2. Who processes the information?
In order to ensure your use of the Websites and Services, your Personal Information is collected and used by the Company.
The Company may process customer personal information on behalf of the user or by the user on behalf of the Company, depending on the party that initially provided such information.
If customer personal information is initially provided by the user, the user must ensure that there are legal grounds for the Company to process such information in accordance with the user's instructions. This may include obtaining the customer's consent for the processing of their Personal Information by third parties, if applicable.
The Policy serves as the sole document that outlines the mutual instructions between the Company and users, and is sufficient to establish the legal consequences arising from the conclusion of a personal information processing agreement.
The entity processing Personal Information based on instructions must comply with all applicable data security requirements during the processing, including the provisions of this Policy.
Only the Personal Information processed in accordance with the provisions outlined in this Policy, using the methods specified herein, and for the purposes stated in this Policy, shall be subject to processing in order to fulfill the specified objectives.
3. What is the purpose of this Policy?
Protecting your Personal Information and confidentiality is of utmost importance to the Company. Therefore, when you use the Websites and Services, the Company safeguards and processes your Personal Information in strict compliance with applicable laws.
To fulfill our obligation of protecting your Personal Information, this Policy aims to transparently inform you about the following:
(a) why and how the Company collects and uses ("processes") your Personal Information when you use the Websites and/or Services;
(b) the role and responsibilities of the Company as a legal entity that determines the purpose and methods of processing your Personal Information;
(c) the tools available to you for reducing the amount of Personal Information collected by the Company about you;
(d) your rights in the context of the processing of Personal Information.
The Company may collect the following categories of Personal Information about you during your use of the Websites and Services:
(i) Personal Information provided by you during registration (account creation), such as your name, phone number, address, and age;
(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser identifier information, hardware and software information);
(iii) date and time of access to the Websites and/or Services;
(iv) information about your activity during the use of the Websites and/or Services (e.g., search history, email addresses of correspondents, email content and attachments, and files stored in the Company's systems);
(v) geolocation information;
(vi) other information about you necessary for processing in accordance with the terms governing the use of specific Websites or Services of the Company;
The Company does not intentionally collect sensitive personal information (such as racial or ethnic origin, political views, health information, and biometric data) unless specified in the user agreements of specific Services. However, you may voluntarily provide such information to the Company, and in such cases, the Company will process it in the provision of Services to you (e.g., if you submit health-related search queries). Please note that the Company cannot request your consent for such processing in advance, as it is not aware of the potentially sensitive nature of the Personal Information you may provide.
The Company does not collect data for the purpose of creating a user "profile" to an extent that would substantially affect your rights and freedoms under applicable law.
5. What is the legal basis and purpose of processing your Personal Information?
The company is not authorized to process your Personal Information without sufficient legal grounds. Therefore, the company processes your Personal Information only in the following cases:
(i) Processing is necessary for the performance of contractual obligations of the company to you, including the provision of website and service functionality (e.g., providing search results based on your search queries).
(ii) Processing is necessary to comply with legal obligations imposed by applicable laws.
(iii) When permitted by applicable law, processing is necessary to pursue the legitimate interests of the company, provided that such processing does not unduly affect your interests, fundamental rights, and freedoms. Please note that when processing your personal information on this basis, the company will always strive to maintain a balance between its legitimate interests and the protection of your privacy.
The company processes your Personal Information to pursue its legitimate interests, including but not limited to the following:
(a) To better understand how you interact with our websites and services.
(b) To improve, modify, personalize, or otherwise enhance the websites and services for the benefit of all users.
(c) To offer you other products and services from the company or other companies that we believe may be of interest to you.
(iv) For specific purposes or as required by applicable law, we may seek your separate consent for the processing of your Personal Information. In jurisdictions where consent is recognized as a separate legal basis, your use of the websites and/or services indicates your consent to such processing. We hereby inform you, and you acknowledge, that you are under no obligation to provide us with any Personal Information when using the websites or services, and it is entirely voluntary on your part. However, you understand that without providing Personal Information, we may not be able to provide you with access to the services, and your use of the websites will be limited.
The company always processes your Personal Information for specific purposes and only the Personal Information that is relevant to achieving those purposes. In particular, we process your Personal Information for the following purposes:
(i) Providing you with access to the websites and/or services (including providing search results based on your search queries, taking into account your preferences, search history, and other Personal Information available to the company).
(ii) Providing access to your user account, including the company's email and file storage if you are registered for the respective services.
(iii) Communicating with you to send you notifications, inquiries, and information related to the operation of the websites and services, the fulfillment of agreements with you, and the processing of your requests.
(iv) Personalizing offers based on your preferences, search history, and other Personal Information available to the company.
(v) Improving the usability of the websites and services, including showing the most relevant search results and providing more personalized websites and services, as well as enhancing other products, applications, and services of the company.
(vi) Creating new products, utilities, and offerings of the company.
(vii) Protecting your rights and the rights of the company.
(viii) Collecting, processing, and presenting statistical data, big data, and other research.
The company only shares Personal Information to the extent necessary to achieve the stated purposes of processing, within the scope permitted and/or specified for the sharing of Personal Information.
6. How the Company protects your Personal Information
In most cases, Personal Information is processed automatically without access by any of the company's employees. If access is required, it is only granted to those employees who need it to perform their tasks. To protect and ensure the confidentiality of data, all employees must comply with internal rules and procedures regarding the processing of Personal Information. They must also adhere to all technical and organizational security measures in place to protect your Personal Information.
The company has implemented adequate technical and organizational measures to protect Personal Information from unauthorized, accidental, or unlawful destruction, loss, alteration, misuse, disclosure, or access, as well as other unlawful forms of processing. These security measures have been implemented taking into account the current level of technology, the cost of implementation, the risks associated with processing, and the nature of the Personal Information.
7. Who else has access to your Personal Information and to whom it may be disclosed
The company may also disclose Personal Information to third parties not belonging to the Company Group to achieve the purposes specified in Section 5 of this Policy. Please note that the level of protection of Personal Information in some countries may not be the same as the level established in your jurisdiction, and by using the Company's Services, you agree to such transfer.
Such third parties may include:
(i) Partners, such as website and application owners, advertising networks, and other partners providing services to the Company related to the placement and display of advertisements on websites, programs, products, or services owned or controlled by such partners, as well as services related to the collection of information about the use of the Company's Sites and Services (metric program operators);
(ii) Advertisers or other Partners who display advertisements to you on the Company's Sites and/or Services, as well as Partners such as information service providers or consultants.
The company may also disclose Personal Information to third parties not belonging to the Company Group:
(i) Third parties in relation to whom a transfer of rights or obligations or novation has been made under the respective agreement;
(ii) Any national and/or international regulatory authority, law enforcement agencies, central or local executive authorities, other official or governmental bodies, or courts to which the Company is obliged to provide information in accordance with applicable law upon the respective request;
(iii) Third parties, in case you have given your consent to the transfer of your Personal Information, or the transfer of Personal Information is necessary for the provision of the corresponding Service to you or the performance of a specific agreement or contract concluded with you.
The company warns that in some cases, the Sites and Services may contain links to third-party forms for collecting Personal Information and recommends that, in such cases, you ensure that the person to whom you are providing Personal Information through the completion of a third-party form complies with applicable legislation on the processing and security of Personal Information during processing.
8. How long do we keep your Personal Information
The company will keep your Personal Information for as long as necessary to achieve the purpose for which it was collected or to comply with legal requirements and regulations.
Unless required by law or agreement with you, emails and documents that you store in the Company's systems as part of the Service will be stored as long as you have an account, but you may delete them at any time.
If you want any of your Personal Information to be deleted from the company's databases, you can independently delete the necessary Personal Information using your account or through the interface of the Sites and/or Services (where applicable).
Deleting your Personal Information by you will result in its destruction by the Company, provided that there are no other sources of deleted Personal Information in its possession, in addition to the Sites and/or Services.
The documentation of the destruction of Personal Information is carried out in accordance with applicable legislation.
9. Your Rights
9.1 What rights do you have
If provided by applicable law, you have the right to access your Personal Information processed by the Company in accordance with this Policy.
If you believe that any information the Company holds about you is incorrect or incomplete, you may log into your account and correct your Personal Information yourself.
If provided by applicable law, you have the right to:
Request the deletion of your Personal Information or its part, as well as withdraw your consent to the processing of your personal information;
Request restrictions on the processing of your Personal Information;
Object to the processing of your Personal Information if provided by applicable law.
The Company will fulfill these requests in accordance with applicable law.
In cases provided by applicable law, you may also have other rights not specified above.
9.2 How you can exercise your rights
To exercise the above rights, please log into your account, and if there is no specific function in the interface, contact the Company (see Section 13 of this Policy).
If you are not satisfied with how the Company processes your Personal Information, please let us know, and we will consider your claim. If you are not satisfied with the Company's response, you have the right to lodge a complaint with the competent authority.
10.1 What are cookies and how does the Company use them
Cookies are small text files placed on the device you use to access the Websites. They contain information that is collected from your device and sent back to the Websites each time you visit them to remember your actions and preferences over time.
The following types of cookies are used on the Websites:
Strictly necessary cookies / technical cookies: These cookies are necessary for the operation of the Websites and to provide you with the Services. Among other things, they allow the Company to identify your hardware and software, including your browser type.
Statistical / analytical cookies: These cookies allow the recognition of users, counting their number, and collecting information such as your actions on the Websites and in the Services, including information about visited web pages and the content you receive.
Technical cookies: These cookies gather information about how users interact with the Websites and/or Services, allowing the detection of errors and testing new features to improve the performance of the Websites and Services.
Functional cookies: These cookies enable certain features to facilitate your use of the Websites, such as saving your preferences (such as language and location).
Third-party tracking cookies: These cookies collect information about users, traffic sources, visited pages and posts displayed to you, as well as the one you clicked to reach a post. They allow displaying posts that may be of interest to you based on the analysis of Personal Information collected about you. They are also used for statistical and research purposes.
The Company uses the information contained in cookies only for the purposes mentioned above, after which the collected data will be stored on your device for a period that may depend on the respective type of cookies but will not exceed the time necessary to achieve their purpose, after which they will be automatically deleted from your system.
10.3 Who else has access to the information contained in cookies
Personal Information collected through cookies placed on your device may be transmitted to and accessed by the Company and/or third parties specified in Section 7 of this Policy. The use of Personal Information outside the Websites for marketing purposes, if applicable, may be subject to separate user agreements available on third-party websites. The Company and/or third parties may also provide you with the option to opt out of personalized posts, which may be subject to the regulations and rules applicable to such products and offers.
The Company may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:
(i) Identifying your actions on the Websites and during the use of the Services by accessing and using cookies stored on your device.
(ii) Collecting statistical information related to the operation of the Websites, Services, or the Company's products, utilities, and offers.
11. Age Restrictions
Our websites and services are not intended for individuals under the age of 18 (hereinafter referred to as "Children").
We do not knowingly collect personal information from children under the age of 18. If you are a parent or guardian and you know that your children have provided us with personal information, please contact us. If we become aware that we have collected Personal Information from children under the age of 18 without parental consent, we take steps to remove this information from our servers or replace it with the Personal Information of the parent or guardian of the Children.
12. Updating this Policy
This Policy may be updated. The company reserves the right to make changes at its discretion, including but not limited to cases where the relevant changes are related to changes in applicable legislation, as well as when the relevant changes are related to changes in the operation of the websites and services.
The company undertakes not to make significant changes, impose additional burdens, or restrict your rights established by this Policy without notifying you. You will be notified of such changes. Corresponding notifications may be displayed on the website or in the services (e.g., through a pop-up window or banner) before such changes take effect or may be sent to you through other communication channels (e.g., email if you have provided us with your contact information).
13. Questions and Suggestions
The company welcomes your questions and suggestions regarding the implementation or amendment of this Policy. Please send a letter to: email@example.com. You can also use this address to submit requests regarding the exercise of your rights or complaints regarding the accuracy of your Personal Information or the legality of its processing.