Last Modified on January 29, 2021

We ask that you read this privacy notice carefully, as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information, and on how to contact us and supervisory authorities in the event you have a complaint.

1. WHO WE ARE

MMG OÜ d/b/a Emberdome Media (“Emberdome,” “We,” or “Us”) collects, uses, and is responsible for certain personal information about you, as part of the Kurgan Compass website, located at kurgancompass.com (collectively, the “Service”).

For those in the European Union, we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controllers of that personal information for the purposes of those laws.

2. PERSONAL INFORMATION WE COLLECT AND USE

Information collected by us: In the course of providing you with the Service, we collect the following personal information when you provide it to us:

• Your name and email address, collected through a newsletter signup form, feedback form, when you sign up for a contest or promotion, or when you email us for technical or other support (your “Account Information”).
• Your IP address, your location (city), your browser type, advertising ID, and your access times and usage statistics (your “Analytic Information”)

How we use your Personal Information: We use your personal information as follows:

• Newsletters/Announcements: We may use your Account Information to send you commercial or marketing messages including, without limitation, newsletters and email communications about our products or services.
• Technical Support: We may use your Account Information to contact you regarding any customer service issues.

Who we share your Personal Information with: We share your Personal Information with certain third parties as part of our operation of the Service. This data sharing enables you to make purchases on the Service and for us to provide you with the Service in an optimal way.

Some of those third-party recipients may be based outside the European Economic Area — for further information, including how we safeguard your personal data when this occurs, see their individual privacy policies linked to below and the section entitled “Transfer of your Information out of the EEA,” below.

We share your Personal Information with the following third parties:

• Newsletters and Marketing Messages: We partner with Mailchimp to collect email addresses, maintain our mailing list, and send out newsletters and other marketing messages, and may share your Account Information with them when you sign up for our mailing list. You can find their privacy policy here: https://mailchimp.com/legal/privacy
• Analytics: We use Google Analytics to analyze user activities and improve the Service. We share your Analytic Information with them. You can find more information on opting out of Google Analytics tracking here.
• Advertisements: If you click on an advertisement on the Service, you may be linked to Amazon through their API. We may share your Analytic Information with Amazon. You can view their terms and conditions here.
• Other Sharing: We will share your Personal Information if we have a good faith belief that (i) access, use, preservation, or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of Emberdome, its employees, clients, or users of the Service. We will not share your personal information with any other third party.

How long your Personal Information will be kept: We will keep your Personal Information for the length of time required to provide you with the Service, unless a longer retention period is required or permitted by law. Afterward, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide.

Please note that some data may be retained if necessary to resolve disputes, enforce our user agreements, and comply with technical and legal requirements and constraints related to the security, integrity, and operation of the Service.

Reasons we can collect and use your Personal Information: The laws in some jurisdictions require that we notify you of the lawful basis for collecting your Personal Information.

To the extent that such laws apply, we rely on the following as the lawful basis on which we collect and use your personal information:

• Consent: At times we may collect, process, store, transfer or disclose your personal data on the basis of your implied or explicit consent, such as when you sign up for the newsletter.
• To fulfill our contractual obligations: In order to fulfill our contractual obligations to you, we must collect, process, and store your personal data and information. We must handle your personal data in this manner to process purchases on the Service. Additionally, we may at times have to transfer or receive your personal data to or from third parties, in order to fulfill other contractual obligations to you.
• Furtherance of legitimate interests: We may collect, process, store, transfer or disclose your personal data in furtherance of those legitimate interests of ours which are not overridden by your interests or fundamental rights and freedoms as set forth in the applicable laws. These legitimate interests include, but are not limited to, (i) providing you with the Service, (ii) protecting our users, staff, and property from fraud and other harm, (iii) collecting information on how you use the Service in order to optimize the design and functionality of the Service, and (iv) communicating with you via e-mail for communications you have explicitly opted into (e.g., notifications about new products and services) or for important communications with you regarding the Service.
• Legal compliance: We may collect, process, store, transfer or disclose your personal data to comply with our legal obligations.

Cookies: When you use the Service, cookies may be used by us and by third parties to allow the Service to function, to allow you to stay logged in between different sessions, and to help to make your user experience better.

Cookies are not spyware or adware, and cannot deliver viruses or run programs on your computer. You may configure your web browsers to accept, reject, or delete cookies, or to notify you when a cookie is being set. We may also use “pixel tags,” otherwise known as web beacons or clear gifs. These are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users.

For more information about our use of cookies, please see our cookie policy.

Depersonalized Information: We may make your Personal Information non-personally identifiable by either combining or aggregating it with information about other users, or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information and is used to analyze usage and improve the Service.

Children’s Privacy: We do not knowingly collect any personal information from children under the age of 13, allow them to create accounts, sign up for newsletters, make purchases, or browse the Service. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16.

Emberdome takes children’s privacy seriously and encourages parents to play an active role in their children’s online experience at all times. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you have any concerns about your child’s personal information, please contact us at [email protected].

Links to Other Sites: The Service may contain links to other sites or services. If you click on a third-party link, you will be directed to that site or service. These external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites or services. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Do Not Track: Because there’s not yet a consensus on how companies should respond to web browser-based or other do-not-track mechanisms yet, we don’t respond to web browser-based do-not-track signals at this time.

3. TRANSFER OF YOUR INFORMATION

Emberdome Media is headquartered in Estonia. No matter where you are located, you consent to the processing, transfer, and storage of your information in and to the U.S., in accordance with the privacy policies of third parties with whom we share your Personal Information. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

If you would like further information, please contact us (see “How to contact us” below).

4. YOUR RIGHTS

Under the laws of some jurisdictions, including the General Data Protection Regulation in the EEA, you have a number of important rights with regard to your Personal Information.

• By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
• If we are processing your personal data for reasons of consent or to fulfill a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
• If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
• You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.
• Finally, in some circumstances, you can ask us not to reach decisions affecting you using automated processing or profiling.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

5. KEEPING YOUR PERSONAL INFORMATION SECURE

We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way.

For example, we limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner. Our web servers are located in a secured and environmentally controlled location, as well.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

6. HOW TO COMPLAIN

We hope that we can resolve any questions or concerns you raise about our use of your Personal Information. Please contact us via the methods listed below in the section entitled “How to contact us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.

If you are an EU citizen, the General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

7. POLICY CHANGES

We may change this privacy notice from time to time. When we do, we will update the date at the head of this page.

8. HOW TO CONTACT US

Write to [email protected] if you have any questions about this privacy notice or the information we hold about you.