Privacy Policy

Privacy Policy

Last updated: June 15, 2025

This Privacy Policy outlines our policies and procedures on the collection, use, and disclosure of your information when you use our Service. It also explains your privacy rights and how the law protects you.

We use your personal data to provide and improve our Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation: Words with capitalized initial letters have specific meanings under this policy, whether used in singular or plural.

Definitions:

Account: A unique account created for you to access parts of our Service.

Affiliate: An entity under common control with a party, typically sharing ownership or management.

Company / Data Controller: Refers to SECUNDUS FIN OÜ, registered in Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 148, 11317, Estonia.

Cookies: [Not applicable] – Our website does not use cookies or any similar tracking technologies.

Country: Refers to Estonia.

Device: Any device that can access the Service, such as a computer, smartphone, or tablet. • GDPR: The General Data Protection Regulation (EU) 2016/679.

Personal Data: Information that identifies or can identify an individual.

Service: The website operated by SECUNDUS FIN OÜ.

Service Provider: Third-party entities that process data on behalf of the Company.

Usage Data: Automatically collected data such as IP addresses, browser types, and usage statistics.

Website: https://https://performagen.io/

You: The individual or legal entity accessing or using the Service.

Collecting and Using Your Personal Data

Types of Data Collected:

• Personal Data:

We may collect:

o First and last name

o Email address

o Usage data

• Usage Data:

Automatically collected when using the Service and may include information such as your IP address, browser type/version, pages visited, and other diagnostic data.

Tracking Technologies: We do not collect or store cookies or use any similar tracking technologies on our Website. No browsing history, preferences, or session data is stored via cookies. As a result, our Website does not require cookie consent banners or tracking disclosures.

Use of Your Personal Data

We may use your data to:

• Provide and maintain our Service

• Communicate with you

• Respond to inquiries

• Send promotional or marketing communications (only with your prior consent)

• Improve user experience and analytics

• Fulfill legal obligations

• Process business transfers

Sharing Your Personal Data

We may share data:

• With service providers for operational and analytics purposes

• With affiliates under similar privacy protections

• With business partners offering complementary services (only with your consent)

• During business transfers like mergers or acquisitions

• When legally required or necessary for rights protection

Data Retention

We retain your personal data only as long as necessary. You can request deletion or updates at any time. Data may be retained longer if required for legal or regulatory compliance.

Data Transfers

Your information may be transferred to and maintained on servers outside your country. We ensure that such transfers comply with GDPR and include appropriate safeguards (e.g., Standard Contractual Clauses).

Security of Your Data

We use commercially reasonable measures to protect your data. However, no method of transmission over the internet is 100% secure.

Your Rights Under GDPR

As the data controller, SECUNDUS FIN OÜ ensures compliance with the General Data Protection Regulation (GDPR). If you are located in the EU, you have the following rights:

• Right to Access

• Right to Rectification

• Right to Erasure (“Right to be Forgotten”)

• Right to Restrict Processing

• Right to Data Portability

• Right to Object

• Right to Withdraw Consent

To exercise these rights, contact us at: sales@performagen.io

Supervisory Authority Contact:

If you believe we are unlawfully processing your data, you have the right to file a complaint with your local supervisory authority. In Estonia, this is:

Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)

Children’s Privacy

Our Service is not intended for children under 13. If we learn that personal data from children has been collected, we will delete it promptly.

Links to Other Websites

Our Service may contain links to external sites. We are not responsible for the content or privacy practices of those sites.

Changes to This Policy

We may update this Privacy Policy occasionally. Any changes will be posted here and, if significant, notified via email or on the site.

Contact Us

If you have any questions about this Privacy Policy, you can contact us at: sales@performagen.io