NORTHDREAMER PRIVACY POLICY AND GDPR
1. Scope of the Privacy Policy
1.1. This Privacy Policy and GDPR (‘’Privacy Policy’’) sets out the principles and procedure for the processing of personal data collected by NORTHDREAMER LLC (‘’Data Controller’’) ,of which the company details is given below, from all Users and Clients (‘’Data Subjects’’) and from all datas collected from www.einitinapplication.com (‘’Web Site’’).
Data Controller Company and Data Controller Contact Personal Details:
NORTHDREAMER LLC
+1 (307) 306-4740
30 N GOULD ST , STE 33683
SHERIDAN, WYOMING 82801
2. Collection of Personal Data
2.1. NORTHDREAMER collects the information of natural and legal persons (”Data Subject”) who visit the URL address www.einitinapplication.com (”Web Site”), use the services and functions on this Website or order the services of NORTHDREAMER and benefit from these services in accordance with the law and legislation.
2.2. NORTHDREAMER may collect Data Subject’s login information, localization information, clicking and routing information automatically with the programs and algorithms placed on the Website. The User accepts and declares that he / she gives express consent (”Express Consent”) to the collection of personal data in this way.
2.3. NORTHDREAMER collects personal data and special categories of personal data contained in these application forms by transmitting the application forms allocated for the use of Users on the Website. The User accepts and declares that he/she gives explicit consent to the collection of his/her personal data in this way.
2.4. Information and documents contained in the application forms are;
i) US Company Formation Documents such as Articles of Organization, Certificate of Formation, etc.
ii) US Company Ownership/Membership Documents such as Initial Resolutions, Statement of Organizer, Statement of Authorized Person, Resignation of Organizer, etc.
iii) US EIN Document (147 C or CP575)
iv) Passport Scan Copy
v) Full home country address
vi) E-mail address
vii) Phone number
And other information and documents submitted by the Data Subject in tangible or intangible environment in the application attachment. The personal data subject to such information, documents, records, drafts, pages and files may be statistically and graphically analyzed by NORTHDREAMER for the sole purpose of improving the service performance and improving the service experience of the Clients without any commercial purpose.
2.4. NORTHDREAMER collects personal data and sensitive data contained in all kinds of written, visual or audio information, documents, records, folders, drafts, pages and files that Users submit in the attachment of the application form or make accessible. The User accepts and declares that he/she gives explicit consent to the collection of his/her personal data and sensitive personal data in this way.
2.5. NORTHDREAMER collects all kinds of special categories of personal data or personal information in the nature of personal data from the Client during the execution of the orders to be created by clicking the buttons on the Website and making payment. The User accepts and declares that he/she gives explicit consent to the collection of his/her personal data in this way.
2.6. NORTHDREAMER automatically collects service and package information, IP address and traffic information, signal information, order history information, which will be subject to the order in the shopping card/order card of the Data Subjects from the Web Site with the performance of session tools on the Website. The User accepts and declares that he/she gives explicit consent to the collection of his/her personal data in this way.
2.7. NORTHDREAMER, without seeking the explicit consent or non-explicit consent of the Data Subjects, It may collect personal data and sensitive personal data of Data Subjects at any time and by any means that it is limited to the purposes of i) protecting its own legitimate interests, ii) obtaining and processing personal data contained in information and documents that are mandatory for the provision of services to Clients, iii) responding to or submitting to the legal notifications, subpoenas, writings of official authorities. The Data Subject accepts and declares that he/she gives explicit consent to the collection of his/her personal data and sensitive personal data in this way.
2.8. NORTHDREAMER may collect the personal data of the Data Subject in third party real persons and legal entities (”Third Party”) with whom the Data Subject has an independent contractor status; in cases where it is understood that third parties are authorized to transfer, transmit, store or process the personal data of the Data Subject or where there are reasons for compliance with the law. The User accepts and declares that he/she gives explicit consent to the collection of his/her personal data and sensitive personal data in this way.
2.9. NORTHDREAMER may collect personal data contained in any information, document, record, draft, page, model and other files and folders that the Data Subject publicly shares, publishes, transmits, presents, makes accessible, exhibits, stages, publicizes, discloses to the public. The Data Subject accepts and declares that he/she gives explicit consent to the collection of his/her personal data and sensitive personal data in this way.
2.10. The Data Subject shall not keep the positioning information of the file containing every information, document, document, record, page and draft that it uploads, transmits, publishes in any way whatsoever to the Website and its sub-domains and interfaces, which are the intellectual property of NORTHDREAMER, inaccessible. The Data Subject accepts and declares that third parties or other Users and Visitors may i) download any information, document, record, draft and page uploaded to the Website and its sub and side platforms; from the publicly accessible areas on these platforms, i) download it to their electronic devices, ii) export it from the Website and the relevant area, iii) view the format characteristics of the information and document (information such as the date of creation of the file, etc.).
2.11. NORTHDREAMER is obliged to ensure that the application forms and information, documents, records, drafts, pages, signed or unsigned files to be uploaded by Data Subjects who order and pay for NORTHDREAMER’s services are uploaded, transmitted and displayed on the Website areas and platforms that are not accessible to everyone. NORTHDREAMER may transfer all kinds of written, visual and audio-visual documents contained in the application form and its attachment to third party real and legal entities in the country or abroad and store these information and documents only for the purposes listed in this Privacy Policy.
3. Processing of Personal Data
3.1. NORTHDREAMER may use the personal data and sensitive personal data collected from the Data Subject for the purposes listed below, transfer, store, archive, record, make copies of, store and in any case process such data. The User accepts and declares that he/she gives explicit consent to the processing of his/her personal data and sensitive personal data in these ways and for these purposes. The Data Subject may withdraw his/her explicit consent at any time. In this case, the Data Subject accepts, declares and undertakes that the use or utilization of some or all of the Website services and facilities may be restricted or disabled:
i) Performing payment services and/or collection services within the scope of IT and/or software products and/or services, e-commerce services (including trading platforms and online payment/collection intermediaries),
ii) Providing and performing services within the packages and orders subject to the advertisements by NORTHDREAMER,
iii) Promotion of service package and orders and marketing activities through short messages and commercial electronic mail messages, (The Data Subject accepts and declares that he/she has given his/her explicit consent for the sending of commercial electronic messages)
iv) User cookies collected through NORTHDREAMER’s Web Site (www.einitinapplication.com) and the performance of digital (google ads, social media ads, e-mail marketing, etc.) or traditional (phone call, SMS, etc.) marketing activities through the e-mail and phone number of the Clients and through domestic and foreign business partners according to product or service ownership or related field,
vi) Performing online sales or telemarketing services, creating orders, executing and maintaining user account activities,
vi) By conducting online sales or telemarketing activities, promoting the services of the NORTHDREAMER and the NORTHDREAMER’S ability to contact and communicate with the Data Subject in order to do so,
vii) Ensuring the submission and delivery to the Data Subject of the invoice (electronic invoice, paper invoice) issued in return for the service purchased by the Client,
viii) Tracking and operating support requests for refunds, payments and orders,
ix) Conducting activities that will enable the development, organization and/or improvement of services such as quality measurement, service needs analysis, Client demand analysis via e-mail or website with Web Site or call center and/or written, audio or video calls for telemarketing or digital marketing purposes,
x) Introducing the packages, services and orders for the purpose of enlightenment, presenting the Clients with requests and suggestions, informing the Clients about campaigns, promotions and discounts, enlightening the Client about the scope of these campaigns and promotions, enlightening the Clients about the scope and liability of other opportunity activities and services, and providing information on the basis of their rights,
xi) Promotion and marketing of new service packages to be presented and showcased to Clients,
xii) Performing management of mass electronic messages to Data Subjects,
xiii) Analyzing the Web Site and its subdomains, interface and all pages (through algorithms or other web applications) and thus increasing the panel and website service and cookie performance,
xiv) Performing personalization and targeting activities for the services and panels provided on the Web Site.
xv) To communicate with the Client regarding the terms and provisions, current status and updates of the contracts concluded with the Clients in accordance legislation, and to provide information arising from our Web Site agreements and policies.
xvi) If It is necessary to process personal data belonging to the Data Subjects, provided that it is directly related to the establishment or performance of any contract to be established with the Client,
xvii) If It is mandatory for NORTHDREAMER to perform and fulfill its obligations arising from contracts and legislation,
xviii) If It is mandatory to process your data for the exercise, waiver or relinquishment of a right or for its protection.
xix) Other reasons, such as when proportionate data processing is necessary for NORTHDREAMER’s legitimate interests, provided that it does not violate or prejudice the Client’s rights.
3.2. Personal Data may be processed by NORTHDREAMER without Explicit Consent if it is mandatory for the protection of the life or physical integrity of the Data Subject or someone else other than the Data Subject who is unable to disclose his consent due to actual impossibility or whose consent is not legally valid.
3.3. Personal Data may be processed by NORTHDREAMER without Explicit Consent if data processing is mandatory for the legitimate interests of NORTHDREAMER.
3.4. Personal Data made public by the Data Subject may be processed by NORTHDREAMER without obtaining Explicit Consent.
3.5. If the Processing of Personal Data is mandatory for the establishment, exercise or protection of a right, Personal Data may be processed by NORTHDREAMER without obtaining Explicit Consent.
3.6. When the legitimate purpose for the Processing of Personal Data disappears, the relevant Personal Data shall be Deleted, Destroyed or Anonymized. Destruction or Deletion of unrelevant Personal Data is performed by NORTHDREAMER periodically every 6 months.
3.7. Upon the request of the Data Subject, the personal data of the Data Subject, which is under the scope of the principles agreed in this Privacy Policy and which is irrelevant to be processed in accordance with the Privacy Policy the legislation, shall be destroyed within 30 (thirty) days.
3.8. NORTHDREAMER reserves the right to anonymise Personal Data gathered and to use any such data. NORTHDREAMER shall use data outside the scope of this Policy only when the Personal Data is anonymised. NORTHDREAMER saves Data Subject’s billing information and other information gathered about Data Subject for as long as needed for obligations deriving from law.
4. Sensitive Personal Data.
4.1. Sensitive Personal Data refers to data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data.
4.2. NORTHDREAMER shall process the sensitive data of the Data Subject only and exclusively with his/her explicit consent. The Data Subject is deemed to have given explicit consent for the processing and collection of sensitive data by using the Website services or by uploading and transmitting the relevant information, document, folder, draft, model, record and page for the service purchased.
5. Transfer of Data to Third Parties
5.1. NORTHDREAMER may transfer Personal Data to a third natural or legal person at USA and/or abroad in accordance with purposes and permissions agreed in Article 3. the Personal Data Protection Regulations by taking the necessary measures in line with the purposes of Personal Data Processing. In this case, NORTHDREAMER ensures that third parties to whom it transfers Personal Data also comply with Privacy Policy.
6. Storage of the Data.
6.1. NORTHDREAMER takes all necessary measures and all cautions to ensure that Personal Data is complete, accurate and up-to-date and updates the relevant Personal Data in the event that the Data Subject requests changes to Personal Data within the scope of PDP Regulations. NORTHDREAMER does not guarantee and undertake in any way that the personal and sensitive data of the Data Subject will not be invaded, lost, captured, stolen, intercepted, obtained by third parties or deleted by third parties.
7. Rights of Data Subject
7.1. All Data Subject may apply to the NORTHDREAMER (which the company and Contact Personal details are listed at Article 1 of Privacy Policy) and obtain the following information about him/her;
a) Learn whether personal data is being processed,
b) Request information if personal data has been processed,
c) The purpose of processing personal data and whether they are used in accordance with their purpose learning,
d) To know the third parties to whom personal data are transferred domestically or abroad,
e Correcting whether the personal data is incomplete or subject to incorrect processing
f) To request the deletion or destruction of personal data within the framework of the conditions stipulated in this Privacy Policy
g) To request that the operations performed pursuant to subparagraphs (e) and (f) be notified to third parties to whom personal data are transferred,
h) To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
i) In case of damage due to unlawful processing of personal data have the right to demand compensation for the damage.
8 Violations.
8.1. Each employee of the NORTHDREAMER LLC reports to the Data Controller that the business, performance or action that he / she thinks is contrary to the procedures and principles specified in the Privacy Policy. In this context, the Data Controller creates an action plan for the relevant violation in accordance with this Policy and PDP Procedures.
9. Audit.
9.1. NORTHDREAMER has the right to regularly and ex officio audit that all employees, departments and contractors of the NORTHDREAMER act in accordance with this Privacy Policy and PDP Regulations at any time and ex officio without any prior notice and conducts the necessary routine audits within this scope. The Data Controller and the Data Controller Contact Person shall establish a PDP Procedure for these audits, submit it to the approval of the Board of Directors and ensure the implementation of the said procedure.
10. Training.
10.1. NORTHDREAMER shall provide the necessary trainings to its employees on the protection of Personal Data within the scope of the Privacy Policy.
11. Cookie Policy.
11.1. NORTHDREAMER uses cookies and session tools and other similar technologies to analyse customer behaviour, maintain the Web Site Services , track Data Subject activities and movements, and to collect information about Data Subjects.
NORTHDREAMER uses cookies for the following purposes:
Necessary Cookies: These cookies are required to be able to use some important features on Web Site, such as logging in. Necessary Cookies don’t collect any personal information.
Functionality Cookies: These cookies provide functionality that makes using NORTHDREAMER’s Web Site services and facilities more convenient and makes providing more personalised features possible.
Analytics Cookies: These cookies are used to track the use and activities and the performance of Web Site and its services.
Advertising Cookies: These cookies are used to deliver advertisements that are relevant to User and Data Subject and to Data Subject’s interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
11.2. Data Subject can remove cookies stored in his/her device via his/her browser settings. Alternatively, Data Subject can control third party cookies by using a privacy enhancement platforms.
12. Children.
12.1. NORTHDREAMER DOES NOT KNOWINGLY AND INTENTIONALLY COLLECT PERSONAL DATA AND SENSITIVE DATA OF CHILDREN. NORTHDREAMER DOES NOT ENTER INTO A SERVICE RELATIONSHIP WITH CHILDREN.
13. Modifications.
13.1. NORTHDREAMER, reserves the right to change the terms, conditions, and notices under the Privacy Policy and other Web Site agreements which is adjusted from time to time, at any time and without prior notice.
14. Execution.
14.1. The Privacy Policy shall be deemed to be established and enter into force between parties at the same time as the User expressly accepts this Agreement or is deemed to have accepted it in accordance with the clauses set out in the Agreement (e.g. viewing the Services, using the Services, creating an order, etc.)
