Privacy Policy

The last update: January 21, 2025

This Privacy Notice explains how we collect, process, and use personal data of consumers (hereinafter referred to as "Consumer," "You," or "Your") when interacting with the site https://www.aisance.io/ (hereinafter referred to as the "Site") and the Aisance mobile application (hereinafter referred to as the "Application"), collectively referred to as the "Service." We are obligated to ensure the protection of your data in accordance with applicable laws.

Before accessing or using our Service, please review this Privacy Notice (hereinafter referred to as the "Notice"), which outlines how we handle your personal data that you provide to us.

This document has been developed in compliance with high privacy standards and adheres to the requirements of the General Data Protection Regulation (GDPR) and other relevant regulations.

1. GENERAL INFORMATION

The use of the Service by the Consumer signifies consent to this Notice and the terms of processing the Consumer's personal data. Please read this Notice carefully so that you understand our approach to processing your personal data.

This Notice describes our interaction with you regarding the collection of personal data through this Service. Your access to this Service and all communications between you and us are governed by this Notice.

You can browse the Site without disclosing your personal data. However, using the Application requires the provision of personal data. By providing personal data, you directly consent to the collection, use, disclosure, and storage of your personal data as described in this Notice.

If you disagree with the terms of the Privacy Notice, please cease using the Service.

This Notice applies to the Service and does not control third-party websites that the Consumer may visit through links available in the Service.

The administration does not verify the accuracy of the personal data provided by the Consumer.

2. INFORMATION ABOUT THE DATA CONTROLLER

EuroAFF.com S.à r.l. (hereinafter "the Company," "We," or "Us"), a legal entity duly incorporated and existing under the laws of the Grand Duchy of Luxembourg, registered at 21 Rue du Puits Romain, 8070 Bertrange, Luxembourg, with Registration Number B280385.

3. PURPOSES OF PROCESSING PERSONAL DATA

Administration of the Service

We process personal data to maintain the operation of the Service, ensure its uninterrupted functionality, and manage User access and control over the features available on the Service.

Identification and Authentication of the User on the Service

Personal data is used to verify the User's identity when logging into the Service, ensuring protection against unauthorized access and secure use of accounts.

Provision of Services

User data is collected to provide core services of the Service, including storing information about settings and ensuring that services align with the personal needs of Users.

Development of Individual Recommendations for Users.

We process data to analyze User behavior, habits, and preferences to create recommendations that help achieve their goals in time management, resource management, and task optimization.

Behavior Pattern Analysis to Improve User Experience

Collected data is analyzed to identify patterns in Service usage to customize functionality according to individual User needs and preferences.

Subscription Plan Adaptation

We analyze data about feature usage, frequency, and intensity of interactions with the Service to propose the most appropriate subscription plan that best suits Users' needs and goals.

Statistical and Research Activities

We analyze data to generate statistical reports and study trends on the Service, helping us better understand User needs and make informed decisions to improve the Service.

Accounting, Reporting, Assessment, and Internal Audit

Personal data is processed to fulfill standard financial, tax, and audit obligations of the Company, ensuring transparency and legality of activities.

Provision of Advertising and Marketing Services and Conducting Market Research

We process data to conduct marketing campaigns, study market trends, and track advertising effectiveness to make our offers more relevant and beneficial to Users.

Traffic Analysis on the Service, Including Through Cookie Files, and Improvement of Service Functionality

We use data to monitor visit numbers, study user behavior, and analyze traffic to improve Service functionality and enhance usability. Using cookie files helps optimize Service operation and ensure seamless usage.

Provision of Effective Technical Support in Case of Issues Related to Service Usage

We process data to promptly provide technical support, helping Users resolve technical issues or clarify Service usage.

Protection of the Company's and Users' Interests, Immediate Response to Any Harmful, Unauthorized, Unethical, or Illegal Activity Resulting from Interaction with the Service

Personal data may be used to identify suspicious activities or Service rule violations to ensure security, protect Users from harmful or illegal actions, and respond promptly to potential risks.

Ensuring Proper Service Functionality, Such as Tracking Failures or Resolving Issues Reported by You

Data is used to monitor Service performance, diagnose and address failures, and enhance Service stability and reliability.

Compliance with Legal, Court, or Regulatory Requirement

We process data in accordance with applicable laws, court orders, or regulatory requirements when necessary to ensure compliance with legal obligations and the legality of our activities.

4. LEGAL BASIS FOR PERSONAL DATA PROCESSING:

  • Consent. We may process your personal data if you have given us consent to use your personal data for a specific purpose. You may withdraw your consent at any time.
  • Performance of a Contract. We may process your personal data when we deem it necessary to fulfill our contractual obligations to you, including providing our Services or upon your request before entering into a contract with you.
  • Legal Obligations. We may process your personal data if we believe it is necessary to comply with our legal obligations, such as cooperating with law enforcement or regulatory authorities, exercising or defending our legal rights, or disclosing your information as evidence in legal proceedings in which we are involved.
  • Vital Interests. We may process your personal data if we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any individual.

5. PERSONAL DATA COLLECTED

This section provides information about the personal data of Users that We may collect during their use of our Services, as well as personal data that We may obtain from other sources.

The table below defines the categories of personal data that We collect, use, store, transfer, or otherwise process:

Categories of personal information

Examples of personal data collected

Categories of personal data sources

Contact information

E-mail address and any other contact information you provide to Us.

Directly from you or through your use of the Service; Third parties.

Registration Data

If You register or log into Your account using a third-party service (Google, Apple), We receive certain information, such as Your registration and profile information from that service. This information includes, for example, Your email address, name, and profile picture, but may vary and is controlled by the respective service or according to Your privacy settings within that service.

Directly from You or through Your use of the Service; Third parties (Google, Apple).

Activity on the Internet, other networks, or devices, including information from cookie files.

Unique device and application identifiers, browsing history, or other usage data, the browser and operating system You use, the URL or advertisement that directed You to the Site or Application, search terms You entered into a search engine that led You to the Service, sections of the Site You visited, links You clicked, pages or content You viewed and for how long, and other similar information and statistics about Your interactions, such as content response times, download errors, duration of visits to specific pages, and other information typically transmitted when browsers interact with websites.

Directly from You or during Your use of the Site; Cookies and other tracking technologies.

Usage Data

Information about how You use our Service, products, and services. The Service may collect data about Your interactions, including marking recommendations as liked or disliked, User-added data, created categories, defined goals, or other actions performed within the Service, to enhance its functionality and personalize Your experience.

Cookies and other tracking technologies (specific to the Application).

Marketing 

and Communication Data

Your preferences regarding receiving marketing information from Us and our third parties, as well as Your communication preferences.

Directly from You or during Your use of the Service;

Cookies and other tracking technologies; Third parties.

Other Information That Identifies You or Can Be Reasonably Associated With You

Information that the User uploads or creates while using the functionality, as well as information to which the User grants access through integrations with third-party services.

Directly from You or during Your use of the Service; Third parties.

The User may choose not to provide this information, but it may hinder the use or access to certain features of the Service.

If You choose to register a User account, You are responsible for maintaining the security of Your account information. We recommend that You do not share Your username, password, or other access details with anyone. If You believe that Your account has been compromised, please contact Us immediately.

Before disclosing another person’s personal data to Us, You must obtain their consent for both the disclosure and the processing of that personal data in accordance with this Notice.

We also collect, use, and share "Aggregate Data" (where data has been combined or grouped in a way that does not identify an individual) or "Anonymized Data" (where personal data has been removed to ensure that the remaining data cannot be reasonably linked to an identifiable individual) for any purposes. Aggregate Data and Anonymized Data may be derived from personal data but are not considered personal data as they do not directly or indirectly reveal Your identity. For example, We may collect and anonymize Your usage data to improve the performance of artificial intelligence algorithms used by the Service.

Any information We receive from third parties will be handled in accordance with this Notice. We are not responsible for the accuracy of information provided to Us by third parties, nor are We responsible for the policies or practices of any third party.

6. PROCESSING OF PERSONAL DATA OF MINORS

In order to respect the privacy of minors, we do not knowingly collect, store, or process personal data provided through the Service by individuals under the age of 18.

If you are a parent or guardian of a child who has provided us with personal data, you may contact us using the contact details provided below to request its deletion.

As of the date this Notice comes into effect, we have no actual knowledge that we "share" or "sell" personal data of individuals under the age of 18.

7. COOKIE USAGE NOTICE

Our Site uses cookies. A cookie is a small text file that contains a small amount of information, sent to your web browser and stored on your device. These files contain information that allows the Site to remember important details, making the use of the Site more efficient and beneficial for Consumers. For example, we use cookies to ensure proper navigation between pages of the Site.

We may use both session cookies and persistent cookies. A session cookie disappears after closing the browser. A persistent cookie remains after you close the browser and can be used by your browser during subsequent visits to the Site.

Using cookie technology, we only collect anonymous statistical data to improve the usability of the Site for Consumers. We do not collect any data that would allow us to identify the Consumer.

Types of Cookies We Use:

  • Strictly necessary cookies are essential for the proper functioning of the Site and for providing the services requested by the Consumer. The duration of these cookies depends on their type. They are used to store long-term Consumer preferences.
  • Analytical third-party cookies are necessary to improve the functioning of our Site.
  • Advertising cookies are used to track Site Consumers. These cookies allow the Service to deliver advertising content that is more relevant to the specific Consumer's interests. For this purpose, we may use advertising tools from the following providers, along with their respective Cookies:
  • Google Ads – cookies used by Google to customize advertising in its services, such as the search engine or online advertising display.
  • Facebook Ads (Facebook pixel) – cookies used for matching advertising on Facebook services with the recipient's individual preferences.
  • Instagram Ads – cookies used for setting up and personalizing advertising on Instagram, based on the consumer's actions, interests, and interactions within the Instagram app.

You can withdraw consent to accept cookies by enabling the appropriate settings in your browser to disable cookie preferences. Information on managing cookies in specific browsers can be found on the pages dedicated to those browsers:

Please note that our Site may not function properly if all cookies are disabled.

If you have not configured your browser to reject cookies, our system will generate them when You visit our  Site.

8. RETENTION PERIOD OF PERSONAL DATA

We will retain your personal data for as long as you use the Service and for 30 days after submitting a request for account deletion, unless you cancel the deletion process during this grace period. Detailed information about the deletion process can be found in our Terms and Conditions. Data that can be anonymized will remain in an anonymized form to improve the operation of the Service.

However, we may delete your personal data upon your request at any time. You also have the right to withdraw your consent for the processing of personal data at any time.

If you have any questions regarding our data retention notice, please contact us using the information provided below.

9. CONSUMER RIGHTS REGARDING PERSONAL DATA

All Consumers of the Service have the following rights:

  • The right to know the sources of collection, the location of their personal data, the purpose of its processing, and the location of the Data Controller.
  • The right to access their personal data and request a copy of it.
  • The right to correct their personal data.
  • The right to delete their personal data, provided there are no violations of obligations and no necessity to retain the data.
  • The right to restrict or block the processing of their personal data if the Consumer objects to such processing, doubts the accuracy of their data, considers the processing to be unlawful, or if necessary for the establishment, exercise, or defense of the Consumer’s rights in court.
  • The right to receive personal data provided to us (in a structured, widely used, and machine-readable format) and reuse it elsewhere or request us to transfer it to a third party of the Consumer’s choice.
  • The right to withdraw consent for processing.
  • The right to request the cessation of processing of their personal data, and we will do so unless there are legitimate and imperative reasons for such processing.
  • The right to file a complaint with us regarding any processing of their personal data or to contact the supervisory authorities in the country where the Consumer resides or works.
  • The right to opt out of the processing of their personal data for analytical purposes.
  • The right to opt out of the processing of their personal data for targeted advertising.
  • Other rights provided by law.

Please note that some of these rights may be restricted if we have a legitimate interest or legal obligation to continue processing the data, or if the data may be exempt from disclosure due to legal professional privileges or obligations to maintain confidentiality.

10. DISCLOSURE OF CONSUMERS' PERSONAL DATA TO THIRD PARTIES

We do not transfer personal data to third parties, except when such transfer is required by applicable law, at the request of the data subject, or in other cases outlined in this Notice.

Access to personal data of Consumers may be granted to individuals who require such access for the purposes of supporting, ensuring quality, operating, or improving the Service and our services. These individuals include:

  • Our employees. Our employees process your personal data to provide services, customer support, technical assistance, marketing, and other operational purposes of the company. All employees are required to comply with appropriate data protection measures. Your data is used exclusively in the course of fulfilling their tasks and duties, ensuring the confidentiality and protection of your personal data.
  • Affiliates. We may share information about you that we collect with any of our current or future subsidiaries or affiliated companies, which may use it in accordance with this Notice.
  • Service providers and partners. We may provide information about you that we collect to our partners, contractors, and service providers who perform functions on our behalf, such as supporting the operation of the Service, data hosting, and other services.
  • Government authorities. We may share information with government authorities in accordance with legal requirements, including (without limitation) in response to lawful requests from government authorities to comply with national security or law enforcement requirements, as well as for tax reporting purposes. We cooperate with governmental and law enforcement authorities to ensure compliance with and enforcement of the law.

By visiting the Service and providing your personal data, you consent to their processing by the third parties identified above, except where separate consent is required.

All individuals who have access to Consumers' personal data are obligated to comply with all applicable laws regarding the protection of personal data and its confidentiality.

With the Consumer's consent, the Service may interact with other third-party websites or services operated by third parties. We do not control the operation of such third-party websites or services, and this Privacy Notice does not apply to them.

We encourage Consumers to carefully review the privacy notice and personal data processing practices of any third-party website or service before providing any personal data or other information that could be used for identification.

11. DATA PROTECTION

We use widely accepted technological and operational security standards, a combination of administrative, technical, personnel, and physical measures, to protect the information and personal data we collect from loss, misuse, disclosure, alteration, or destruction.

However, no one can guarantee complete security of your information or absolute protection against any threats arising beyond our control. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any account you may have with us has been compromised), please immediately inform us of the issue by contacting customer support in accordance with the instructions provided below.

We recommend that Consumers avoid using unsecured channels to transmit confidential information to us.

12. CHANGES TO THE PRIVACY NOTICE

We may update this Notice by publishing a new version on our Site. If we update it in such a way that significantly alters how we use Consumers' personal data, we will notify them of these changes, if it is reasonable and possible. Otherwise, we recommend that Consumers periodically review this Notice to stay informed of any other changes.

The "Last Updated" date above will indicate when the Terms and Conditions were last reviewed. By continuing to use the Service after this date, you agree to the changes.

13. REGIONAL PRIVACY PROVISIONS: AUSTRALIA

This section applies to Users accessing the Service from Australia and outlines additional rights and obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), as amended by the Privacy and Other Legislation Amendment Act 2024.

Compliance with Australian Privacy Law

Company, acknowledges and complies with the requirements of the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the amendments introduced by the Privacy and Other Legislation Amendment Act 2024. This Notice explains how We collect, use, disclose, and store the personal data of Consumers in Australia, as well as their rights under the applicable laws.

Collection and Use of Personal Data

In addition to the categories of personal data described in Section 5 of this Notice, We collect, use, and disclose personal data of Australian Consumers for the following purposes:

  • Service Administration: Ensuring seamless access to the Service and maintaining its core functionalities.
  • User Authentication and Security: Verifying identity, preventing unauthorized access, and ensuring secure transactions.
  • Compliance with Australian Legal Requirements: Responding to requests from law enforcement, regulatory authorities, and fulfilling tax and legal obligations.
  • Marketing and Communication Preferences: Processing Consumer preferences regarding direct marketing communications, in accordance with the Spam Act 2003 (Cth).

Cross-Border Data Transfers

The Company is incorporated under the laws of the Grand Duchy of Luxembourg and processes personal data using infrastructure located outside Australia. By using the Service, Australian Consumers acknowledge and consent to the transfer of their personal data outside Australia, including to the European Economic Area (EEA) and other jurisdictions where the Company or its service providers operate. In accordance with the Privacy and Other Legislation Amendment Act 2024, the Company must take additional security measures to protect personal data transferred outside Australia. If a data breach occurs, affected Australian Consumers will be notified without undue delay, and the breach will be reported to the Office of the Australian Information Commissioner (OAIC) as required by law.

Consumer Rights Under Australian Law

In addition to the rights outlined in Section 9 of this Notice, Australian Consumers have the following rights under the Privacy Act 1988 (Cth), as amended:

  • Consumers may request access to personal data held by Us, subject to legal exceptions.
  • Consumers may request corrections to inaccurate, incomplete, or outdated personal data.
  • Consumers may object to certain data processing activities, including direct marketing.
  • Where We rely on consent as the legal basis for processing, Consumers may withdraw such consent at any time.
  • If a Consumer believes their privacy has been seriously breached, they may have a statutory right to initiate legal proceedings for serious invasion of privacy, as per amendments introduced in the Privacy and Other Legislation Amendment Act 2024.

To exercise these rights, Consumers may contact Us using the details provided in Section 16.

Complaints and Dispute Resolution

If an Australian Consumer has a concern regarding how We handle their personal data, they may lodge a complaint by contacting Us at the details provided below. We will acknowledge receipt of the complaint and aim to respond within 45 days. If the Consumer is not satisfied with Our response, they may escalate the complaint to the Office of the Australian Information Commissioner (OAIC).

14. REGIONAL PRIVACY PROVISIONS: CANADA

This section applies to Users accessing the Service from Canada and outlines additional rights and obligations under the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the Consumer Privacy Protection Act (CPPA), introduced as part of Bill C-27.

Compliance with Canadian Privacy Law

The Company acknowledges and complies with the requirements of PIPEDA and, where applicable, CPPA. This Notice explains how We collect, use, disclose, and store the personal data of Consumers in Canada, as well as their rights under the applicable laws.

Collection and Use of Personal Data

In addition to the categories of personal data described in Section 5 of this Notice, We collect, use, and disclose personal data of Canadian Consumers for the following purposes:

  • Service Administration: Ensuring seamless access to the Service and maintaining its core functionalities.
  • User Authentication and Security: Verifying identity, preventing unauthorized access, and ensuring secure transactions.
  • Compliance with Canadian Legal Requirements: Responding to requests from law enforcement, regulatory authorities, and fulfilling tax and legal obligations.
  • Marketing and Communication Preferences: Processing Consumer preferences regarding direct marketing communications, in accordance with the Canadian Anti-Spam Legislation (CASL).

Cross-Border Data Transfers

The Company is incorporated under the laws of the Grand Duchy of Luxembourg and processes personal data using infrastructure located outside Canada. By using the Service, Canadian Consumers acknowledge and consent to the transfer of their personal data outside Canada, including to the European Economic Area (EEA) and other jurisdictions where the Company or its service providers operate. In accordance with PIPEDA and CPPA, the Company must take additional security measures to protect personal data transferred outside Canada. If a data breach occurs, affected Canadian Consumers will be notified without undue delay, and the breach will be reported to the Office of the Privacy Commissioner of Canada (OPC) as required by law.

Consumer Rights Under Canadian Law

In addition to the rights outlined in Section 9 of this Notice, Canadian Consumers have the following rights under PIPEDA and, where applicable, CPPA:

  • Consumers may request access to personal data held by Us, subject to legal exceptions.
  • Consumers may request corrections to inaccurate, incomplete, or outdated personal data.
  • Consumers may object to certain data processing activities, including direct marketing.
  • Where We rely on consent as the legal basis for processing, Consumers may withdraw such consent at any time.
  • Under CPPA, Consumers may request their personal data in a structured, commonly used, and machine-readable format.
  • If a Consumer believes their privacy has been seriously breached, they may file a complaint with the Office of the Privacy Commissioner of Canada (OPC).

To exercise these rights, Consumers may contact Us using the details provided in Section 16.

Complaints and Dispute Resolution

If a Canadian Consumer has a concern regarding how We handle their personal data, they may lodge a complaint by contacting Us at the details provided below. We will acknowledge receipt of the complaint and aim to respond within 45 days. If the Consumer is not satisfied with Our response, they may escalate the complaint to the Office of the Privacy Commissioner of Canada (OPC).

15. REGIONAL PRIVACY PROVISIONS: UNITED STATES OF AMERICA

This section applies to Users accessing the Service from the United States and outlines additional rights and obligations under federal and state data privacy laws.

Compliance with U.S. Privacy Law

Company acknowledges and complies with applicable U.S. federal privacy laws. Additionally, We comply with state-specific laws, including:

  • California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA): California residents have specific rights regarding their personal data, including the right to access, delete, and opt out of the sale of their data.
  • Virginia Consumer Data Protection Act (VCDPA): Virginia residents have rights to access, correct, delete, and opt out of processing for targeted advertising.
  • Colorado Privacy Act (CPA): Colorado residents have rights to access, correct, delete, and opt out of data processing for targeted advertising.
  • Connecticut Data Privacy Act (CTDPA): Connecticut residents have rights to access, correct, delete, and opt out of data processing for targeted advertising.
  • Utah Consumer Privacy Act (UCPA): Utah residents have rights to access, delete, and opt out of the sale of their personal data.

Collection and Use of Personal Data

In addition to the categories of personal data described in Section 5 of this Notice, We collect, use, and disclose personal data of U.S. Consumers for the following purposes:

  • Service Administration: Ensuring seamless access to the Service and maintaining its core functionalities.
  • User Authentication and Security: Verifying identity, preventing unauthorized access, and ensuring secure transactions.
  • Compliance with U.S. Legal Requirements: Responding to requests from law enforcement, regulatory authorities, and fulfilling tax and legal obligations.
  • Marketing and Communication Preferences: Processing Consumer preferences regarding direct marketing communications in accordance with applicable laws.

Cross-Border Data Transfers

The Company is incorporated under the laws of the Grand Duchy of Luxembourg and processes personal data using infrastructure located outside the United States. By using the Service, U.S. Consumers acknowledge and consent to the transfer of their personal data outside the U.S., including to the European Economic Area (EEA) and other jurisdictions where the Company or its service providers operate. In compliance with U.S. privacy laws, the Company must take additional security measures to protect personal data transferred outside the United States. If a data breach occurs, affected U.S. Consumers will be notified without undue delay, and the breach will be reported to the appropriate regulatory bodies in accordance with applicable laws.

Consumer Rights Under U.S. Law

In addition to the rights outlined in Section 9 of this Notice, U.S. Consumers have the following rights under federal and state privacy laws:

  • Consumers may request access to personal data held by Us, subject to legal exceptions.
  • Consumers may request corrections to inaccurate, incomplete, or outdated personal data.
  • Consumers may request deletion of their personal data, subject to certain legal exceptions.
  • Consumers may opt out of the sale of their personal data to third parties if applicable.
  • Where We rely on consent as the legal basis for processing, Consumers may withdraw such consent at any time.
  • Consumers will not be discriminated against for exercising their data privacy rights.

To exercise these rights, Consumers may contact Us using the details provided in Section 16.

Complaints and Dispute Resolution

If a U.S. Consumer has a concern regarding how We handle their personal data, they may lodge a complaint by contacting Us at the details provided below. We will acknowledge receipt of the complaint and aim to respond within 45 days. If the Consumer is not satisfied with Our response, they may escalate the complaint to the relevant regulatory bodies.

16. CONTACT US

If you have any comments or questions regarding our Service, or if you have any concerns, feedback, or complaints about our Notice, you can contact our specialist by:

We strive to respond to any emails as promptly as possible, where feasible.

When you send us an email with a request, we may ask you to provide information necessary to verify your identity.