SECTION 1 – GENERAL CONDITIONS
EACH USER MUST CAREFULLY READ AND COMPLY WITH THIS POLICY.
You provide and guarantee to us the right to process your personal data, including the right to perform the following actions to process your personal data (fully or partially in an automated system): storing, registration, changing, restoring, and removing. Also you agree that your personal data is included in the personal data base and any additional notification is not required.
SECTION 2 – DEFINITIONS
2.1.1. “Website” shall mean the website maintained at cloud.propuskator.com and/or all the subdomains of the website «cloud.propuskator.com».
2.1.3. “Personally identifiable information” (hereinafter – “Personal Information” or “Personal Data”) shall mean any information that can be directly associated with a specific person and can be used to identify that person (including the information about Your activities, such as information about Your use of the Website and/or the Mobile application, when directly linked to personally identifiable information, including automatically collected). We do not consider Personal Data to include information that has been anonymized so that it does not identify a specific User.
2.1.4. “Controller” means a legal person, which determines the purposes and means of the processing of personal data.
2.1.5. “Processor” means a natural or legal person, which processes personal data on behalf of the Controller.
2.1.6. “Owner” (“Website Owner”, “Mobile application Owner”) or “Operator” or “we”, ( “us” or “our”) means a legal person (entity) – LLC «TOO SMART TECHNOLOGY» (registration code: 43286855), which owns the exclusive rights for the objects of intellectual property – the Website and/or the Mobile application. LLC «TOO SMART TECHNOLOGY» registered under the legislation of Ukraine (address: 03164, Ukraine, Kyiv, Pidlisna street, 1, office 11).
SECTION 3 — INFORMATION WE COLLECT AND PROCESS
3.1. The User hereby expressly consents to provide to Us, immediately upon Our notice of request, any information (including Personal Data) that We, in Our sole discretion, deem to be required to maintain compliance with any law, regulation or policy.
3.2 Technical (programmatic) means of our Website and/or the Mobile application can collect such Personal Data: first name, e-mail, user location. 3.3. The above mentioned information and documentation, described in paragraph 3.2., may be requested and or collected by us prior to activating Your account on the Website and/or the Mobile application and/or any services available through the Website and/or the Mobile application. Any doubts as to validity, authenticity and genuineness of the documents and information, provided by You shall be considered a valid reason to deny Your access to our Website, the Mobile application and services.
3.4. The User, You hereby expressly consents, represents and warrants that any and all information provided to Us is valid, current, complete and accurate.
3.5. Personal Data Collected from all the Users, including non-registered Users. We collect the Personal Data from running the Website and/or the Mobile application and use information, provided to Us by You, sent to Us by Your computer, mobile phone, or other access device, which may include Your IP address, device information including, but not limited to, identifier, name, and type, operating system, mobile network information and standard web log information, such as Your browser type, and the pages You accessed on Our Website and/or the Mobile application. You (as a user) give your voluntary and undoubted consent for the collection and processing specified data and its transfer to third parties in order to implement functioning of the Website and/or the Mobile application and its appropriate work.
3.6. We also collect and store such information as: User requests in support regarding the work of the Website and/or the Mobile application, its related services and other issues.
3.8. YOU AGREE THAT YOUR PERSONAL DATA MAY BE PROCESSED AND STORED BY US OR OUR COUNTERPARTIES DURING THE PERIOD OF TIME THAT IS PRACTICALLY NECESSARY TO FULFILL THE AIMS AND PURPOSES THAT IMPACT WITH FUNCTIONAL PURPOSE OF THE WEBSITE AND/OR THE MOBILE APPLICATION.
SECTION 4 — HOW WE USE YOUR INFORMATION
We use the information we receive from you as follows:
4.1. We collect only the User’s Personal Data that we need for their proper using of the Website and/or Mobile application. In particular, we use Your Personal Data to:
administer Our Website and/or the Mobile application and/or provide services;
develop new products and services;
personalize Our Website and/or the Mobile application for You;
send You technical notices, support and administrative messages;
communicate with You about products, services, promotions, events and other news and information we think will be of interest to You;
monitor and analyze trends, usage and activities in connection with Our Website and/or the Mobile application and/or services;
provide third parties with statistical information about Our Users (but those third parties will not be able to identify any individual User from that information);
4.2. The Website and/or the Mobile application Owner is the only data controller and processor, except for the cases when there is an objective Website (the Mobile application) Owner’s need to control/process or store information at the Website (the Mobile application) Owner’s counterparties or agents.
SECTION 5 — PERSONAL DATA PROTECTION AND STORAGE
5.1. The Website (the Mobile application) Owner will do any and all efforts and actions prescribed by Applicable Law to store any of Your Personal Data in secrecy by means of, including but not limited to firewalls and data encryption, physical access controls to Our data centers, and information access authorization controls (which are designed to comply with Applicable Law and regulations), authorization of access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities.
5.2. Personal Data of Our users is stored and processed on servers in Netherlands. However, Your Personal Data may be temporarily stored and processed in other jurisdiction, in particular in Ukraine.
5.3. We reserve the right to store, process and transfer Your Personal Data to Our servers in various jurisdictions, where Our facilities and/or Our service providers are located. It may also be processed by staff operating who work for Us and/or for one of Our service providers. Staff may be engaged in the fulfillment of Our services and/or the processing of Your data and/or the provision of support services. By submitting Your Personal Data, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Policy.
SECTION 6 — THIRD PARTIES
6.1. We may share your personal information with:
service providers under contract who help with parts of our business operations;
Our banking partners;
companies that We plan to merge with or be acquired by (should such a combination occur, We will require that the newly combined entity follow these terms with respect to Your Personal Data);
law enforcement, government officials, or other third parties when We are compelled to do so by a subpoena, court order, or similar legal procedure; or We believe in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of Our policies;
Our Personal Data processing counterparties or agents, hired by or cooperating with Us, whose services are required by Us from the practical point of view;
other third parties — only with Your prior consent or direction to do so.
SECTION 7 — INTEGRATING THIRD PARTY SERVICES AND LINKS TO OTHER WEBSITES
7.1. Our Website and/or the Mobile application may, from time to time, contain links to and from the websites and/or mobile applications of Our partner networks, advertisers, and affiliates (including, but not limited to, websites on which the Website is advertised). If You follow a link to any of these websites and/or mobile applications, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these policies before You submit any Personal Data to these websites or use these services.
SECTION 8 — PROTECTING YOUR CHILD’S PRIVACY
8.1. Our Website and/or the Mobile application are not designed for use by anyone under the age of 13. If you are a child (a person under the age of 13 years), you should withhold from using Our Website and/or the Mobile application. If you are a parent or guardian and believe your child is using Our Website and/or the Mobile application, please contact us to remove your child’s account. We reserve the right to ask you for verification of your relationship to the child before we honor such a request. However, as parent of a child, you should understand that you are legally liable for any actions of your child.
8.2. Some functions of the Mobile application may be available only to persons who have reached the age of full dispositive legal capacity of a natural person.
SECTION 9 - RETAIN INFORMATION
9.1. In accordance with applicable laws and as needed to provide services to our Users, we may hold your Personal Data. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. We may retain Your Personal Data for as long as Your account is active. Moreover, Your Personal Data may be hold beyond the abovementioned period till it is indispensable for Us to have relevant information to respond to any issues that may arise later.
SECTION 10 - SECURITY
10.1. We use relevant electronic and procedural safeguards to protect the privacy of the information you provide to Us from loss, misuse, disclosure, alteration and destruction.
10.2. PLEASE NOTE THAT TRANSMISSION OF DATA OR INFORMATION (INCLUDING COMMUNICATIONS BY E-MAIL) OVER THE INTERNET OR OTHER PUBLICLY ACCESSIBLE NETWORKS IS NOT ONE HUNDRED PERCENT SECURE.
SECTION 12 — YOUR RIGHTS AS THE DATA SUBJECT, APPLICABLE LAW
12.3. “How to remove all of Your Personal Data?”
You have right to require correction of your Personal Data, updating, complete removal or removal of incorrect and/or inaccurate data by sending Us an email to email@example.com. Nevertheless, this request must comply with the aim of using Our Website and/or Mobile application and Our legal obligations.
12.4. “How to prohibit Personal Data processing if you are allow this before? How to get all of Your Personal Data collected by Us?”
If you want to prohibit Personal Data processing or get all of your Personal Data collected by Us, you can send Us a require via email firstname.lastname@example.org.
SECTION 13 — CONTACT US
13.1. If you have any questions regarding this Agreement, please contact us by e-mail – email@example.com.