

3. Hotjar Services:

   Hotjar Form Analysis & Conversion Funnels, Hotjar surveys, Hotjar Recruit User Testers; Hotjar Heat Maps & Recordings, Hotjar Poll & Survey widgets

4. Others:

   We may use some other third-party tools, widget and application Jetpack ; Game Analytics; Sanoma, Mailchimp, OAuth; Mailer Lite widget

The above third party service providers will not use any external services and respects your privacy. No visitor or user specific data is collected and you can easily opt-out of tracking by enabling “Do Not Track” in their browser settings.

4. PURPOSES OF COLLECTION AND USE OF YOUR PERSONAL DATA

We may use your Personal Data to provide our services to you smoothly and to meet your satisfaction to use our Platform, and to address your needs and concerns. For the following purpose we may collect and use your Personal Data, including but not limited to about our users for the following purposes:

1. Personify you experience to use of our Platform.
2. Maintain your interest and account with us.
3. Analyze and enhance our communications and strategies.
4. Provide our services to you and your services to other users of the platform
5. Send you texts, emails or other communications regarding general adherence information, Service maintenance, updates, or changes to this Privacy Policy or any other relevant agreements.
6. create, manage and control your account and dashboard information, and to verify access rights to the Platform and our Services
7. Respond to your inquiries, commercial requests, comments and provide customer support.
8. To protect the security and safety of our users and Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users. to respond to claims of any violation of our rights or those of any third parties;
9. Comply with all applicable legal requirements, industry standards and our policies, including, reasonable necessity to comply with legal process and law enforcement instructions and orders.
10. enforce this Privacy Policy or our Terms and Conditions

We will not share any of your personally identifiable or transactional information with any person or entity, other than as set out in this policy. We do not rent, sell, or share our users Personal Data, with any people, entity or non- affiliated companies for marketing purposes (including direct marketing purposes) without your explicit permission.

5. TO WHOM WE MAY DISCLOSE OR SHARE YOUR PERSONAL DATA

We do not share your personal data with other people or organizations that are not directly linked to us. With your prior permission or consent, we may disclose your Personal Data under the following circumstances and authority:

1. To our employees, contractors and/or related entities.
2. To our third party service providers as mentioned in this privacy policy or to other organizations that provide services on our behalf such as dealing with online payments and other forms of payment processing and preventing fraud.
3. To our existing or potential affiliates and business partners.
4. To any other organization that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer takes place, we will use reasonable efforts to try to make sure that the organization we transfer your personal data to uses it in line with our privacy policy.
5. To any law enforcement agency, court, regulator, government authority, or other organization if we are required to do so to meet a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.
6. To protect our legal rights, liabilities, and interests.

Any entity or organization which accesses your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and adhere to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards. We will not share your personal data with anyone else for their own marketing purposes unless we have your permission to do this.

By providing us with your Personal Data, you consent to the disclosure of your Personal Data to third parties who reside outside the Spain and EU and acknowledge that we are not required to ensure that those third parties comply with the Spain and EU privacy laws. We have sole discretion to take all reasonable steps to secure the information against unauthorized access or disclosure. In no event, we do not sell trade, rent or otherwise transfer your any identifiable information to any third parties except the above circumstances.

6. THE PURPOSES FOR WHICH YOUR PERSONAL DATA IS PROCESSED

If you visit and use our Platform, we may collect, use and process your Personal Data in accordance with the terms set out in this Privacy Policy. Your Personal Data may be used for the following purposes (hereinafter “purposes”):

1. Web browsers/administration.

   We may use your Personal Data for administrative purposes, including to help us better understand how our customers access and use our Websites and applications; to provide our prospective partners, service providers, regulatory bodies or other entities with reports; to set up and maintain security, anti-piracy and fraud-prevention measures, along with other services designed to protect our customers, partners and ourselves; and to enforce our regulations, directives and procedures.

2. Marketing.

   We may, within the confines of the law, use your Personal Data for marketing and promotional purposes, including for email communications and other means of electronic communication. For example, we may use your Personal Data to send you newsletters; inform you of special offers, promotions, competitions, and services; invite you to an event organized by us or our Members; or send you information that we think will interest you.

3. Communication.

   We may use your Personal Data to communicate with you, including responding to requests for assistance. We may communicate with you in a variety of ways, including via email, your social media accounts and/or text message, if you have agreed.

4. Customer Support.

   We may use your Personal Data for customer support purposes, including suggesting services and offering you technical support. Similarly, we may use your Personal Data to provide you with adapted, personalized content and information based on your use of our platform

5. Research and development.

   We may use your Personal Data for research and development purposes, in particular to improve our Platform and its services. We may also use it for research and analysis purposes to improve our Services, services, business activities, operations and processes.

6. Legal obligations.

   We may use your Personal Data to comply with legal obligations, including responding to an authority, a court order or a preliminary disclosure request. Also, we may use your Personal Data where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, directives and other policies.

7. THE BASIS ON WHICH YOUR PERSONAL INFORMATION IS PROCESSED:

As a responsible company, we need a lawful basis for collecting and/or processing your data. We generally rely on a number of grounds (reasons) for this processing within our business activities. We process your personal information in accordance with the provisions set out in the GDPR and the relevant applicable data protection laws and regulations. The legal bases for processing your personal information are:

1. To comply with contractual obligations.

   When you user our Platform for any purpose or use any services offered through our Platform, the purposes of processing your personal data are primarily determined by that use and we will process your information so that we can provide your purpose of use our platform and services.

2. As a result of your consent.

   When you have consented to the processing of your personal information by us for certain services through the Platform, you can withdraw this consent at any time by following the instructions provided in the subscription process or by contacting us at contact@siila.org

3. There is a legitimate interest

   For the purpose of following legitimate interest we may use your Personal Data without your consent, but we will inform you for any such use if needed. The legitimate interest of using your data may including but not limited to

   • analyze and optimize our Platform;
   • maintain the security and safeguard of our Platform and its user;
   • Prevent and investigate any criminal acts.
   • protect our legal rights, liabilities, and interests

We will follow the entire legal obligation to use your personal data for the purpose legitimate interest. As any other entity we are subject to legal obligations and regulations.

8. LIMITED LIABILITY OF PRIVACY PRACTICE:

1. Links to Third Party Websites:

   Occasionally a user may include links (“Links”) that enable other users to access websites that are owned and operated by third parties (e.g., LinkedIn, Google, Facebook, etc.) (“Third Party Sites”) and which are provided as a convenient method of accessing information regarding employers or candidates that may be useful to other users. You represent that if you are including Links in our Information that you have obtained all necessary permissions from any affected individuals to provide any Links to pages containing information of such individuals (i.e., access to an individual’s LinkedIn page, etc.). As a user who may use information provided on a Third Party Site, you acknowledge that we are not affiliated in any way with any Third Party Sites, and that if you click on a Link to a Third Party Site, once you have left our website, we have no further control over the content and materials that you will be viewing on the Third Party Site. We are not responsible for the content, accuracy, or opinions expressed on any Third Party Site. We will not, and are under no obligation to, investigate, monitor or check the Third Party Sites for accuracy or completeness, or for any obscene, scandalous, inflammatory, pornographic, indecent, profane, defamatory or unlawful content or materials. We are not responsible for the privacy policies applicable to Third Party Sites. Once you link to a Third Party Site, this Privacy Policy is no longer in effect.

2. Social Media Pages/Interactive Services:

   If you interact with our Platform or with any of our third party service providerby and through the Interactive Services (an Integrated Services Digital Network (ISDN)) or any Social Media Platform, you should be aware that the Personal Data that you submit by and through such platform can be read, collected and/or used by other users of those platforms(depending on your privacy settings associated with the accounts you have with such Social Media Platform, if applicable), and could be used to send you unsolicited messages or otherwise to contact you without your consent. We are not responsible for the Personal Data that you choose to submit in this Platform. The Social Media Platform that is operated independently may have its own privacy or security policies. We will have no responsibility for any violation or breach of the privacy o and security practices of such Social Media Platform. We encourage you to review the privacy and security policies and settings of the Social Media Platform you interacted to, it will help you understand those Social Media Sites’ privacy practices.

3. Business Relationships:

   During your use of our platform, you may encounter links to the sites of “Siila”’s service providers or business partners. We are not responsible for the privacy practices of other businesses. We strive to comply with all applicable laws in the EU and Law around the world that is designed to protect your privacy. Although legal requirements may vary from Country to Country or State to State. We intend to adhere to the principles outlined in this Privacy Statement even if, in conjunction with the above, we transfer your information from your country of residence to countries that may not require the same level of protection for your information. Our goal is to protect your information no matter where that information is collected, transported, or retained.

4. Links to Third Party Websites:

   Occasionally a user may include links (“Links”) that enable other users to access websites that are owned and operated by third parties (e.g., LinkedIn, Google, Facebook, etc.) (“Third Party Sites”) and which are provided as a convenient method of accessing information regarding employers or candidates that may be useful to other users. You represent that if you are including Links in our Information that you have obtained all necessary permissions from any affected individuals to provide any Links to pages containing information of such individuals (i.e., access to an individual’s LinkedIn page, etc.). As a user who may use information provided on a Third Party Site, you acknowledge that we are not affiliated in any way with any Third Party Sites, and that if you click on a Link to a Third Party Site, once you have left our website, we have no further control over the content and materials that you will be viewing on the Third Party Site. We are not responsible for the content, accuracy, or opinions expressed on any Third Party Site. We will not, and are under no obligation to, investigate, monitor or check the Third Party Sites for accuracy or completeness, or for any obscene, scandalous, inflammatory, pornographic, indecent, profane, defamatory or unlawful content or materials. We are not responsible for the privacy policies applicable to Third Party Sites. Once you link to a Third Party Site, this Privacy Policy is no longer in effect.

9. PERSONAL DATA SHARED ON OUR NETWORKING PLATFORM AND EXCHANGED BETWEEN THE USERS

We have ultimately no oversight over the shared on our networking platform and exchanged between the users or members that might occur in the occasion of using our social networking platform; participate in an event, during any course and any other way directly or through our platform. Also, Service Provider may offer free Newsletter and the clients can choose to Opt-in to such Newsletter using their email. In any event, if any breach or wrongful incidents occurred with the Personal Data shared between the users or members, in such case we will have no responsibility or liability to such breach or wrongful incidents. Users or Members will have option to report such breach or wrongful incidents to “Siila”, such reported incidents, from the Service provider and/or the Client will triggers disciplinary measures that we may judge appropriate such as a temporary or permanent ban, and can even go to legal actions against the individual(s). We encourage all the user and members to engage in a mutually respectful, tolerant and meaningful manner.

10. THIRD-PARTY PRIVACY POLICIES AND DISCLOSURE

During your use of our platform and its services, you may be able to access or encounter links of our business partners, technology, software, Sponsored Offers and services owned and controlled by third parties. By clicking on a logo, images or links displayed on the “Siila”, those third-parties may collect information about you when you use their services or communicate with them. We are not responsible for the privacy practices of other businesses and any use of such third-parties or any submission of information to them will be subject to the applicable Terms and Conditions and privacy policy of those third-parties. We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety.

11. ADVERTISING AND ANALYTICS:

To promote our site and services, we may use third-party advertising and analytics platforms, including but not limited to Google ads, Facebook Ads, Amazon Advertising and Amazon Mobile Ads , Google Analytics, Hotjar Analytics, ,Facebook's ad tracking feature, Game Analytics; etc.. We may also use remarketing or retargeting pixels through Google, Facebook and LinkedIn. We do not share personal information that directly identifies you with third-party advertisers for their direct marketing purposes.

1. Behavioral Remarketing:

   We may use the Google, and Facebook remarketing service to advertise on third party websites to previous visitors to our site. It could mean that we advertise to previous visitors who haven't completed a task on our site, for example using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network or somewhere on LinkedIn and Facebook. Third-party vendors, including Google, LinkedIn and Facebook, use cookies to serve ads based on someone's past visits to the “Siila” site. Any data collected will be used, share or process I accordance with this privacy policy, as well as the Privacy Policies of Google, LinkedIn & Facebook.

2. Google Ad-Words:

   Google AdWords remarketing service is provided by Google Inc. You can Opt-Out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page you can found here: http://www.google.com/settings/ads/ . Google also recommends installing the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout for your web browser. Google Analytics Opt-out browser Add-on provides website visitors the ability to prevent their information or data from being used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

3. Facebook Ads:

   Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from the Facebook and other participating companies through the Digital Advertising Alliance in the USA http://optout.aboutads.info/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

4. Amazon Advertising:

   Amazon remarketing service is provided by Amazon Inc. You can learn more about interest-based advertising from Facebook by visiting this page Amazon Advertising Guidelines and Acceptance Policies you may found here https://advertising.amazon.com/resources/ad-policy/creative-acceptance . To opt-out from Amazon interest-based ads follow these instructions from Amazon Advertising Preferences https://www.amazon.com/adprefs .

5. Google Analytics:

   We may use Google Analytics. Google Analytics uses “cookies”, which are text files placed on your computer or mobile device, to help the website analyses how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. You can refuse the use of Google Analytics by clicking on Opt-Out (https://tools.google.com/dlpage/gaoptout )

6. Facebook Conversion Tracking Pixel:

   This tool allows us to follow the actions of users after they are redirected to a provider's website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous. This means that we cannot see the personal information of any individual user. However, the collected data are saved and processed by Facebook. We are informing you on this matter according to our information at this time. Facebook can connect the data with your Facebook account and use the data for their advertising purposes, in accordance with the Facebook's privacy policy, you can found here: https://www.facebook.com/about/privacy/ . Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. In addition, a cookie will be saved onto your computer for these purposes. By using our website you agree to the data processing associated with the integration of Facebook pixel. You can revoke your permission using https://www.facebook.com/ads/settings .

7. Hotjar, Jetpack ; Game Analytics;:

   We may use some other analytics tools or platforms, including but not limited to Hotjar Form Analysis & Conversion Funnels, Hotjar surveys, Hotjar Recruit User Testers; Hotjar Heat Maps & Recordings, Hotjar Poll & Survey widgets; , Jetpack ; Game Analytics; Sanoma, Mailchimp,etc. which may uses “cookies”, to help the website analyses how users use the site. You can refuse the use of those Analytics following their Opt-Out or other option in accordance to their Privacy policy and practices.

12. SECURITY OF YOUR PERSONAL DATA

We are committed to protect or safeguard the data we collect from you. We take all reasonable and necessary steps to protect the information provided by you from unauthorized access. We may follow commonly accepted industry standards to protect the Personal Data submitted to us. We are using SSL CERTIFICATE and other Encrypt security system for ensuring and protect the confidentiality of your personally identifiable information. However, no method of transmission over the Internet or method of electronic storages is 100% safe and secure. Therefore, we are not in the actual position to guarantee the absolute security of your information. If you have any questions about security on our website, you can submit us an email we may take all reasonable steps and may allow third parties to assist us regarding processing your Personal Data and adopt proper security measure to safeguard your information for ensuring security.

13. FAIR INFORMATION PRACTICES:

We may apply Fair Information Practices as the law define and permitted. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. As required by the law we will ensure that all the Users of our Website or Platform will have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only those Users have enforceable rights against data users, but also that User have to recourse courts or government agencies to investigate and/or prosecute non-compliance by data processors.

14. CHILDREN PRIVACY POLICY:

We take children's privacy seriously. Our website complies with the GDPR and Children’s Online Privacy Protection Act ("COPPA") and the Children's Online Privacy Protection Law under the local territory of every user of our website. We do not knowingly collect or solicit Personal Data from anyone under the age of 13. If any child under 13 wish to use our platform, they can do so upon parental or guardian consent in accordance with applicable law. Where required by applicable law, we may ask children for consent from their parents or legal guardians before we approve any use of our platform. We instruct children under the age of 13 to insert their parent's or guardian's email address and banking information upon any interaction to us.

We may use Email Consent option to get parental consent. We will send a consent letter to such email address you use to create an account with us, to get parental consent to use our platform. In the email, we may explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will reject you access and use of our Platform. And we will delete all the information we collected from you.

If any parent believes that their child is participating in any activity of our Platform, that collects Personal Data and the parent didn’t receive any email providing notice or seeking your consent, please contact us at contact@siila.org to provide us permission or request to delete your child's account and any associated information.

If we have to collect any children data, we will do so my complying with the Law and regulation for the Children’s Data practice, we will maintain the following legal requirements

• We will not require a child to disclose more information than is reasonably necessary to use our platform.
• Parents can review their child's Personal Data, contact us to delete it, and refuse to allow any further collection or use of their child's information.
• Parents may allow us to the collect and use of their child's information, and in the same time can disallow us to disclosure of such collected data to any third-parties unless that is part of the service.
• Parents can review, delete, manage and refuse to share their child's data , through account settings on our website, through our support staff or contacting us directly
• We will notify parents directly before collecting Personal Data from their child. The notification may include a) the data we may collect and how it might be disclosed; b) the link our privacy policy, and c) the option to provide consent or reject it. Also, if the parent doesn't provide any consent within a reasonable time, we will delete the parent's and child's online contact info from our records.

At any time, if any parent wishes to remove their child's information or refuse us to further collection of Personal Data from their children, they can request us to do so by sending an email to contact@siila.org, that we delete from our records the Personal Data we have collected in connection with those children. Upon any parental request we will remove all the collected information of their children immediately Also, Parents can request access to, change, or delete their child’s Personal Data by contacting us here. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any Personal Data.

15. PRIVACY PRACTICE UPON BUSINESS OR OWNERSHIP TRANSFERS

We may sell, transfer, or otherwise share all or some parts of our assets in connection with an actual or contemplated merger, reorganization, business transaction, or in the event of bankruptcy. In such scenarios, your information may be one of the assets transferred. We will post a notice or otherwise notify you and collect your consent, as may be required by law, before the information is transferred and becomes subject to a different privacy policy.

16. GOVERNING LAW AND JURISDICTION

This Privacy Policy has been prepared based on provisions of the Spanish Data Protection and Digital Rights Act 3/2018 (the “Data Protection Act”), the General Data Protection Regulation (GDPR) of the European Union (EU), California Consumer Privacy Act (CCPA), Children's Online Privacy Protection Act (COPPA), California Online Privacy Protection Act of 2003 (CalOPPA), other applicable USA and International data protection law and other relevant law of the local territory of the user. We and each user may submit to the exclusive jurisdiction of the local territory of the users.

17. COMPLIANCE WITH LAWS OR REQUESTS FROM LAW ENFORCEMENT:

In the following circumstances, we may disclose your Personal Data according to your wish or regulations by law with

1. Your prior Consent or permission;
2. By the applicable law within or outside your country of residence, legal process, litigation requests;
3. By requests from public and governmental authorities;
4. if it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of service or as otherwise required by law;
5. To protect our legal rights and interests; and
6. To secure the information against unauthorized access or disclosure Siila takes all the reasonable steps.

We encrypt the transmission of data on pages where you provide payment information. However, no security or encryption method can be guaranteed to protect information from hackers or human error. In no event, we do not sell trade, rent or otherwise transfer your personally identifiable information to any third parties except the above circumstances.

18. INTERNATIONAL DATA TRANSFER POLICY

Please be aware that, our platform is registered and operated from Spain but we are offering our services to the international user. Personal Data we collect may transferred to, stored, and processed in any country where one or more of our sites or services are based or have facilities or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, while other countries may not have the same standards of data protection as those in your home country, we will continue to protect the Personal Data that we transfer in line with this privacy policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

1. Outside Spain:

   By submitting any of your Personal Data to us, you are transferring your Personal Data to the Spain and you consent to such transfer.We do not represent or warrant that the Website or any part thereof, is appropriate or available for use in any particular geographic location. If you choose to access our Website, you do so on your own initiative and at your own risk, and are responsible for complying with all local laws, rules, and regulations applicable in your jurisdiction. If you are visiting the Website from outside Spain, please be aware that your information will be transferred to, stored and processed in the Spain where our servers are located and our central database is operated. By using the Website, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy.

2. Outside The EEA:

   Please note that some of our service providers may be located outside the European Economic Area (the “EEA”). In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of protection of personal data, or enter into legal agreements ensuring an adequate level of data protection. We may transfer our databases containing your Personal Data in connection with the transfer or sale of all (or substantially all) of our business assets, or in the event of a merger, consolidation or similar transaction.

IF YOU ARE LOCATED IN THE EUROPEAN ECONOMIC AREA, WE MAY PROCESS YOUR PERSONAL DATA FOR THE ABOVE PURPOSES WHEN

1. YOU HAVE CLEARLY CONSENTED TO THE USE OF YOUR PERSONAL DATA,
2. WE NEED YOUR PERSONAL DATA TO PROVIDE YOU WITH SERVICES OR TO RESPOND TO YOUR INQUIRIES,
3. WE HAVE A LEGAL OBLIGATION TO USE YOUR PERSONAL DATA
4. WE HAVE A LEGITIMATE INTEREST IN USING YOUR PERSONAL DATA TO ENSURE AND IMPROVE THE SAFETY, SECURITY, AND PERFORMANCE OF OUR SERVICE.

We do not share any of your personally identifiable or transactional information with any person or entity, other than as set out in this policy. No other third party receives your personally identifiable information or other transactional data. However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

19. AUTO RESPONDERS AND MARKETING OPT-OUTS:

We may use auto responder’s tool to communicate with you by e-mail. You may opt-out of receiving emails and other messages from us by following the instructions in those messages or directly use the user settings on your personal dashboard once signed in. We may also use the information that you provide to us to communicate with you about our current activities or to notify you about any updates or changes to our services. If you decide that you would no longer want to receive such messages you can opt-out from receiving such emails from us. In order to opt-out you can click on an unsubscribe link provided at the bottom of every email or as described in that email.If you have difficulties opting out, you may contact us at contact@siila.org .

20. ANTI-SPAM POLICY:

We also hate spam or junk e-mail (unsolicited commercial e-mail) as you do. We endorse and comply with the requirement of the Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM Act of 2003) and other applicable unsolicited commercial e-mail laws. If you subscribe with us, there will have always an option of unsubscribing immediately.

21. CHANGE TO THIS PRIVACY:

This Privacy Policy may change from time to time. We may not diminish your rights under this Privacy Policy without your consent. We have sole discretion to update, amend, modify, and enact any part or all the policy and procedure in this Privacy Policy at any time without any prior notice. Any such changes, update, or modification will be effective immediately upon posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its policies.

22. TRACKING PRIVACY POLICY:

We don't track you personally and we never sell your data. Here is what we track: we track how users use our site in general so that we can make it better. We are monitoring traffic, usage activity, site performance, and we use general analytic tools so that we can improve your experience. We do not associate any of this data with you personally. We never sell or share your personally identifiable information unless required to do so by law.

23. CHOICES YOU HAVE ABOUT YOUR INFORMATION:

You may, of course, decline to submit information to us, in which case you may not be able to use our website or purchase any Services from us. You may also control the types of notifications and communications we send, limit the information shared within the Siila Platform about you, and otherwise amend certain privacy settings.

You have certain rights under existing data protection legislation including the right to request a copy of the personal information we hold about you if you request it from us in writing. You can exercise the following rights in accordance with this privacy policy.

1. Right to access: the right to request copies of your personal information from us;
2. Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;
3. Right to erase: the right to request that we delete or remove your personal information from our systems;
4. Right to withdraw: Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal information.
5. Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it;
6. Right to data portability: the right to request that we move, copy or transfer your personal information;
7. Verify and seek rectification: the right to verify the accuracy of their Data and ask for it to be updated or corrected;
8. Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling to inform our market research and customer demographics.
9. Lodge a complaint: the right to bring a claim before their competent data protection authority.
10. Right to Nondiscrimination: We do not discriminate against users who exercise their privacy rights. You are entitled to exercise the rights described above free from discrimination prohibited by the GDPR & CCPA.

24. DURATION OF HOLDING YOUR PERSONAL DATA:

Unless a longer retention period is required or permitted by law, we may hold your Personal Data on our systems for as long as necessary to fulfill the purposes outlined in this Privacy Policy or until you request us to delete or erase it. Even if we delete your Personal Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

25. YOUR CONSENT:

By using “Siila” or any interaction with this platform and its services, you provide your consent to us to collect, process and transfer (including international transfer) of your Personal Data in accordance with this privacy policy. Wherever possible, we will attempt to obtain your explicit consent to collect and process your information. If you have given us explicit permission to do so, we may from time to time provide your name and contact information to selected partners whom we believe may provide services or Services? Already services you would find useful. Sometimes you may give implicit consent, such as when you send us a message through our support or by e-mail to which you would reasonably expect us to reply. Without your consent to use of your Personal Data for a specific purpose, we do not use your information in any way that would identify you personally. We may continue to use, disclose or process your information in accordance with this Privacy Policy and on the above basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by contacting us at contact@siila.org

26. YOUR ACCEPTANCE TO THESE POLICIES:

By using this Platform, you signify your acceptance of this Privacy Policy. If you do not agree to this policy, please do not use our Platform. Your continued use of the site following the posting of changes to this policy will be deemed your acceptance of those changes.

27. DATA PROTECTION OFFICER (DPO):

If you have concerns about the way we are handling your Personal Data, please let us know immediately. We want to help. You may contact us directly at contact@Siila.org . In the unlikely event that a dispute arises between you and us regarding our handling of Personal Data, we will do our best to resolve it. You may also contact our Data Protection Officer directly. If you have a particularly sensitive request, please contact our Data Protection Officer at.

Address: Espalter 3, 6D, 28014 Madrid, Spain

Phone: +34xxxxxx

Email: dpo@Siila.org

28. CONTACT US:

If you have any question about this Privacy Policy or would like to access or modify your personal identifiable information, please contact us.

Address:Espalter 3, 28014 Madrid Spain

Email: contact@siila.org

FYI: Please note that

• This Privacy Policy was last updated on April 2021.
• We reserve the right to change this Privacy Policy at any time. Modifications to this Privacy Policy can be made without prior notification.
• Continued use of the “Siila”, Websites signifies your acceptance of any changes to this Privacy Policy.