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1. Definition of concepts
1.1. "Law" means the Law of Ukraine "On Personal Data Protection" with all amendments and additions.
1.2. "Site" means an information unit on the Internet, a resource of web pages (documents) that are united by a common theme and linked to each other by means of links. The site is registered to the Rightholder and must be linked to a specific domain, which is the address of the Site. This Policy is designed for the following website: https://improveme.tech/.
1.3. "Personal data" means the set of personal data and/or non-personalized information about the User, provided to the Rightholder as a result of the User's use of the Site and/or automatically collected by the Rightholder and/or third parties.
1.4. "Policy" means this Privacy and Personal Data Protection Policy for the Site (with all available additions and changes).
1.5. "User" means a legal entity or individual who uses the Site and/or accesses it from any device.
1.6. "User agreement" means the agreement concluded between the Rightholder and the User regarding the order, rules and features of using the Site. The User joins such agreement and has no right to introduce and/or demand introduction of any changes or additions to such Agreement.
1.7. "Rightholder" means the person in whose name the Site is registered, namely the individual entrepreneur Roman Oleksandrovych Totskyi, RNOKPP 3539603498, registration address: Ukraine, 03115, Kyiv, str. Feodory Pushina (Oresta Vaskula), bldg. 23, sq. 12.
2. Relationships covered by the Policy
2.1. This Policy is used and applies exclusively to Personal data received from the User in connection with his use of the Site. The provisions of this Policy are aimed at:
• determination of types and types of received Personal data, directions and purposes of use (processing) of Personal data, as well as sources of obtaining such Personal data;
• determination of the User's rights regarding the protection of the confidentiality of the Personal data provided by the User;
• identification of persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).
2.2. The rules of this Policy do not apply in case of processing by third parties of Personal data voluntarily provided by the User.
2.3. By using the Site, the User:
• agrees to the terms of this Policy and gives its consent to the Rightholder to collect, process, maintain and store Personal Data in the manner and under the conditions stipulated by this Policy;
• gives consent to the Rightholder's use of cookies in accordance with the terms of this policy at the first visit to the Site, which will allow the Rightholder to use cookies every time the User visits the Site.
2.4. If the User does not agree with the terms of this Policy and/or individual terms of this Policy, in this case the User is obliged to immediately stop using the Site.
2.5. In connection with the provision of Personal Data, the User automatically receives the following rights:
• receive data on the processing of Personal Data (grounds and purposes of such processing, applied methods of processing, information about persons who have access to them or to whom they may be disclosed on the basis of a contract or the Law);
• to receive data on the location or place of residence (residence) of the owner of the Personal Data, namely - the Rightholder who processes the Personal Data;
• receive data on the period of storage of personal data;
• receive data on the completed or anticipated cross-border transfer of Personal Data;
• appeal the actions or inaction of the Rightholder to the authorized body for the protection of the rights of the subjects of personal data or in court;
• exercise other rights in the area of Personal Data protection provided by the Law, other applicable legal acts or provisions of this Policy.
3. List of Personal Data collected
3.1. In connection with the use of the Site, the Rightholder may automatically collect and process the following non-personalized information about the User:
· information about the User's computer, including IP address, geographic location, browser type and version, as well as operating system;
· information about the User's visit and use of this Site, including the source of links, duration of visit, page views and ways of navigating the Site;
· information regarding the e-mail address that the User enters when registering on the Site, as well as for setting up subscription to e-mails and/or newsletters from the Site;
· information entered by the User when using services on the Site;
· information generated when using the Site, including when, how often and under what circumstances the User uses the Site;
· information related to everything that the User buys by switching to the platforms of the Rightholder's partners, using the services of the Site;
· information about the services used by the User;
· information that the User places on the Site with the intention of publishing on the Internet, and which includes the User's name, profile photos and the content of messages;
· information contained in any messages that the User sends by e-mail or through the Site, including content and metadata;
· any other personal information provided by the User.
3.2. The User provides the Rightholder with the following personal (personal) data:
· full surname, first name and patronymic;
· date of birth, age and gender;
· email address;
· mobile phone number;
· profile pictures;
· interests and hobbies;
· information about education and employment;
· data and information obtained as a result of combining certain Personal Data of a specific User, as well as data and information obtained from third parties (partners, marketers, researchers).
3.3. The user is the only person responsible for the completeness of the personal data provided, and is obliged to change them in a timely manner (update, check, correct) on a regular basis.
3.4. The Rightholder assumes that all Personal Data provided by the User are reliable and that the User maintains such information in an up-to-date state.
3.5. Before disclosing the Personal Data of a third party to the Rightholder, the User undertakes to obtain consent from such a person both for the disclosure and for the processing of such Personal Data in accordance with this Policy.
4. Purposes of collecting and processing Personal Data
4.1. Personal data provided to the Rightholder through the Site will be used for the purposes specified in this Policy or on the relevant pages of the Site. The right holder may use the User's Personal Data for the following purposes:
· administration of the Site and business;
· personalization of the Site for the User;
· providing the User with the opportunity to use the services available on the Site;
· supply of services used through the Site;
· sending the User other offers and news;
· sending e-mail messages that the User has specifically requested;
· informational mailing by e-mail, if the User has given his consent to it (at the same time, the User has the right to refuse the mailing at any time);
· sending the User marketing messages concerning the business of the Right Holder and/or the business of carefully selected third parties, which, in the opinion of the Right Holder, may be of interest to the User, by e-mail or similar technology (the User can notify the Right Holder at any time, if the User has more no marketing messages required);
· provision of statistical information about Users to third parties;
· dealing with requests and/or complaints submitted by the User and/or about the User relating to our Site;
· ensuring the security of the Site and preventing fraud;
· verification of compliance with the provisions and conditions governing the use of the Site for another purpose;
· to analyze the User's behavior, as well as identify the User's preferences for a certain type of content;
· for prompt and correct operation of the Site, improvement of its functionality and content;
· to identify the User;
· to comply with the requirements of the Law;
· for technical support of the Site, identification of problems in its operation and their elimination;
· for any other purposes, subject to separate consent from the User.
4.2. The processing of Personal Data consists of the following basic principles:
· legality of purposes and methods of processing;
· conscientiousness;
· conformity of the purposes of Personal Data processing to the purposes previously determined and declared when collecting such Personal Data;
· compliance of the volume and nature of the processed Personal data with the declared purposes of their processing.
4.3. Personal data is processed in the following cases:
· obtaining consent from the User;
· achievement by the Rightholder of the goals stipulated by the international agreement, the norms of the current legislation of Ukraine or the Law;
· provision by the User of his Personal Data to an unlimited number of persons;
· fulfillment of other obligations of the Rightholder to the User, including, but not limited to, provision of certain services and content to the User;
4.4. Privacy settings can be used to limit the publication of User information on the Site and can be adjusted using the privacy controls on the Site.
4.5. The Rightholder, without the User's express consent, has no right to provide the User's Personal Data to any third party for the purposes of such third party's direct marketing.
4.6. In case of depersonalization of Personal data, which does not allow directly or indirectly to identify the User, further use and disclosure of such Personal data to third parties is allowed and the rules of this Policy do not apply to such persons.
4.7. The Rightholder takes all possible measures to protect the confidentiality of the received Personal Data, except when the User has made such data publicly available.
4.8. Processing of Personal Data is carried out with the use of automation tools and without the use of such automation tools.
5. Disclosure of Personal Data
5.1. The right holder has the right to disclose Personal Data to the following persons:
· to its affiliates, branches and representative offices, opened both on the territory of Ukraine and on the territory of other states;
· to the successors of the Rightholder, which arose as a result of its liquidation, reorganization or bankruptcy, and who received exclusive rights to own the Site;
· to third parties solely for the purpose of providing and/or receiving certain content by the User and/or access to such content; receiving the services of the Site;
· to the Rightholder's employees, officers, insurers, professional consultants, agents, suppliers and/or subcontractors as necessary for the purposes set out in this Policy;
· to third parties when the User has consented to the disclosure, transfer or processing of his Personal Data, as well as in other cases expressly provided for by the current legislation of Ukraine, the Law or this Policy.
5.2. The right holder has the right to disclose Personal Data:
· to the extent provided by the norms of the current legislation of Ukraine;
· in connection with any current or anticipated legal rights;
· for the purpose of establishing, exercising or protecting the legal rights of the Rightholder (including providing information to other persons for the purpose of fraud prevention);
· to a buyer (or potential buyer) of any business or asset sold (or planned to be sold) by the Rightholder;
· to any person who, in the reasonable opinion of the Rightholder, may apply to a court or other competent authority with a request for the disclosure of such Personal Data, if, in the reasonable opinion of the Rightholder, such court or authority may with sufficient probability order the disclosure of such Personal Data .
5.3. The right holder discloses Personal Data only if:
· is sure that third parties will comply with the terms of this Policy and will take the same measures to protect the privacy of Personal Data that the Right Owner takes directly,
· consent to such disclosure was previously expressed by the User and/or is permitted on the basis of current legislation and/or the Law.
6. International transfer of Personal Data
6.1. The information that the Rightholder collects may be stored, processed and transferred between any countries in the world in which the Rightholder operates for the purposes of using the information in accordance with this Policy.
6.2. Information collected by the Rightholder may be transferred to such countries that do not have Personal Data protection laws similar to those in force in the European Economic Area: the United States of America, Japan, China and India.
6.3. Personal data that the User publishes on the Site or provides for publication on the Site may be accessible via the Internet worldwide. The right holder cannot prevent the use and/or incorrect use of such Personal Data by third parties.
6.4. The User expressly agrees to the transfer of Personal Data and information described in this section of this Policy.
7. The procedure for submitting complaints and questions to the Rightholder
7.1. Each User has the right to express his objection to the Rightholder against the processing and storage of his Personal Data by sending such a request to email: email.improve.me@gmail.com.
7.2. If the User has questions related to the procedure for applying or using this Policy, the procedure and/or method of processing Personal Data, the User can ask such a question by sending it to email: email.improve.me@gmail.com.
7.3. The User has the right to change or delete Personal Data at any time by sending a special request to the Rightholder by email: email.improve.me@gmail.com.
7.4. The right holder has the right to refuse to change and/or delete Personal Data if such actions result in:
· to violation of the rules of this Policy;
· to violation of the current legislation of Ukraine and/or the Law;
· the nature of the Personal Data is evidence in any legal proceedings arising between the Rightholder and the User.
8. Terms and procedure for storing Personal Data
8.1. Personal data is stored independently by the Rightholder.
8.2. Storage is carried out for the entire period necessary to achieve the stated goals of Personal Data processing.
8.3. The right holder undertakes to destroy or anonymize such data immediately after achieving the goals of Personal Data processing.
8.4. Regardless of the provisions of this section, the Rightholder stores documents (including electronic documents) containing Personal Data:
· to the extent provided by the norms of the current legislation of Ukraine;
· if the Rightholder believes that the documents may be relevant to any current or future legal proceedings;
· in order to establish, exercise or protect the legal rights of the Rightholder (including providing information to others for the purpose of fraud prevention).
8.5. The use of the Site is intended for persons of any age, who gain access to it only under the condition of providing prior consent to the processing of Personal Data of such persons.
9. Procedure for protection of Personal Data
9.1. Protecting the confidentiality of Personal Data is a primary and important task for the Rightholder. The right holder complies with all necessary international standards, rules and recommendations for the protection of Personal Data.
9.2. The right holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure and/or unauthorized access to such Personal Data by third parties.
9.3. The User acknowledges that the transmission of information over the Internet is inherently dangerous, and the Rightholder cannot guarantee the security of data transmitted over the Internet.
9.4. The User is responsible for maintaining the confidentiality of the password that the User uses to access the Site; The copyright holder will not ask for a password (except in the case of entering the Site).
10. Cookies
10.1. The site uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server every time the browser requests a page from the server. Cookies can be "persistent" or "session": persistent cookies are stored by the web browser and remain valid until the set period of validity, if the User has not deleted them before the expiration of the period of validity; session cookies, on the other hand, expire at the end of the User's session when the web browser is closed. Cookies usually do not contain any information that identifies the User, but the User's Personal Data stored by the Rightholder may be linked to the information stored in the cookies and obtained from them.
10.2. The copyright holder uses both session and persistent cookies on the Site.
· Below are the names of the cookies that the Rightholder uses on the Site and the purposes for which they are used:
Ø The Rightholder uses Google Analytics, Facebook Pixel and Google Adwords on the Site to recognize the computer when the User visits the Site; track Users when such Users move through the Site; allow you to use the shopping cart using the Site; improve the usability of the Site; analyze the use of the Site; administer the Site; prevent fraud and increase the security of the Site; personalize the Site for each User; target advertisements that may be of particular interest to specific Users; describe the goals.
· Most browsers allow the User to refuse to accept cookies, for example:
Ø in Internet Explorer (version 10) the User can block cookies using the cookie override settings by clicking “Service”, “Browser Properties”, “Privacy” and then “Advanced Settings”;
Ø in Firefox (Version 24) User can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use settings for history” from the drop-down menu and unchecking “Accept cookies from sites”;
Ø in Chrome (Version 29) User can block all cookies by going to Settings and Controls and clicking on Settings, Show advanced settings and Content settings, then selecting Block sites from setting any data" under the heading "Cookies".
10.3. Blocking all cookies will negatively affect the usability of many sites. If the User blocks cookies, he will not be able to use all the functions of the Site.
10.4. The User can delete cookies already stored on the User's computer, for example:
· in Internet Explorer (version 10), it is necessary to manually delete cookies (instructions for this can be found on the page http://support.microsoft.com/kb/278835);
· in Firefox (version 24) User can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use settings for history”, clicking “Show cookies”, then “Delete all cookies” ;
· in Chrome (Version 29) User can delete all cookies by going to Settings and Controls and clicking on Settings, Show more settings and Clear Browsing data and then selecting Delete cookies and other data site and plugin” before clicking “Clear Browsing Data”.
11. Final Provisions
11.1. The Rightholder has the right to update this Policy at any time by publishing a new version on the Site. The User should periodically check this page to ensure that they understand the content of any changes to this Policy. The Rightholder may notify the User of changes to this Policy by e-mail or through the personal message system on the Site.
11.2. The site contains hyperlinks and information about third-party sites. The copyright holder does not control and is not responsible for the privacy policies and practices of third parties.
11.3. This revision of the Policy is effective from the moment of publication of such Policy on the Site.
11.4. This Policy may be changed unilaterally at the initiative of the Rightholder. The Rightholder bears no responsibility to the User for changing the terms of this Policy without the permission and/or consent of the User.
11.5. The user undertakes to regularly check the provisions of this Policy for possible changes and/or additions.
11.6. The User has the right to instruct the Rightholder to provide the User with any Personal Data that the Rightholder keeps about the User; the provision of such information depends on the following conditions:
· provision of relevant evidence regarding the identification of the User's identity (the Rightholder has the right to request a copy of the User's passport or ID card).
11.7. The Rightholder may hide Personal Data that the User requests to be hidden, within the limits allowed by the norms of the current legislation of Ukraine and/or the Law.
11.8. The User has the right at any time to instruct the Rightholder not to process the User's Personal Data for marketing purposes.
11.9. In practice, the User usually either expressly agrees that the Rightholder uses the User's Personal Data for marketing purposes, or the Rightholder gives the User the opportunity to refuse the use of such Personal Data for marketing purposes.
11.10. This Policy was developed in accordance with the norms of the current legislation of Ukraine on the protection of personal data.
11.11. Regardless of the measures taken by the Rightholder to protect the confidentiality of the received Personal Data, the User is considered duly informed that any transmission of Personal Data on the Internet cannot be guaranteed to be secure, and therefore the User carries out such transmission of Personal Data at his own risk.
