Personal data processing and privacy policy
This Policy on the processing of personal data and confidentiality (hereinafter referred to as the Policy) applies to all information that LLC "GREEN FISH PLANT" (hereinafter referred to as the Company) and/or its affiliates, including all persons belonging to the same group as LLC "GREEN FISH PLANT", may obtain about the user during his use of any of the sites, services, services, programs and products of LLC "GREEN FISH PLANT" during the process of registration, authorization and other use, as well as during the execution by LLC "GREEN FISH PLANT" and its affiliates of any agreements and contracts concluded with the user in connection with the use of the services. The User's consent to the processing of personal data and other information provided by him to the Company, expressed in accordance with the Policy, is considered to be simultaneously provided by the User to third parties specified in the Policy who are engaged by the Company to assist in the implementation of the User Agreement, the Membership Agreement, and the License Agreement.
Using the website electro.nd.ua (hereinafter referred to as the Site), the cloudpay Application (hereinafter referred to as the Application), the cloudpay Service (hereinafter referred to as the Service), in particular, the User's registration and authorization, means the User's unconditional consent to the Policy and all the conditions for processing his personal data and other information specified therein, namely to perform actions stipulated by the Law of Ukraine "On Personal Data Protection" both without and with the use of automation tools, and confirms that, by giving such consent, he acts freely, of his own free will and in his own interest; in case of disagreement with the Policy and all its conditions, the User must refrain from using the Site, Application, Service.
By using our Site, Service, Application and providing your consent to the use of personal data, you, in particular, give your consent to the recording of a conversation with an employee of the Company or a call center operator, to sending you via any communication channels, including: SMS notifications, push notifications, sending messages via WhatsApp, call, voice message, e-mail message, information, individual offers and advertising materials about products and services provided by the Company, related to the Site, Service, Application and the Company's business activities, including messages about existing or under development products and services of the Company and its partners. You acknowledge that you have read the terms of this Policy and agree to the processing of your personal data on the terms specified below. If you do not agree to these terms, please do not provide your personal data. You independently decide to provide us with your personal data through special interactive forms posted on the Site, Service and Application. You give your consent to the processing of personal data freely, of your own free will and in your own interest. By providing your consent and continuing to use the Site, you express your agreement that your consent to the processing of personal data is specific, informed and conscious. Consent is considered given if you tick the box in the interactive personal data collection form to confirm that you agree with this Policy.
Terms and definitions
The following terms are used in this Policy::
- Personal data — any information relating directly or indirectly to an identified or identifiable natural person (personal data subject).
- Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data
- Privacy of personal data — a requirement that must be observed by the Company or another person who has gained access to personal data, not to allow their dissemination without the consent of the personal data subject or the presence of another legal basis.
- User — a person who has access to the Site, Service, Application via the Internet. "Cookies" — a small piece of data sent by a web server and stored on the user's computer, which a web client or web browser sends to the web server in an HTTP request each time it tries to open a page of the corresponding site.
- IP address — a unique network address of a node in a computer network built using the IP protocol.
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Personal data and other information of the User received and processed by the Company
- During registration, authorization of the User, as well as during use of the Site, Application, Services, making payments, conducting surveys, sending informational and advertising messages and in all other cases provided for by the User Agreement, the Accession Agreement, the License Agreement, the Company may request from the User (clause 1.1.1. of the Policy) and/or automatically receive (clause 1.1.2. of the Policy) the following information about the User:
- surname, first name, patronymic, year, month, date and place of birth, gender, passport data, mobile phone number, email address, registration address/actual (postal) address, login and password information for access to individual functions of the Site, Application, Service, driver's license data, data on the presence (absence) of medical contraindications to the use of a vehicle, biometric data (photographs), data on the place of work, position, control information, history of using the Service (information on the number of visits to the Service).
- information that is automatically transmitted to the Company during the use of the Site, Application, Service, using the software installed on the User's device, in particular IP address, information about cookies and tracking bugs, information about the country and (or) city of the User's location, information about the User's Internet browser (or other program used to access the Site, Application, Service), access time, address of the requested page, about the User's devices used to access the Site.
- This Policy may be applied only to the Site, Application, Service. The Company does not control and is not responsible for third-party sites and software to which the User may access through links available on the Site, in the Application, in the Service. On other third-party sites, the User may be collected or requested to provide other information, and other actions may occur for which the Company is not responsible.
- The Company generally does not verify the accuracy of personal information provided by users and does not exercise control over their legal capacity. The Company assumes that the User is an adult capable person who meets the requirements of the User Agreement, the Accession Agreement, the License Agreement, provides reliable and sufficient information and keeps this information up to date. The risk of providing unreliable information is borne by the user who provided it.
- The Company has the right to verify the information provided by the User in accordance with the provisions of the User Agreement, the Membership Agreement, the License Agreement. In the event that the User provides inaccurate information, the Company has the right to suspend or cancel the registration and/or deny the User access to the Site, Application, Service. The Company and/or other third parties are not responsible for the provision of inaccurate information and the negative consequences arising from this. If the Site, Application, Service is used by a minor and/or incapacitated person, then the parents, adoptive parents and other legal representatives of the minor and/or incapacitated person are responsible for such unauthorized use by the Company.
- The user's consent to the processing of personal data is valid indefinitely from the moment of the user's registration on the site and/or the Service and/or the Application, and does not require periodic confirmation. The Company will store personal information for as long as necessary to achieve the purpose for which it was collected, or to comply with the requirements of current legislation and regulatory acts of Ukraine.
- During registration, authorization of the User, as well as during use of the Site, Application, Services, making payments, conducting surveys, sending informational and advertising messages and in all other cases provided for by the User Agreement, the Accession Agreement, the License Agreement, the Company may request from the User (clause 1.1.1. of the Policy) and/or automatically receive (clause 1.1.2. of the Policy) the following information about the User:
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Purposes of collecting and processing users' personal information
- The Company collects, processes and stores only those personal data that are necessary to provide the Service and provide services (fulfillment of agreements and contracts with the user), in strict accordance with applicable law.
- The Company uses the User's personal data and other information for the purposes of concluding and executing the User Agreement, concluding and executing the Membership Agreement, the License Agreement, providing additional services, improving the quality of the service, the User's participation in promotions, surveys, research conducted by the Company (including, but not limited to, conducting surveys, research via electronic, telephone and mobile communication), making decisions or taking other actions that give rise to legal consequences. The specified purposes of using personal data apply to all information specified in clause 1.1 of the Policy.
- The purposes of collecting and processing personal data include, without limitation, the following: registration, identification and authorization of the User within the Service; conclusion and execution of the User Agreement, the Accession Agreement, the License Agreement; provision of the Service to the User, as well as any additional functionality within the Service; processing of User requests by the Company within the Service; analysis and research of opportunities to improve the Service; sending news and information about products, services, special offers; provision of services to the User.
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Terms of processing of user personal information
- The User's personal information remains confidential, except in cases where the User voluntarily provides information about himself/herself for general access to an unlimited number of persons.
- The Company uses the User's personal data and other information only for the purposes specified in the Policy and in accordance with the Policy.
- The Company will not disclose to third parties, distribute, sell or otherwise dispose of the personal data and other information received, except for the purposes, in the manner and within the limits provided for in this Policy.
- The processing of the User's personal and other data is carried out by the Company to the extent necessary to achieve each of the purposes specified in Section 2 of the Policy, in the following possible ways: collection, recording (in particular, on electronic media), systematization, accumulation, storage, compilation of lists, marking, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction, cross-border transfer of personal data, obtaining an image of personal data, obtaining information about them, as well as other ways that can be used for their use. The Company has the right to process the User's personal and other data both with the use of automated means of processing the User's personal data and without the use of automation means.
- The Company has the right to transfer personal data provided to it by the User for processing (to give instructions for processing) (to the extent necessary for the Company to fulfill its obligations) to third parties, in particular, to organizations involved by the Company to send information messages via e-mail / mobile operators, debit / credit funds from / to bank card (s) / current account — credit organizations (banks), payment systems, mobile operators, as well as other organizations.
- The Company also has the right to transfer personal data provided to it by the User to state authorities, courts, other authorized bodies and organizations, in cases and in the manner required by the law applicable to the Policy.
- The Company guarantees the fair and lawful processing of the User's personal and other data in accordance with the purposes set out in Section 2 of the Policy.
- The Company guarantees immediate updating of the User's data if the User provides updated data.
- Consent to the processing of personal data and other data is provided by the User on an indefinite basis, or until the expiration of the storage periods of the relevant information or documents containing the above information, which are determined in accordance with the law applicable to the Policy. After the expiration of the specified period, personal data is subject to destruction by the Company.
- The Company processes personal data based on the following principles: lawfulness and fair basis; limitation of personal data processing to achieving specific, predetermined and legitimate purposes; prevention of processing of personal data incompatible with the purposes of collecting personal data; prevention of combining databases containing personal data processed for purposes incompatible with each other; processing only those personal data that meet the purposes of their processing; compliance with the requirements of the law and the law; ensuring the security of personal data.
- Ensuring the security of personal data.
- The security of personal data processed by the Company is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of the current legislation of Ukraine in the field of personal data protection. To prevent unauthorized access to personal data, the Company applies the following organizational and technical measures: appointment of officials responsible for organizing the processing and protection of personal data; limitation of the number of persons who have access to personal data; familiarization of subjects with the requirements of the current legislation of Ukraine and the Company's regulatory documents on the processing and protection of personal data; organization of accounting, storage and handling of information carriers; identification of threats to the security of personal data during their processing, formation of threat models based on them, in particular during automated data processing; development of a personal data protection system based on the threat model, in particular during automated data processing; verification of the readiness and effectiveness of the use of information protection tools, in particular during automated data processing; delimitation of user access to information resources, personalization and accounting of access of the Company's employees to software and hardware means of information processing; registration and accounting of actions of users who carry out automated data processing; registration and accounting of actions of users of personal data information systems; use of anti-virus tools and means of restoring the personal data protection system; use, where necessary, of firewalls, intrusion detection, security analysis and cryptographic information protection tools; organization of access control to the Company's territory, security of premises with technical means of personal data processing.
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User changes personal information
- The User may at any time change (update, supplement) the personal data and other information provided by him/her by contacting the Company, for example, through the support service or using the contacts specified on the Site, in the Appendix, with a request to change (update, supplement) the information provided by him/her earlier (the Company changes (updates, supplements) the information provided by the User only after carrying out the User identification procedure applied by the Company at the time of the relevant request).
- The User has the right to withdraw his/her consent to the processing of personal data by sending a relevant written notice to the Company no less than 30 (thirty calendar) days prior to the withdrawal of consent, while the User acknowledges and understands that access to the Site and Application Services, the Service will not be provided by the Company from the moment the Company loses the ability to process the User's personal data.
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Measures taken to protect users' personal information
- The Company takes necessary and sufficient organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, distortion, blocking, copying, distribution, as well as from other illegal actions with it by third parties.
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Use of cookies
- To improve the quality of the Service, the Company may use (temporary and permanent) cookies, tracking bugs and/or other technologies for collecting data that are not of a personal nature (for example, IP address, browser type and data about the Internet service provider (ISP), as well as (for Users who use the Company's services via a mobile device), a unique device identifier, operating system data and coordinates in order to take into account the number of Users and their behavior while using the Service. To improve the convenience of Users, the Company has the right to collect and process information about the total number of operations, pages viewed by the User, referring/exit pages, platform type, date/time of recording of information, number and location of views of this page, page views and used (search) words.
- The Company may use cookies and tracking bugs to monitor the use of the Service, collect non-personal information about the User, store preferences and other information on the User's device in order to save the User's time required to repeatedly enter the same information into the forms of the Site, Application, as well as to display content during subsequent visits by the User to the Site, Application. Information obtained using cookies and tracking bugs may also be used by the Company for statistical research aimed at adjusting the content of the Site, Application in accordance with the User's preferences.
- The Company may provide the User with the opportunity to change the settings for accepting cookies and tracking bugs in their browser settings or disable them completely, however, in this case, some features of the Service may not work correctly.
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Change of Privacy Policy. Applicable Law
- The Company has the right, at its sole discretion, to change and (or) supplement the Policy at any time without prior and (or) further notice to the User to make changes to this Policy. When making changes, the current version indicates the date of the last update. The current version of the Policy is always available on the Site, Service or Application.
- The User's continued use of the Service, Application, Site after any changes and/or additions to the Policy constitutes his/her agreement with such changes and/or additions.
- The User undertakes to regularly review the content of the Policy in order to be informed of its changes/amendments in a timely manner.
- This Policy and the relations between the user and the Company arising in connection with the application of the Policy are subject to the substantive and procedural law of Ukraine.
- The Policy has been developed in accordance with the provisions of the Law of Ukraine "On Personal Data Protection", as well as other regulatory legal acts of Ukraine that establish requirements for the processing of personal data. If any obligation or any rights, conditions, principles of processing are not mentioned in the Policy, they are determined in accordance with the current legislation of Ukraine.
- In the event of loss or disclosure of Confidential Information, the Site Administration is not responsible if this confidential information:
- Became public domain until lost or disclosed.
- Was received from a third party before it was received by the Site Administration.
- It was disclosed with the consent of the User.
- Before filing a lawsuit in disputes arising from the relationship between the User and the Company, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute).
- The recipient of the claim shall, within 30 calendar days from the date of receipt of the claim, notify the claimant in writing of the results of the claim review.
- If an agreement is not reached, the dispute will be referred to a judicial body for consideration in accordance with the current legislation of Ukraine.