Privacy Policy

This Privacy Policy describes how RBY & Co SIA, operating under the brand Recoverby (“we,” “our,” or “us”), collects, uses, discloses, and otherwise processes information that relates to you. This Privacy Policy applies to personal information collected both online and offline, including when you visit Recoverby.com, use any application or service that links to this Policy, or communicate directly with us (collectively, the “Services”).

This Privacy Policy is intended to be read together with our Terms & Conditions. It complies with the General Data Protection Regulation (GDPR) and applicable EU and Latvian privacy laws.

BY USING OUR SERVICES OR OTHERWISE PROVIDING US WITH YOUR PERSONAL INFORMATION, YOU EXPRESSLY CONSENT TO THE INFORMATION HANDLING PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT ACCESS OR USE THE SERVICES.

For any questions about this Privacy Policy or our privacy practices, please contact us at info@recoverby.com.

The data controller responsible for your personal information is:

RBY & Co SIA

Registration No.: 40203740288

Address: Dunikas iela 25, Liepaja, Latvia, LV-3407

Email: info@recoverby.com

The data controller implements the organisational and technical measures necessary to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, or any other unlawful processing.

Personal information is any information that relates to or can be used to identify you. The categories we collect depend on your interactions with us and our Services.

• Information You Provide Directly

We collect information when you place an order, register an account, subscribe to our newsletter, or contact us for support. This includes:

1. Basic identifying information: name, email address, physical address, phone number

2. Date of birth (where required for age verification)

3. Payment information: payment card details processed securely by our payment provider

4. Order information: details of products purchased, delivery address, pricing and payment records

5. Account information: username, password, and communication preferences

6. Any other information submitted when using our Services or communicating with us

You are responsible for ensuring that any personal information you submit is accurate, complete, and up to date. You must notify us promptly of any changes. We are not responsible for losses arising from inaccurate information provided by you.

By providing us with personal information about another person, you confirm that you have obtained that person’s permission to share their information with us for the purposes outlined in this Policy.

• Automatically Collected Information

When you visit our website, we automatically collect certain technical data from your browser or device, which may include:

1. IP address and general location inferred from it

2. Browser type and language, operating system

3. Referring and exit pages, URLs visited, time spent on pages

4. Dates and times of visits

• Information from Third-Party Sources

We may obtain information about you from third-party sources such as business partners, contractors, and publicly available records, in order to improve the accuracy and completeness of our records.

• Social Media

If you interact with us on social media platforms (including Facebook, Instagram, and TikTok), any personal information you submit may be visible to other users of those platforms. We are not responsible for the information you choose to submit on social media or for the privacy practices of those platforms.

We use cookies and similar tracking technologies to enhance your experience, analyze web traffic, remember your preferences, and improve our Services. Cookies are small text files stored on your device.

• Types of Cookies We Use

1. Essential Cookies — necessary for the website to function and to enable navigation and use of its features

2. Performance Cookies — collect anonymous information about how visitors use our website to help us improve its performance

3. Functional Cookies — remember your preferences (such as language or region) to personalise your experience

4. Targeting / Advertising Cookies — deliver relevant advertisements based on your browsing behaviour and help measure the effectiveness of marketing campaigns

• Pixels

We may use pixels (web beacons) to help deliver cookies, track user sessions, and measure the effectiveness of our promotions.

• Your Cookie Choices

By using our Services, you consent to the use of cookies in accordance with this Privacy Policy. You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the website.

We use third-party analytics providers, such as Google Analytics and Facebook Pixel, to collect information about how users interact with our Services. These providers use cookies and similar technologies to gather data that helps us analyse user behaviour and improve our offerings.

Analytics Providers may collect demographic information, usage data (pages visited, time on site, entry/exit pages), and technical data (browser type, OS, IP address). This information may be shared with us and with other website operators in aggregated form.

Users can manage cookie preferences through their browser settings. For Google Analytics, you may use the Google Analytics Opt-out Browser Add-on. For Facebook Pixel, please visit Facebook’s Privacy Policy. Disabling cookies may affect your experience on our website.

We process your personal data on the following legal grounds under Article 6(1) of the GDPR:

• Consent (Art. 6(1)(a)) — where you have given explicit consent, e.g., to receive marketing communications

• Contract (Art. 6(1)(b)) — where processing is necessary to fulfil an order or take steps at your request before entering into a contract

• Legal obligation (Art. 6(1)(c)) — where processing is required to comply with a legal obligation, e.g., accounting and tax law

• Legitimate interests (Art. 6(1)(f)) — where processing is necessary for our legitimate business interests, such as fraud prevention, website security, and service improvement, provided these are not overridden by your rights

We use your personal information only for the purposes for which it was collected or where applicable law allows. These purposes include:

• Order fulfilment — processing purchases, shipment, payment, and sending order confirmations and updates

• Account management — creating, maintaining, and securing your account

• Customer support — responding to enquiries and resolving issues

• Marketing and promotions — informing you about our products, services, and offers (where you have consented)

• Website improvement — monitoring and analysing usage trends to improve our site, products, and user experience

• Personalisation — tailoring content and advertisements to your interests

• Security — maintaining the safety and integrity of our Services

• Research and development — testing and improving our Services

• Legal compliance — responding to law enforcement requests and complying with applicable laws

• Fraud prevention — detecting and addressing fraudulent or harmful activities

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• Marketing Communications

If you have provided your email address and consented to marketing communications, we may send you news and promotional offers. Every marketing email will include an unsubscribe link. You may also withdraw consent at any time by contacting us at info@recoverby.com. Please note that even if you opt out of marketing emails, we may still send you important service-related notices.

• Advertising

We use third-party advertisers to deliver targeted advertisements across the internet based on your interactions with our Services. These providers may use cookies, pixels, and other technologies to collect data and personalise ads. Their practices are governed by their own privacy policies. For opt-out options, visit optout.aboutads.info.

We do not sell or rent your personal information to third parties. We may share your information in the following circumstances:

• Service providers — trusted partners who assist us with order processing, delivery, customer support, and IT services, who are contractually obligated to keep your data confidential

• Payment processing — payments are processed securely by Stripe, a PCI-DSS Level 1 certified payment processor. We do not store your payment card details on our servers. Stripe may collect personal data 0 including via cookies and similar technologies - as part of providing secure payment services. This may include transactional data and identifying information about devices that connect to its services. For more information, see Stripe's Privacy Policy.

• Delivery partners — your name and delivery address are shared with logistics and courier partners solely to fulfil your order

• Legal authorities — we may disclose information to government regulators or law enforcement where required by law, to protect victims of fraud, or to defend our legal interests

• Business transfers — in the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction

We cannot guarantee that all personal information will be disclosed only as described in this Policy. No method of data transmission over the internet is 100% secure, and third parties may unlawfully intercept communications.

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specifically, we retain data for as long as:

• It is necessary for the purposes for which it was collected

• We or you are able to exercise legitimate interests under applicable law, such as bringing or defending legal claims

• A legal obligation to retain it exists, for example under accounting or tax legislation

• Your consent remains valid, where consent is the legal basis and no other basis applies

When none of the above conditions apply, your personal data is permanently and securely deleted from our systems and any physical or electronic records, or anonymised so that you can no longer be identified.

As a data subject under the GDPR, you have the following rights with respect to your personal information:

• Right of access — to request access to the personal data we hold about you and details of how it is processed

• Right to a copy — to receive a copy of your personal data in a commonly used electronic format (data portability)

• Right to rectification — to request correction of inaccurate, incomplete, or outdated data

• Right to erasure — to request deletion of your data (“right to be forgotten”), subject to legal exceptions

• Right to restrict processing — to request that we temporarily suspend processing of your data

• Right to object — to object to processing based on legitimate interests or for direct marketing purposes

• Right to withdraw consent — to withdraw consent to data processing at any time, without affecting the lawfulness of processing carried out before withdrawal

• Right to lodge a complaint — to lodge a complaint with the Data State Inspectorate of Latvia (Datu valsts inspekcija) or another relevant supervisory authority

You may exercise these rights free of charge by contacting us at info@recoverby.com or in writing to: Dunikas iela 25, Liepaja, Latvia, LV-3407. We may require verification of your identity before responding to your request. We will respond in writing within 15 days.

EEA residents may also lodge complaints with the European Data Protection Board. More information is available at the EDPB Members page.

• Security Measures

We implement appropriate physical, administrative, and technical safeguards to protect your personal information against accidental or unlawful destruction, alteration, unauthorised disclosure, or access. This includes the use of SSL encryption for data transmission.

Despite our efforts, no method of transmission over the internet or electronic storage is entirely secure. We are not responsible for lost, stolen, or compromised passwords, or for unauthorised account activity resulting from such. In the event of a security breach affecting your personal data under our control, we will take reasonable steps to investigate and notify you as required by applicable law.

• Storage

Your personal information is stored in environments secured against unauthorised access, protected by a combination of physical and technical security measures. Third-party hosting providers used by us are required to maintain equivalent standards.

We do not knowingly collect personal information from children under the age of 16 without verified parental consent. If we become aware that we have collected personal data from a child under 16 without such consent, we will take steps to delete that information as quickly as possible.

If you believe we have inadvertently collected personal information from a minor under 16, please contact us immediately at info@recoverby.com.

We are headquartered in Latvia, within the European Union, and our Services are governed by EU law. If you are accessing our Services from outside the European Union, your personal information may be transferred to, stored, and processed within the EU.

Data protection laws within the EU — in particular the GDPR — may offer a higher level of protection than the laws of your home country. By using our Services, you consent to the transfer, processing, and storage of your information within the EU in accordance with this Privacy Policy.

Our website may contain links to third-party websites and social media platforms. We are not responsible for the content or privacy practices of those external sites. We encourage you to review their privacy policies before submitting any personal information.

We reserve the right to update this Privacy Policy at any time without prior notice. Changes will be effective immediately upon publication on Recoverby.com. Your continued use of our Services after any changes constitutes your acceptance of the updated Policy. We will notify you of significant changes by posting a notice on our homepage or sending an email to the address on file.

If you have any concerns about the privacy of your personal information or our practices, we encourage you to contact us first at info@recoverby.com so that we can attempt to resolve the matter amicably.

If we are unable to reach a satisfactory resolution, you have the right to lodge a complaint with the Data State Inspectorate of Latvia (Datu valsts inspekcija) or any other relevant EU supervisory authority. You may also refer disputes to EU online dispute resolution platforms.

Any unresolved disputes will be handled in accordance with the governing law of Latvia, as described in our Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us:

RBY & Co SIA (Recoverby)

Dunikas iela 25, Liepaja, Latvia, LV-3407

Email: info@recoverby.com

Website: recoverby.com