1.1. This Policy is an official document of the Company and an integral part of offer as well as any other contracts concluded with the User, when expressly provided for by their terms.
1.2. Using the Site and/or Mobile Application, the User freely, by his own will and in his own interests, give written consent to the following ways of processing your personal data:
Collection, recording, systematization, accumulation, storage, change (update, modification), extraction, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.3. The owner and administrator of personal data processed by the software of the Site and/or Mobile application (hereinafter - the personal data) is Interactive Group FZC, address: Office number 424, Fourth floor, One UAQ Building, Umm Al Quwain, United Arab Emirates, P.O. Box 7073, company license number № 1761.
1.4. The Company performs processing of information about users, including their personal data, in order to fulfill the Company's obligations to users regarding the use of the Site and/or Mobile аpplication.
1.5. Location of personal data: to ensure safety of personal data, the Company uses cloud services of Amazon Web Services Inc.. Data stored by Amazon Web Services Inc. are kept at data processing centers in the United States, and Amazon Web Services Inc. affiliated companies located throughout the world.
The personal data includes information about:
- last name, first name and patronymic;
- date of birth;
- sign of sex;
- mobile phone number;
- health status;
- photo of the person.
1.6. The processing of personal data means any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, renewal, use and distribution (distribution, sale, transfer), depersonalization, destruction of personal data carried out by the Site and/or Mobile application.
1.7. The purpose of processing personal data is providing access to the Site and/or Mobile Application.
1.8. The personal data of Users may be transferred to third parties-contractors of the Company.
1.9. In Ukraine the user's personal data may be transferred to the third party-contractors of the Company, in particular, providers of LLC «Technology for people», EAC "Center of social business".
1.10. The transfer of the user's personal data to third party- contractors may be carried out by the Company with the condition that such contractors take obligations to ensure the confidentiality of the information received.
1.11. The User has the right to revoke his consent at any time. Withdrawal of consent does not affect the legality of the processing that was based on the consent prior to its withdrawal.
1.12. The User shall have the right to obtain from the Company the erasure of personal data concerning him or her without undue delay (Right to erasure («right to be forgotten»)) and the Company shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(а) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) The User withdraws consent on which the processing and where there is no other legal ground for the processing;
(c) The User objects to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing;
(d) the personal data have been unlawfully processed;
Where the Company has made the personal data public and is obliged to erase the personal data, the Company , taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform third parties-contractors of the Company which are processing the personal data that the data subject has requested the erasure by such third parties of any links to, or copy or replication of, those personal data.
1.13. Paragraphs 1.12. shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by State law to which the Company is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Company;
(c) for reasons of public interest in the area of public health;
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise or defence of legal claims.
1.14. The User has the right to obtain from the Company restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by the User, for a period enabling the Company to verify the accuracy of the personal data;
(b) the processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead;
(c) the Company no longer needs the personal data for the purposes of the processing, but they are required by the User for the establishment, exercise or defence of legal claims;
(d) the User has objected to processing pending the verification whether the legitimate grounds of the Company override those of the data subject.
1.15. Where processing has been restricted under paragraph 1.14., such personal data shall, with the exception of storage, only be processed with the User’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
1.16. A User who has obtained restriction of processing pursuant to paragraph 1.14. shall be informed by the Сompany before the restriction of processing is lifted.
2.1. The personal information in this Policy means:
2.1.1. Information provided by user himself, including personal user information.
Such data can be provided both when a user logs on to the Site and / or in Mobile Application, or in his subsequent actions.
2.1.2. Information provided by users additionally at the request of the Company, during the provision of the Site and / or in Mobile Application.
The Company has the right, in particular, to request from the User a copy of the identity document or other document containing the User's name, surname, photo, as well as other additional information which, at the Company's decision, will be necessary and sufficient to identify such User and will allow Abuse and violation of the rights of third parties.
2.2. Data that is transmitted in automatic mode:
- IP address;
- browser type, add-ons, query time;
- the location of the user, his actions, etc.
Such information is depersonalized, and therefore does not refer to the composition of personal data.
3.1. The Company carries out personal data processing of users for the purposes of providing them access to the Site and / or Mobile application. The Company may transfer depersonalized data to any users or partners, including publishers, advertisers and related sites with the aim of carrying out marketing, statistics and so on researches based on the depersonalized data.
3.2. User’s Personal data is stored exclusively in electronic media and processed using automated systems, except when manual processing of personal data is necessary in connection with the implementation of legal requirements.
3.3. User’s Personal data is not transferred to any third parties, except for the cases specifically provided in this Policy.
The transfer of the user's personal data to third party is carried out by the Company with the condition that such contractors take obligations to ensure the confidentiality of the information received.
3.4. In order to execute contracts / offers between the User and the Company and provide the User with access to use the functionality of the Site and Mobile applications, the Company develops the provided services and products, creates and introduces new services and products, optimizes the quality of services and products, improves the available functions of the Website and Mobile Applications.
To ensure the implementation of these objectives, the User agrees to the collection, storage, accumulation, systematization, extraction, comparison, use, filling (clarification) of their data, as well as to receive and transfer to the affiliated parties and partners the results of the automated processing of such data with the use of various information evaluation models, in the form of integer and / or text values and identifiers corresponding to the estimated criteria specified in the inquiries, for processing data by the Company and / or persons specified in this paragraph.
4.1. Providing Services for the use of the Site and / or access to the Mobile Application (hereinafter - Services), the Company, acting reasonably and in good faith, believes that the User:
- has all the necessary rights to enable him to register and use this Site and / or Mobile Applications;
- indicates reliable information about yourself in the amounts necessary for using the Site and / or gain access to the Mobile Applications;
- acquainted with these Rules, expresses its agreement with them and assumes the rights and duties indicated.
4.2. The Company does not verify the reliability of the received (collected) information about users, except for cases when such verification is necessary in order to fulfill the obligations to the user and third parties.
4.3. User has the right to make, change and edit his data at any time.
5.1. The Company do not disclose the personal information of Users to companies, organizations and individuals, not related to the Company by legal or contractual relations, with the regulation of the provision on confidential information. The exceptions are the cases listed below.
5.1.1. The user has given his consent. The Сompany can provide user information with companies, organizations or individuals not connected with the Company legally if the user has given consent to it. Consent to disclosure of personal data is confirmed by the User at the time of registration on the Site and / or download the Mobile application.
5.1.2. Personal data may be disclosed in cases provided for by applicable law.
5.2. The Company takes all necessary measures to minimize the risk and prevent unauthorized attempts to access, use, distort, disclose or destroy data stored by the Company.
6.1. The User has the right to:
6.1.1. know the source collection, the location of their personal data, the purpose of processing, location or residence (stay) or the holder of a personal data or give an instruction to obtain this information, authorized persons, except in cases established by law;
6.1.2. get information about the terms of access to personal data, including information about the third party to whom his personal data is transferred;
6.1.3. access to their personal data;
6.1.4. receive not later than thirty days from the date of receipt of the request, except as provided by law, the answer to whether his personal data are processed and receive the contents of such personal data;
6.1.5. make a reasoned request to the owner of personal data with an objection to the processing of their personal data;
6.1.6. make a reasoned request to change or destroy their personal data by any owner and controller of personal data, if this data is processed illegally or is inaccurate;
6.1.7. to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, non-provision or late provision, as well as to protect against the provision of information that is inaccurate or discredits the honor, dignity and business reputation an individual;
6.1.8. to make complaints to the processing of their personal data to authorized persons;
6.1.9. apply legal remedies in case of violation of the legislation on personal data protection;
6.1.10. make reservations regarding the restriction of the right to the processing of their personal data during the granting of consent (if such consent is given);
6.1.11. withdraw consent to the processing of personal data (if such consent was given);
6.1.12. know the mechanism of automatic processing of personal data;
6.1.13 protection against automated solution that has legal consequences for him.