Privacy Policy

This Policy is a legally binding agreement between you (“you” or “user”) and us. By accessing and using the Platform, or providing information to us in other formats, you agree and accept the terms of this Privacy Policy as amended from time to time and consent to the collection and use of information as set out in this Privacy Policy. We encourage you to review this Privacy Policy carefully and periodically refer to it to understand it and its subsequent changes, if any. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP USING THE PLATFORM IMMEDIATELY, AND WHERE RELEVANT, UNINSTALL IT.

The definitions in the Terms of Service apply to this Policy unless stated otherwise. IN ADDITION TO THIS POLICY, PLEASE REVIEW OUR TERMS OF SERVICE, WHICH ARE INCORPORATED HEREIN BY REFERENCE, TOGETHER WITH SUCH OTHER POLICIES THAT YOU MAY BE NOTIFIED OF BY US FROM TIME TO TIME.

During your use of the Natutti LTD delivery and installation platform for installing third-party software and third-party mobile applications (“Additional Offers”), Natutti LTD gathers information from your computer.

To protect your privacy and ensure you understand exactly what information is collected, we have set up this Privacy Policy.

What Information Does Natutti LTD Collect and for What Purpose?

We collect two types of data and information from you:

Non-Personal Information

Natutti LTD retains some non-personally identifiable information (“Non-Personal Information”), such as your approximate geo-location, registry, program files, hard drive space, system memory size, CPU, video hardware, browser types, browser extensions, installation date, changes made in your system, time zone, operating system, administrative privileges status, default search providers, browser language, operating system language, system architecture (32bit or 64bit), and other information related to your use of the Platform to provide you with better services.

Non-Personal Information also includes user ID, session ID (which is your User ID and timestamp), File ID (the program the user wants to download), and the URL of the web page from which you arrive. The Platform retains a unique identifier created using some of your system’s variables, such as the hard drive serial number and other hardware information. Please note that the generated User ID cannot be associated or reverse-inferred to indicate a particular person and cannot de-anonymize or divulge user identity. This information is retained so that Natutti LTD can audit and track installations, statistically analyze usage, audit its affiliates, and calculate payments to third parties based on such installations.

Additionally, we collect information regarding the installation process, including the software and Additional Offers presented to you via Natutti LTD and installed on your computer or mobile device, as well as technical information regarding the installation process, such as success/failure, duration, malfunctions, errors, etc. The installation information is used to provide, maintain, and improve Natutti LTD’s operation and services.

This technical Non-Personal Information is used by our servers to provide, maintain, and improve the Natutti LTD operation and services, such as verifying that any installed Software and Additional Offers are compatible with your computer or mobile device; determining which Additional Offers and versions should be offered to you and installed on your computer or mobile device; correlating errors with certain technical information for debugging purposes; and creating and managing statistics to guide future improvements and developments.

Personal Information

“Personal Information” is information that identifies or may identify you, or may be of a private or sensitive nature. When you send us your name and e-mail address through the “contact us” form field, we retain this information. Additionally, the Personal Information we collect includes your IP address and information gathered by searching predefined limited keywords and terms in your search queries, cookies, and browsing history. It is collected and retained so that Natutti LTD can audit, track installations, and perform fraud detection checks, as well as security and compatibility verifications during the installation.

We also treat any Non-Personal Information specifically connected or linked to any Personal Information as Personal Information as long as such connection or linkage exists.

How is the Information Processed?

The Personal Information and Non-Personal Information we process are stored on your computer and analyzed to create statistical and profiling information that we process to allow better service and monitor the use of Natutti LTD.

Sharing Information with Third Parties

We share Non-Personal Information with third parties when this is required to provide, maintain, or improve the Natutti LTD operation and services. We will NOT share Personal Information with any third party, except in an aggregated or statistical form.

As a core part of our revenue model, during the installation process, Natutti LTD may display third-party advertisements, Offers, and Additional Offers. We share your Non-Personal Information with such third parties to provide you with advertisements and Offers we or such third parties think you may be interested in, based on your statistical Non-Personal Information.

Such third-party services may have their privacy policies, and we advise you to read them carefully. Inclusion of a link to a third-party website or service is not a recommendation of a third-party website, product, or service. Third-party sites may contain information or services that are illegal, unreasonable, or that some people may find inappropriate or offensive. Before using third-party sites and services or making a purchase, we recommend you read and understand those sites’/product’s terms and conditions, shipping, return, warranty, and privacy policies and ensure you agree to their terms. You acknowledge that we are not responsible for the products, services, or descriptions of those products or services that you receive from third-party sites or the content or privacy practices of those sites and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

We may share your Personal Information and other information in special cases if we have a good reason to believe that it is necessary to:

• Comply with law, regulation, subpoena, or court order
• Detect, prevent, or otherwise address fraud, security, violation of our policies, or technical issues
• Enforce the provisions of this Privacy Policy or any other agreements between You and Natutti LTD, including the investigation of potential violations thereof
• Protect against harm to the rights, property, or safety of Natutti LTD, its partners, its affiliates, users, and/or the public.

Security and Confidentiality

The collection and processing of your information aim to provide you with services offered by us and third parties. We will store this information as long as it is reasonably necessary to attain the mentioned purposes and in accordance with any applicable legal or ethical requirements.

We place great emphasis on the security and integrity of your information and the data stored in our systems. We have security measures in place to prevent unauthorized access to and protect the loss, misuse, and alteration of the information under our control. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied, or otherwise, that we will prevent such access.

We shall notify any user whose information is suspected of being accessed, disclosed, altered, or deleted by an unauthorized person so that they can take appropriate measures to minimize the adverse effects of such a data security breach (Breach Notification). Such Breach Notification will be given within a reasonable time after we learn of said breach unless we deem, at our sole discretion, that such Notification might hinder and prevent ongoing efforts to detect the source of the breach.

For the avoidance of doubt, a Breach Notification does NOT constitute an admission by us that the breach occurred due to malpractice, failure, bad faith, or negligence on our behalf or that the breach even occurred in our systems.

If you feel that your privacy was treated not in accordance with our Policy, please contact us directly at [email protected], and our privacy officer shall investigate promptly.

No Obligation to Store Information

Nothing in this Policy is interpreted as an obligation to store information, and we may, at our discretion, delete or avoid recording and storing any and all information.

Children Protection

Regardless of the aforementioned, we do not knowingly collect or store information regarding children under the age of 13.

Information Warranty Disclaimer

Notwithstanding anything else in this Policy, we are not responsible for the accuracy, correctness, and security of any information we gather, store, and disclose to you or anyone else.

Review and Deletion

We value your privacy and control over your personal information, and therefore you may, at any time, notify us that you wish to either review your personal information or delete it. You can notify us by sending an email to our legal department at [email protected]. To delete or allow you to review your personal information, we may require you to provide us with identifying information or install additional Offers to allow such review.

Changes to this Privacy Policy

This Policy may be revised from time to time at our discretion, so please check it regularly. The last revision will be reflected in the “Last modified by” heading.

Change of Ownership

In the event of a change of ownership or control of all or part of Natutti LTD, including without limitation through acquisition, merger, or sale, we reserve the right to sell all or part of the Personal Information and Non-Personal Information we store in our systems. You acknowledge that in the event of bankruptcy, insolvency, or receivership, we may have no control over the use and transfer of your personal information.