Privacy Policy

 The Privacy Policy governs the processing of Personal Data by the Company.

The provisions of this Privacy Policy describe how the Company processes, stores, and receives Personal Data.

Reference to the words “we”, “our” or “us” (or equivalent terms) means the Company.

Reference to the words “you” or “your” (or similar words) means the User receiving the Services.

The words he/she and their derivatives in the text of the document can be applied to either a male person or a female person, depending on the context of the document.

We are grateful to you for using the Company’s services.

• DEFINITIONS 

1. Personal Data means any information that directly or indirectly allows you to identify the User. For example, first name, last name, phone number, and IP address.

1. Statistical Data means any information that is publicly available and directly or indirectly relates to the User.

1. Data means a generalized concept for Personal and Statistical Data.

1. Services means the set of actions, operations, or processes performed by the Company for the benefit of the User, in accordance with the purpose and scope described on the Site and/or in the relevant contractual documentation.

1. Company’s Website (hereinafter referred to as the “Site”) means a web page or group of web pages available on the Internet at: https://stilando.world/, operated and controlled by the Company.

1. Company “STILANDO” (hereinafter referred to as the “Company” )means TURBO PARTNERS LLP, a legal entity registered under the laws of the United Kingdom, with company number OC444668 and registered office at 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX

1. User is an individual or legal entity to whom the Company provides Services.

1. Third Party means a natural or legal person, government agency, institution or body besides the Company or the User, the Controller or the Processor.

1. Controller – means any natural or legal person, government agency, institution, or other body that independently determines the purposes and means of personal data processing.

1. Processor – is a natural or legal person, government agency, institution, or other body that processes Personal Data on behalf of and behalf of the Controller.

1. Cookies – are a piece of information in the form of text or binary data that is transmitted to the browser from the site.

1. User’s Consent (hereinafter “Consent”) – means a voluntary, specific, informed, and unequivocal expression of will, in which the User using a statement or explicit affirmative action agrees to the processing of his Personal Data and to comply with the terms of this Privacy Policy.

1. Contract means a legally binding agreement concluded between the Company and the User (including legal entities), which establishes the terms, scope, and procedure for the provision of the Services, as well as the rights and obligations of the Parties.

1. GENERAL PROVISIONS

1. The Company provides Services to Users and corporate Clients located in different regions of the world. Accordingly, the Company carries out its activities in compliance with the applicable laws and data protection regulations of the jurisdictions in which it operates, including but not limited to the United Kingdom and the European Economic Area.

1. The Company acts as a Controller when it independently determines the purposes and means of processing Personal Data collected through the Site or for its own operational purposes. In certain cases, where the Company processes Personal Data on behalf of another entity, it acts as a Processor strictly in accordance with the documented instructions of such Controller.

1. The Company ensures that the processing of Personal Data is carried out lawfully, fairly, and transparently, in accordance with the principles established by applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR), where applicable.

1. PERSONAL DATA

1. The Company may receive the following Personal Data about the Users: 
   1. full name;
   2. email address;
   3. telephone;
   4. local address;
   5. transaction, credit, subscription, and payment history (if applicable and solely for the purpose of receiving payment for the Services).

1. The Company may receive and process the following Statistical Data about the User:
   1. generalised analytical information about the use of the Site, including the number of visits, viewed service categories, time spent on pages, and navigation activity;
   2. anonymised data regarding the effectiveness of marketing and advertising campaigns, including inquiries related to travel arrangements, lifestyle management, event organisation, or consultation requests;
   3. technical metrics collected through analytics tools (such as Google Analytics or Meta Pixel), including session duration, visited sections, type of device and browser, and operating system;
   4. aggregated data concerning User interaction with the Company’s communications, including the number of submitted forms, responses to messages, and participation in promotional activities, processed solely in statistical form;
   5. publicly available information from open official registers and websites, including the Company’s name, jurisdiction, registration details, bank or payment information, and verified data from corporate or governmental databases, where such data are used for legitimate business verification purposes;
   6. other non-personal statistical information that does not identify the User individually but is used for analytics, internal reporting, optimisation of Services, and improvement of operational efficiency.

1. The Company may receive the following Personal Data about the User’s personnel – legal entity:
   1. full name;
   2. email;
   3. telephone.

1. The Company purposefully does not process the User’s banking data, and such data is processed exclusively by the payment system, which is used to receive payments. The Company may process payment data solely to resolve disputes and/or to comply with the requirements of the legislature and/or the decision of the judicial/executive authority.

1. The Company may also receive and process Data obtained from the Contract concluded between the Company and the User (including legal entities). Such data may include identification and registration details, contact information, payment and invoicing data, and other information necessary for the execution and administration of the Contract.

1. The Company does not collect or process sensitive Personal Data of Users, such as race or ethnic origin, political views, religious or philosophical beliefs, union membership, genetic or biometric data, health information, sexual life or sexual orientation.

1. When visiting the Site or receiving Services, Company may collect the following Personal Data automatically:
   1. IP address;
   2. time zone and language settings;
   3. browser type and version;
   4. operating system, device type, and screen extension;
   5. the country in which you are located;
   6. data about your visit to the Site, including full URL information, routes to and from the Site (including date and time), page response time, data loading errors, length of stay on certain pages, page activity (such information such as scrolling and mouse movements, clicks), methods used to exit the page and telephone numbers to contact the User’  support.

1. The Company has the right to collect and receive Personal Data as follows:
   1. When providing the Services — during the creation, execution, and performance of the Contract, including registration of requests, communication, fulfilment of obligations, and payment processing.
   2. When using the Site — through forms, questionnaires, and interactive elements that require the User to provide certain information voluntarily.
   3. Automatically — through Cookies, log files, analytics tools, and other tracking technologies that collect technical and usage data when the User visits the Site.
   4. From Third Parties — including partners, service providers, or public sources, where permitted by applicable law and necessary for the proper provision of the Services.

1. The Company has the right to use Personal Data for the following purposes to:
   1. provide, perform, and improve the Services in accordance with the Contract and the User’s requests.
   2. ensure the operation, security, and technical functionality of the Site.
   3. administer internal operations, including troubleshooting, data analysis, testing, research, and statistical reporting.
   4. communicate with the User, including responding to inquiries, sending confirmations, notices, or updates related to the Services.
   5. comply with legal, regulatory, and contractual obligations applicable to the Company.
   6. prevent, detect, and investigate fraud, abuse, or other unlawful activity.
   7. protect the Company’s legitimate interests, including the establishment, exercise, or defence of legal claims.
   8. conduct analytics, marketing research, and improve User experience, provided that such processing complies with applicable data protection laws.

1. TRANSFER OF PERSONAL DATA

1. The Company may transfer Personal Data to entities with which the Company cooperates in the implementation and provision of Services:
   1. Payment service. To receive payment for the Services, Personal Data may be transferred automatically.
   2. Contractors and employees. The Company may transfer your Personal Data to other entities with which it will start cooperation, including legal and tax consultants, as well as entities that provide accounting, logistics, marketing, and IT services.
   3. Counterparties. The Company has the right to disclose or transfer Personal Data in the following transactions: acquisition or merger, financing, corporate reorganization, joint venture, including the sale of assets, or bankruptcy.
   4. Courts, law enforcement, and state bodies. The Company has the right to transfer Personal Data in case of fulfillment of any legal obligations, including in accordance with a court order.

• USER CONSENT

1. The User’s Consent to the processing of Data shall be deemed to have been duly provided in the following cases:
   1. when the User marks (ticks) the checkbox on the Site confirming that they have read, understood, and agreed to this Privacy Policy, which serves as a clear affirmative action expressing the User’s Consent to the processing of Data;
   2. when the User signs the Contract with the Company, whereby the provision of Data and its processing are necessary for the preparation, conclusion, and performance of the Contract in accordance with applicable law.

1. The Company may also collect additional explicit Consent in writing or digital if required by applicable law (for example, for marketing or promotional communications).

1. By performing any of the above actions, the User confirms that they have read and understood this Privacy Policy and voluntarily provide their Consent to the processing of their Data by the Company for the following purposes to:
   1. receive and use the Services provided by the Company;
   2. allow the Company to process, store, and use the Data necessary for the execution of the Contract;
   3. enable communication between the Company and the User regarding the provision of the Services;
   4. ensure the fulfilment of legal and regulatory obligations applicable to the Company;
   5. improve the quality, functionality, and personalisation of the Services and the Site;
   6. protect the Company’s rights, interests, and reputation in accordance with applicable law.

1. The Company reserves the right to obtain the User’s Consent via the Pop-up form. The Pop-up form may contain a Consent form in the сheckbox view.

• PERSONAL DATA STORAGE AND PROTECTION 

1. The Company uses all necessary security and protection measures for Personal Data to ensure their confidentiality and prevent loss or improper disclosure.

1.  The Company protects and stores Personal Data from:
   1. losses;
   2. unlawful use, transfer, disclosure, modification, deletion, and/or destruction.

1. We may use the following methods to protect Personal Data in accordance with the article “Security of processing” 32 GDPR:
   1. pseudonymization and encryption of Personal Data;
   2. ability to ensure constant confidentiality, integrity, availability and fault tolerance of Personal Data processing systems;
   3. regular testing, evaluation and measurement of the effectiveness of technical and organizational measures to ensure the security of processing Personal Data.

1.  The Company does not store the User’s Personal Data in the event of a request to delete Personal Data on his behalf in accordance with the right to delete, as provided in Article 17 of the “Right to Erase” GDPR.

1. Company has the right to retain Personal Data of User for 3 (three) years after the termination of the relationship in the following cases:
   1. for statistical accounting;
   2. if the current legislation requires their storage;
   3. if they are necessary for doing business.

• GROUNDS FOR PERSONAL DATA PROCESSING

1. 1. The Company processes Personal Data based on the following legal grounds:
      1. User’s Consent;
      2. receiving Services from the Company;
      3. to comply with the provisions of applicable law, for the proper level of our business, the conclusion, and execution of corporate transactions (sale of shares/stocks, mergers, acquisitions), to fulfill your obligations to you and/or the Third Party.

1. In cases where the basis for the processing of Personal Data is Your Consent, You have the right to withdraw it at any time. To withdraw your Consent, You may email: support@stilando.world. If Your Consent is withdrawn, the Company has the right to terminate the provision of the Services and terminate all relations with You. If Consent is withdrawn, your Personal Data will be permanently deleted.

1. The Company undertakes to stop processing Personal Data within 15 (fifteen) business days from the date of receipt of the withdrawal of Consent.

• USER RIGHTS

1. When processing personal and statistical data, the Service grants the User the following rights:

1. Right of access (Article 15 GDPR). The User may contact us directly to access the Data we hold about them, as well as any additional information provided for in Article 15 of the General Data Protection Regulation (GDPR).

1. Right to erasure (Article 17 GDPR). The User has the right to request the deletion of their Data. In such a case, the Data will be permanently deleted in accordance with Article 17 GDPR, unless legal exceptions apply.

1. Right to data portability (Article 20 GDPR). The User has the right to receive their Data in a structured, commonly used, and machine-readable format and to transmit it to another controller or request its direct transmission to a third party, where technically feasible, pursuant to Article 20 GDPR.

1. Right to rectification (Article 16 GDPR). The User has the right at any time to request the update, correction, or completion of inaccurate or incomplete Data in accordance with Article 16 GDPR.

1. Right to object (Article 21 GDPR). The User has the right to object at any time to the processing of their Data on grounds relating to their particular situation, pursuant to Article 21 GDPR.

1. Automated individual decision-making, including profiling (Article 22 GDPR). The User has the right not to be subject to a decision based solely on automated processing, including profiling, if such a decision produces legal effects concerning them or similarly significantly affects them, as set forth in Article 22 GDPR.

• SUBMISSION OF REQUEST

1. A User in any jurisdiction has the right to submit a request to the Company if he believes that his rights have been violated by writing a request in writing to the support of the Company at the address: support@stilando.world 

1. The User’s request must contain accurate information about the requirements for the Company. If the exact requirements are not specified in the request, the Company has the right to refuse to fulfill the request.

1. We will not be able to respond to your request or provide you with Personal Data unless we can verify your identity and confirm that the Personal Data belongs to you. In case of receiving a request with inaccurate information and/or in case of inability to confirm the User’s identity, the Company has the right not to process the received request and contact the User for clarification. In case of receiving a response to a request for clarifications, the User must provide a new corrected request or submit a new request.

1. The Company must respond to the request or fulfill the conditions set forth in the request within 21 (twenty one) business days from the moment of its receipt.

• RESPONSIBILITY

1. The Company informs the User that Personal Data may be used to provide the Services, and in case of disagreement with this, the User is not entitled to receive the Services.

1. The Company is not responsible for:
   1. any loss, damage, or harm resulting from the User’s failure to provide accurate, complete, or up-to-date Personal Data;
   2. any unauthorised access to or use of Personal Data caused by the User’s disclosure of credentials, negligence, or non-compliance with security recommendations;
   3. any damage caused by Third Parties or as a result of the use of Third-Party websites, links, or services, including cases where such sites are referenced on the Company’s Site;
   4. failures or interruptions in the operation of telecommunication networks, Internet providers, or other circumstances beyond the reasonable control of the Company;
   5. the User’s provision of Personal Data to any Third Party independently of the Company.

1. The Company may link to other websites or services. The privacy practices of these websites and services are not governed by this Privacy Policy and the Company, and the Company cannot be held responsible for the processing of User’s Data by Third-Party websites and services.

1. The Company is not responsible for:
   1. for any damage to the User resulting from the processing of his Data;
   2. for the User’s consent to the processing of the User’s Data by the Company.

1. Unfortunately, the transmission of information over the Internet cannot be completely secure. Although we make every effort to protect personal data, we cannot guarantee the secure process of transferring personal data to the site. In this regard, you are solely responsible for possible failures when transferring your Data to the Company.

• COOKIES

1. Site pages may contain electronic images known as web beacons (sometimes also called transparent GIFs or pixel tags). Web beacons are usually small images placed on the web page or email you are viewing. The request that a device connected to the Internet makes to download such an image from the server/computer is recorded, and it provides us with information such as the IP address, the time the image was viewed, and the type of browser used to do so.

1. Cookies do not transmit viruses and/or malware to your device, as the data in the Cookie does not change during transit and does not affect your computer’s performance in any way. They act more like logs (i.e., record User activity and remember state information) and are updated each time you visit the Site.

1. The Company uses Cookies for the following purposes:
   1. authentication and identification;
   2. storage of personal preferences and settings;
   3. access session tracking;
   4. storage of statistical data;
   5. website analysis.

1. The Company can use the following web analytics services:
   1. Facebook;
   2. Google Analytic.

• CONFIRM POLICY

1. The Services of the Company are intended for people who have reached the age of majority, in accordance with the laws of the country of residence of such a person. The Company does not process the Data of minors.

1. The Company has the right to delete the Personal Data of a person who has not reached the age of majority, without warning and any consequences for the Company, as well as to terminate the provision of the Services to such a person.

1. If you have information about the receipt of the Services by a person under the age of majority, please contact the Company support service by sending an email to: support@stilando.world

• PRIVACY POLICY CHANGE

1. We have the right to periodically make changes to the Privacy Policy, the security of Personal Data, and compliance with the requirements of the laws of the jurisdiction in which we operate.

1. The User is obliged to familiarize himself with the new terms of the Privacy Policy and the Company is not responsible if the User has not familiarized himself with the new terms of the Privacy Policy.

1. The Company updates the date of changes to the current version of the Privacy Policy in the “Updated” line at the top of the document.

1. Our digital or otherwise stored copies of the Privacy Policy are considered true, complete, valid, and enforceable and in effect, at the time you visit the Site.

• CONTACTS

1. The User has the right to contact the Company support service at:support@stilando.world to ensure his rights, in accordance with the terms of this Privacy Policy, or in case of violation of his rights, or to leave feedback or ask a question.