Last Modified: July 25th, 2024
Introduction
Aylo Premium Ltd (hereinafter “we”, “us”, or “our”) operates the website metrohd.com (hereinafter the “Website”) and is the controller of the information collected or provided via the Website. Please read this Privacy Notice carefully, as your access to and use of our Website signifies that you have read, understand, and agree to all terms within this Privacy Notice. We respect your privacy and are committed to protecting your Personal Information. If you have any questions about our privacy practices, please see the section “Contact Information” below for information on how to contact us.
For the purposes of this Privacy Notice, “process”, “processed”, or “processing” means any operation or set of operations performed on Personal Data or on sets of Personal Information or data (excluding disclosure thereof) as defined hereinafter, by automated means, including one or several of the following operations: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure or destruction. Information on disclosure of Personal Data or of sets of Personal Data or Personal Information as defined hereinafter may be found in the “Disclosure of Your Personal Information” section below.
This Privacy Notice applies to information we collect:
It does not apply to information collected by:
For greater certainty, the terms “Personal Data” or “Personal Information” mean any information or data regarding a user which can lead to identify such user, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person or user. It does not include data that has been anonymized or pseudonymized.
We may, depending on whether if you are an unregistered or a registered user on the Website, process, collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:
We use different methods to collect data from and about you including through:
Third-Party Single Sign-on: We may obtain information if you choose to create or sign-in your account through a third-party platform if available, we will have access to certain information from that platform such as your name, email address or such other information you may have submitted and allowed this third party to share.
When you use the Website, we provide functionalities where you can add or remove a model or content from and to your favourite list. To request removal of your Personal Information from the Website, please visit the section ‘Manage Your Personal Data’ below or send an e-mail at privacy@aylopremiumltd.com to help you initiate the process. In some cases, we may not be able to remove your Personal Information, in which case we will inform you accordingly.
We process Personal Information for the following purposes:
We strive to provide you with choices regarding the Personal Information you provide to us.
In some states or countries where the law requires, we may employ third-party service providers to verify your identity, age, and to verify the authenticity the identification documents you provide us using facial recognition technology. Facial recognition technology creates a mathematical representation of your facial features which are detected from the live scan of your face, your selfie, and the government-issued ID you submit or have previously submitted to us. Information derived from this mathematical representation, which may be considered biometric information under the laws of certain states and countries, is processed by our service providers on our behalf. Your biometric information will be collected and processed to:
We will store your biometric information according to the section “Retention of Personal Information” below.
You will be asked to provide your consent to biometric information processing which you may withdraw at any time by using the links below. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.
Please note that this section entitled “Biometric Information” only applies to identifiers processed by our third-party age verification service providers solely for the purpose of granting you access to the Website in some states or countries only.
We disclose your Personal Information when necessary to perform the services or for other purposes set out in this Privacy Notice. When we disclose your Personal Information, we usually rely on the performance of our contract with you, our legal obligation to do so, our legitimate interest (e.g., operating the Website), so long as it doesn’t outweigh your interests or your consent, except when expressly stated otherwise below in the paragraph “To comply with the law or protect our rights or the rights of third parties”. Disclosure of your Personal Information may also involve transfers of your Personal Information outside the EEA. To the extent that we need to transfer Personal Information outside the EEA, we will do so according to the section “Transfers of Your Personal Information to Other Countries” or when necessary for the performance of the contract between us.
The parties to whom we may disclose your Personal Information include:
We may disclose your information to third parties for the above purposes where necessary to comply with our legal obligations, to perform a task in the public interest (where the public interest is laid down by applicable law), or under our legitimate interests and the interests of the public, including as part of investigations or regulatory enquiries to detect, investigate and prosecute illegal activity.
As you navigate through and interact with the Website, we use automatic data collection technologies to collect website activity data. The technologies we use for this automatic data collection may include use of cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.
We currently use the following types of cookies, which are set by the Website:
Analytics, Functionality, Targeting and Advertising cookies can be switched off at any time by accessing the ‘Manage cookies’ option that is located at the footer of the Website. However, if you decline to accept these cookies, some functionality on the Website may be disabled and may interrupt your access to certain parts of the Website.
Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use the Website, including by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only to provide Google Analytics services to us and will not use this information for other purposes. In addition, the Website uses Google Signals, which are also services provided by Google that help us to run remarketing campaigns, collect more accurate data, and understand in a better way how users engage with the Website on different devices (cross-device activity). Google Signals apply to Google users who accept personalized advertising on their Google accounts. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU and the adequacy decision of the EU Commission C (2023) 4745 confirming an adequate level of data protection in the US under the EU-US Data Privacy Framework and applicable national extensions (for example the UK Extension to the EU-US Data Privacy Framework). You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.
Some content or applications, including advertisements on the Website are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you click to view, access, or use any of the third-party feature on the Website or directed to such third-party website. Unless expressly stated otherwise, the Website does not provide any Personal Information to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access the Website to provide targeted content. You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your Personal Information only where:
Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), the legal bases on which we rely may differ from those listed above.
We may share the information we collect globally, across our corporate group and with our service providers and other third parties. Transfers are necessary for a variety of reasons, including our operation and provision of the services stated in our Terms & Conditions and this Privacy Notice to fix, analyse, and improve our Website, products and services. Whenever we transfer Personal Information to countries outside the EEA and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Notice, as permitted by the applicable laws and based on appropriate mechanisms.
Where applicable, we rely on decisions of the European Commission, known as “adequacy decisions,” recognising that certain countries offer a level of protection of Personal Data that is essentially equivalent to the EEA. In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.
For more information or to obtain a copy of our standard contractual clauses, please see the section “Contact Information” below on how to contact us.
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. Unless we have a legal obligation or a preservation or court order which would legally oblige us to retain your Personal Information for a specific period, where we no longer need to process and retain your Personal Information in accordance with this Privacy Notice, we will delete your Personal Information from our systems.
Where permissible, we will also delete your Personal Information upon your request. Information on how to make a deletion request can be found under “Your Rights Related to Your Personal Information”. For more information on our data retention periods, please send us an e-mail at privacy@aylopremiumltd.com.
We take appropriate security measures (including physical, electronic, and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Information.
You are responsible for always maintaining the secrecy of your unique password and account information. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
Subject to local law, you have certain rights regarding the Personal Information we collect, use, or disclose and that is related to you, including the right:
If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of the Website, some of our services or the Website platform as case may be.
You can exercise your rights of access or deletion of your data by following the dedicated links in the section “Manage Your Personal Data” below. If you need assistance regarding the exercise of your rights, you can also send an e-mail at privacy@aylopremiumltd.com to help you with the process.
Prior to processing an access or deletion request of your data, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it or deleted in an unauthorized way.
Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be able to respond to your request. Additionally, in some cases, to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.
Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricably linked to the use of certain Personal Information (e.g., your e-mail address). If you delete your account, your Personal Data and all account related information including, but not limited to, user profile data, sharing data and any data or content specifically associated with your account will no longer be accessible. If, after deleting your account, you wish to have an account with us in the future, you will have to sign up for a new account.
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their Personal Information, as this term is also defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, such Consumers have the right to:
You can exercise your rights to know and to request the deletion of your data by following the dedicated links in the section “Manage Your Personal Data” below. For the rest of the rights described above, email us at privacy@aylopremiumltd.com with the subject line “CCPA Request.” If you need assistance regarding the exercise of your rights, you can also send an e-mail at privacy@aylopremiumltd.com to help you with the process.
In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you to verify that you have access to your account and/or verify the email account used to register with us.
You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.
We disclose certain categories of California residents’ Personal Information for our business purposes, as described in the section above titled “Disclosure of Your Personal Information”.
We do not sell, trade, or exchange your Personal Information with anyone for money.
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:
We reserve the right to refuse online service through our Legal Service Process Platform, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
This Privacy Notice does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of the Website.
Our Website prohibits minors from accessing or using its platform in any way. the Website is forbidden to persons under the age of eighteen (18) or the applicable age of majority in the jurisdiction from which the Website is accessed. We do not knowingly collect Personal Information from minors. If you become aware that a minor has provided us with Personal Information in any way, inadvertently, fraudulently or erroneously attempted to provide us such information with the intent to access the Website, please contact us at privacy@aylopremiumltd.com to remove such information immediately.
We may modify or revise our Privacy Notice from time to time. Although we may attempt to notify you when major changes are made to this Privacy Notice, you are expected to periodically review the most up-to-date version found at this location, so you are aware of any changes, as they are binding on you. If we change anything in our Privacy Notice, the date of change will be reflected in the “Last Modified” date mentioned in the heater of this Privacy Notice.
If you have any questions about this Privacy Notice or our information-handling practices, please contact us at privacy@aylopremiumltd.com.
You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.
Our Data Protection Officer can be contacted at the following email address: dpo@aylopremiumltd.com.
Registered Users may request a copy of their Personal Data or request the deletion of their Personal Data via the links below. Please note that the below website is governed by the present Privacy Notice.
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AYLO BILLING US CORP, 610 BRAZOS STREET - SUITE 500, AUSTIN, TEXAS 78701, USA
AYLO BILLING LIMITED, 195-197 OLD NICOSIA-LIMASSOL ROAD, DALI INDUSTRIAL ZONE 2540, BLOCK 1, CYPRUS