Privacy Policy

TIME 9 OÜ ("the Company”, "Acunar", “we”, “us” and “our”) respect and protect the privacy of visitors to our websites and our customers who use our services. To ensure transparency, this Privacy Policy describes our information handling practices when you access content we own or operate on the websites located at, or any other websites, pages, features, or content we own or operate (collectively, the "Website(s)") and/or when you use the Acunar mobile app, any Acunar API or third party applications relying on such an API, and related services (referred to collectively hereinafter as "Services").

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Privacy Notice, please contact us at [email protected].

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. Acunar may provide additional information about the data collection, use and sharing practices of specific Services. 

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes we will notify you by email address specified in your account.

You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you do choose not to share certain information with us.

Data we collect
We collect personal information to provide you with our Services. When we require certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes.

We collect or may collect the following types of information:
Personal Identification Information: Full name, date of birth, phone number, photographs, phone number, home address, preferred language and email.
Formal Identification Information for KYC: Proof of your ID, utility bill, proof of your passport details, driver’s license details, national identity card details, photograph identification cards, and/or visa information.
Financial Information: Bank account information, transaction history, trading data, and/or tax identification.
Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
Online Identifiers: username, location/tracking details, browser fingerprint, OS, browser name and version, login history and/or personal IP addresses.
Usage Data: Information provided to our support team, public social networking posts, security questions, user ID, click-stream data and other data collected via cookies and similar technologies. 

Usage of Data
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. We may use this information in the following ways:
To maintain legal and regulatory compliance. Some of our core Services are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, financial information, transaction information, online identifiers, and/or usage data in certain ways. 

To enforce our terms in our user agreement and other agreements
Acunar handles very sensitive information, such as your identification and financial data, so it is very important for us and our members that we are actively monitoring, investigating, preventing and mitigating any potentially prohibited or illegal activities, enforcing our agreements with third parties, and/or violations of our posted Terms and Conditions and Policies and Procedures. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected on our Services for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform our Services in accordance with our Terms and Conditions.

To provide Acunar Services
We process your personal information in order to provide the Services to you. For example, when you want to purchase Acunar Package, we require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information.

To provide Service communications
We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services.

To provide customer service
We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. We may process your information in response to another customer’s request, as relevant. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

To ensure quality control
We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions. Our basis for such processing is based on the necessity of performing our contractual obligations with you.
EEA Residents: pursuant to EEA Data Protection Law, we process this personal information based on our contract with you.

To ensure network and information security
We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. Without processing your personal information, we may not be able to ensure the security of our Services.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legal obligations.

For research and development purposes
We process your personal information to better understand the way you use and interact with Acunar Services. In addition, we use such information to customise, measure, analyse, and improve Acunar Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services. Our basis for such processing is based on legitimate interest.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.

To enhance your website experience
We process your personal information to provide a personalised experience, and implement the preferences you request. You may choose to provide us with access to certain personal information stored by third parties and without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.

To facilitate corporate acquisitions, mergers, or transactions
We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.

To engage in marketing activities
Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. We use information about your usage of our Services and your contact information to provide marketing communications. You can opt-out of our marketing communications at any time.
EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy on your consent.

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to so limit the use of your personal information, certain features or Acunar Services may not be available to you.

Information collected automatically and use of it 
We receive and store certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software and your IP address/MAC address/device identifier.

Share of Personal Data to Third parties
We take care to allow your personal data to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. Acunar will never sell or rent your personal information. We will only share your information in the following circumstances:
We share your information with third party identity verification services in order to prevent fraud. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.

We share your data exclusively for the purpose of processing your orders and/or giving you access to the infrastructure (e.g. servers, IT services, web hosting) of service providers commissioned by us. These service providers will process your data strictly in compliance with our instructions and will be supervised by us. Such service providers are strictly prohibited from using the data collected and processed through the Acunar website for their own purposes.

We may share your information with service providers under contract who help with parts of our business operations such as technology services (including email gateway and send SMS gateway providers) and marketing services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.

We share your information with financial institutions with which we partner to process payments you have authorised.

We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our Privacy and Procedures or any other applicable policies.

Safeguarding Personal Data
We understand how important your privacy is, which is why Acunar maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.

For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities.

Full credit card data is securely transferred and hosted off-site by a payment vendors in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to Acunar staff.

We cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please protect your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorised access to or use of your account.

We cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email [email protected].

Access to Personal Data
You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this at any time by logging in to your account and clicking the My Account tab – Edit Profile.

Rights to access, correction and deletion and right to object
You have a right of access to the personal information that we hold about you under European data protection legislation, and to some related information. You can access your Personal Data by logging on your account. You can also require any inaccurate personal information to be corrected or deleted.
You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances. Please email that you would like to opt-out to [email protected].
EEA users and Personal Data
If you are a resident of the EEA TIME 9 OÜ is data Controller with respect to your personal information.

Our legal bases for processing under EEA Data Protection Law are described above in the sections entitled “Usage of Data” and “Share of Personal Data to third parties”. We may process your personal information if you consent to the processing, to satisfy our legal obligations, if it is necessary to carry out our obligations arising from any contracts we entered with you, or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety of Acunar , our customers or others.

Individual Rights
EEA Residents have the following rights, which can be exercised by going to your Acunar Account or contacting us at [email protected] so that we may consider your request under applicable law.

Right to withdraw consent
You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of Acunar’s processing based on consent before your withdrawal.

Right of access to and rectification of your personal information
You have a right to request that we provide you a copy of your personal information held by us. This information will be provided within 30 days, unless such provision adversely affects the rights and freedoms of others. You may also request us to update any of your personal information held by Acunar that is inaccurate. 

Right to erasure
You have the right to request erasure of your personal information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing that you previously consented, but later withdraw such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. Right to erasure is subject to limitations by relevant data protection laws.

Right to data portability
If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.

Right to restriction of processing 
You have the right to restrict or object to us processing your personal information where one of the following applies:
(a) You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.
(b) The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
(c) We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.
(d) You have objected to processing, pending the verification whether the legitimate grounds of Acunar’s processing override your rights.
Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.
We will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information have been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.

Right to object to processing
Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

If you believe that we have infringed your rights, we encourage you to contact us first at [email protected] so that we can try to resolve the issue or dispute informally. You can also complain about our processing of your personal information to the relevant data protection authority. You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place. 

Storage of your personal information. Acunar will try to limit the storage of your personal information to the extent that storage is necessary to serve the purpose(s) for which the personal information was processed, to resolve disputes, enforce our agreements, and as required or permitted by law.
You may reach Data Protection Officer at [email protected].

If you have any questions regarding this Privacy Policy or the scope of personal data, please contact us under the following email address: [email protected].

Last updated: January 1, 2020