PRIVACY POLICY AND CONSENT FOR PERSONAL DATA PROCESSING

REVISED ON: 26.03.2019
§1. General provisions

1.1. These Confidentiality Provisions (hereinafter the “Confidentiality Policy”) are applied and valid as to the full information about the User which the Company may obtain when using Mobile Application, and other features, programs, products or services of the Company.

§2. Consent for personal data management

By downloading, registering and starting using Mobile Application you, as a User, provide free and informed consent for your personal data collection, processing, storage and use, and confirm the following:
2.1. You fully, thoroughly and with diligence read and understood the content of the Confidentiality Policy.
2.2. Content of the Confidentiality Policy is quite clear to you. No further explanations as to any item are needed.
2.3. It is believed that the content of the Confidentiality Policy as a whole, and / or some of their provisions do not violate any of your rights and are not burdensome.

§ 3. ATTENTION!

3.1. You shall provide only true and complete information in Mobile Application and assume full legal liability for consequences of violation thereof. In particular, the Company reserves its right to block your Profile (Account) until relevant information clarification, or without obtaining any prior and / or subsequent consent to refuse you from further use of Mobile Application.
3.2. You shall be aware of any risks associated with your address or information disclosure about your exact location or other personal information. If you decide to use Mobile Application using third party operator authentication service, such as Facebook information, the Company may obtain additional information about the User, access to which will be provided by such third party.
3.3. When you contact the Company or post comments, you shall be fully liable for their content. Any complaints or claims can be also held against you, if your information or comments are recognized as illegal, harmful, threatening, slanderous, offensive to morality, infringing copyrights, promoting hate and / or discrimination against people for racial, ethnic, gender, religious or social reasons, contain insult against specific individuals or organizations, and in one way or another violate the current laws of Ukraine and / or international law.
3.4. Mobile Application may contain links to other persons` Internet resources for additional convenience when using services of the Company and for obtaining additional information by Users. If you use these links, you move to Internet resources to which this Confidentiality Policy of Mobile Application is not applied. In this case, you agree that:
3.4.1. The Company does not exercise any prior, current or further control over such third-party Internet resources and / or their privacy policy that may significantly differ from this Confidentiality Policy or be unavailable as a whole. Accordingly, you shall assume all and any risks associated with movement to other Internet resources, including information confidentiality.
3.4.2. This Confidentiality Policy is not applied to any personal data chosen to be provided to other parties, or which other persons may, without your consent or without your knowledge, take from your equipment.
3.4.3. The Company shall not monitor and control any information posted on the Internet resources of other persons, nor bear any responsibility for its content / nature, since it may only refer to a specific material which, according to it, discloses or complements information, posted in Mobile Application.
3.5. Information that is not defined as personal information, may be collected, used and disclosed by the Company for any purposes, since such information does not identify the Users.

§ 4. The list of information the Company can collect, obtain and use

4.1. Information required from the Seller for registration is specified in §4 of Mobile Application Terms and Conditions, namely:
4.1.1. Information identifying the User: name, registration and tax numbers, Certificate data (at least one Certificate is required), location (according to Certificate) and the form of ownership.
4.1.2. Information identifying authorized representatives: full name, contact phone number, email address.
4.1.3. Desired status of service participant: Seller.
4.1.4. The list of certificates the Seller has with number, date of issue, validity and expiry date.
4.1.5. List of goods to be offered for sale and indicated in the Certificate.
4.1.6. Scanned copies of the Extract from the Unified State Register of Legal Entities and Individual Entrepreneurs dated no later than 3 working days before the date of application submission for registration; powers of attorney or other documents authorizing the relevant person to be a representative of the company (if the authorized representatives are not the persons specified in the Extract from the Unified State Register of Legal Entities and Individual Entrepreneurs); Seller`s Certificates.
4.2. Information required from the Buyer for registration is specified in §5 of Mobile Application Terms and Conditions, namely:
4.2.1. Information identifying the User: name, registration and tax numbers, information about Certificate (if any), location (according to Certificate or statutory documents) and the form of ownership.
4.2.2. Information identifying authorized representatives: full name, contact phone number, email address.
4.2.3. Desired status of service participant: Buyer.
4.2.4. List of goods the Buyer is interested in.
4.2.5. List of Certificates (if any) the Buyer has with the number, date of issue, validity period and the date of expiry, and certification body.
4.2.6. Scanned copies of the Extract from the Unified State Register of Legal Entities and Individual Entrepreneurs dated no later than 3 working days before the date of application submission for registration. If the Buyer is a foreign legal entity, then scanned copy of the extract from the trade register or another document confirming its status as a legal entity of the Buyer; powers of attorney or other documents authorizing the relevant person to be a representative of the company (if the authorized representatives are not the persons specified in the Extract from the Unified State Register of Legal Entities and Individual Entrepreneurs); Buyer`s Certificates (if any).
4.3. Information required while Mobile Application downloading and use, namely: e-mail address and / or telephone number and password, other information provided by the Users during their registration. The Company may request from the User or obtain itself the following data independently while Mobile Application use: UDID/IMEI, type and version of the device operating system, device model, e-mail and phone number.
4.4. Information that the Company may obtained during enquiries, when the User may be offered to express its opinion on specific issues.
4.5. Information obtained using feedback forms on the User`s personal data (name, contact phone number, e-mail) and the User`s request for reply.
4.6. Information about User`s actions when using Mobile Application, for example, which orders were reviewed by the User and its personal preferences.

§ 5. Directions of information and data use

The Company reserves its right to use information obtained from the User (including personal data) at its own discretion and without obtaining any prior or subsequent consent from the User, in order to:
5.1. Identify the User when accessing Mobile Application.
5.2. Ensure the proper and effective use of Mobile Application, in particular to create and manage User`s Accounts.
5.3. Provide information about Mobile Application Terms and Conditions to the User.
5.4. Maintain, provide technical support and response to the User, and settle technical difficulties and access to various functions. Moreover, when the User contacts Support Desk, the Company may, if needed, collect personal information, during Mobile Application operation, required for request fulfilment submitted by the User and feedback receipt. The Company may also contact the User using current contact details from its Profile provided for this purpose. The Company may also collect other Users` communication information, for example, any requests to Support Desk provided by the Users, or any feedback provided by them.
5.5. Analysis made using statistical and other data to improve the quality of services provided; offers and experience adaptation, including advertisement on their services or services of the third parties; and to develop and offer new or additional services.
5.6. To place orders and facilitate contracts conclusion through Mobile Application. In particular, the Company may post information about its User, including personal data and its contact details, required to conclude agreements between the Users, as the buyers and the sellers, or to send notices and offers and to support communication between the Users, as well as to make payments.
5.7. Advertisement. The Company may collect personal data, such as name and contact details of the User, its participation in promotional and other marketing campaigns organized in Mobile Application or on third-party websites; information on advertising campaigns performance, including orders review in or out of Mobile Application; information as replies for questionnaires or other enquiries that may be conducted by the Company for marketing purposes. Such information may be processed, stored and used, in particular, for analytical purposes and in order to understand User`s interests.
5.8. Conduct research and analytical activities to improve Mobile Application operation.
5.9. Website and mobile data. The Company may automatically obtain and register information on its servers obtained from the User`s device, including IP address, software and hardware attributes, pages requested by the User, mobile identifiers, information about Mobile Application use, and / or information about other devices used, or system level information. This may take place in Mobile Application or on third-party services.
5.10. Anti-fraud measures.

§ 6. Information the Company does not collect and process

6.1. The Company does not collect or process information and personal data about racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, as well as data related to health, sexual life, biometric or genetic data.

§ 7. Records of telephone conversations

7.1. Phone calls, made by the User to the Contact Center of the Company or received by the User from the Contact Center operators, may be recorded to improve the quality of services provided by the Company and may be used as an evidence in the event of any dispute arising out of contracts execution.

§ 8. Statistical information management

8.1. In the process of Mobile Application operation the Company may collect certain statistical and other information using such technologies as cookies, pixels and local storage in the User`s mobile device. The Company may allow third parties (advertising and / or analytical services providers) to collect information using above technologies directly in Mobile Application.

§ 9. Information and data storage

9.1. The Company may store its information collected and obtained in Mobile Application as long as it will be required to meet above business objectives.
9.2. The places for storage and responsible persons shall be determined solely by the Company without prior and / or subsequent approval from the Users.

§ 10. Information disclosure and transfer

10.1. The Company may transfer information collected and processed to its separate divisions, dependent and affiliated persons (legal entities acting jointly with the Company on the basis of the agreement on joint activity or under the general control of the Company, etc.) that may be located in Ukraine or abroad, and also to the contracting parties and independent service providers.
The above persons may only process and use personal data obtained for the purposes set forth in §5 above. In this case, data transferred remain the subject of this Confidentiality Policy, and the persons affiliated with the Company, contracting parties and independent service providers shall use the information obtained from the Company in accordance with the current law, security requirements implemented by the Company and subject to provisions of this Confidentiality Policy.
10.2. In addition to the grounds for information disclosure, as specified in clause 10.1, the Company may provide information about Users in cases directly stipulated by the current laws of Ukraine, namely:
10.2.1. To individuals and public authorities in order to implement anti-fraud and abuse measures in Mobile Application and / or to prevent alleged violations of the law, or to deal with any other alleged violations of this Confidentiality Policy or Mobile Application Terms and Conditions by the Users.
10.2.2. To requests executed by competent authorities in accordance with requirements of the current laws of Ukraine.
10.3. The Company will not lease any personal data of Mobile Application Users to the third parties. If Company`s business on Mobile Application management or any part thereof is alienated, as an exception to this general rule, due to which the Company transfers all / almost all its assets to the new owner (assignee), the Users` personal data may be transferred to the acquirer in order to ensure continuity of Mobile Application servicing.
10.4. The Company may transfer certain personal information (data not allowing to identify a particular User) to the third party service providers, trusted partners or marketing researchers to better understand which advertisement or services may be of interest to the users, to improve overall quality and Mobile Application services efficiency, and to secure their own contribution to research that, in the Company`s opinion, can bring important social benefit.
10.5. In cases of personal data transfer specified in this section, to inform the Users about their personal data transfer is at discretion of the Company, depending on specific reason and purpose of the data transfer.

§ 11. Data privacy

To maintain confidentiality of Users` information, the Company undertakes to take the following actions:
11.1. To ensure that each of its employees, officers, directors or counterparties, who have access to confidential information, was notified of the confidential nature of the information and was imposed with requirements to comply with the data confidential regime, including in the event of employment, contractual or other relations termination with the Company.
11.2. ATTENTION! Information transferred to the Company will not be deemed to be confidential and the Company will not be obliged to protect its confidentiality if:
11.2.1. It has been known to the Company prior to its transfer by the User or is / becomes publicly known as a result of improper, negligent or wilful act of the disclosing party.
11.2.2. It has been legally obtained from the third party without limitation and violation of this Confidentiality Policy.
11.2.3. It has been provided by the User or its authorized representative to the third party without similar requirement to the third party rights restriction.
11.2.4. It has been independently developed by the Company, provided that the persons or a person who developed it did not have access to the confidential information.
11.2.5. It has been allowed for publication by written permit issued by the party which provided such information.
11.2.6. It has been disclosed to the State of Ukraine at the public authority`s request or included in the state registers, including by open access in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Associations or other registers with open data.
11.3. All information that will be collected and used by the Company will be protected by the technical means and procedures ensuring security in order to prevent unauthorized data access or use. In particular, the Company will use technologies for secure data transfer through the Internet (using secure protocols) and secure data storage. Access to account, where the User can view and edit personal data in the order established by the Company, shall be provided through the control of mobile telephone number of the User`s authorized person selected by the User during registration and confirmed by SMS.
11.4. All payment transactions, to be made by the Users while Mobile Application use and related to mutual settlements, including transactions with plastic cards, will be conducted through the bank or other accounts involving payment partners of the Company. The relevant transactions will be conducted through redirection to the Internet resources of such payment partners of the Company and / or Processing Centers with access to electronic settlement systems, which guarantees the high level of payments security to its Users due to SSL protocol for confidential information transfer and special security technologies for online card payments: “Verified by Visa” and “MasterCard Secure Code”. Any User`s card data, including CVV code, shall be always transferred encrypted through secure communication networks.
11.5. Any User`s card transactions will be conducted upon full compliance with requirements of “VISA International”, “MasterCard” and other payment systems in the world. The Company will not obtain bank card details of the User or other financial information.
11.6. ATTENTION! User`s information security is very important for the Company. However, unfortunately, no security system ensures absolute results and 100% guarantee of its confidential treatment. The Company cannot guarantee protection of its servers and Mobile Application against hacker and spam attacks, nor can it guarantee that the information provided by the User through Mobile Application will not be intercepted during its transmission over the Internet.
Therefore, the Company recommends to the User:
(a) to refrain from information provision that constitutes personal or commercial secret and is of interest to the third parties which unintended disclosure may do harm to the User or any third parties.
(b) to use Mobile Application only from its own devices, which will allow better protecting User`s data and do not transfer SMS authorization codes provided in Mobile Application to the third parties. By using Mobile Application on the third-party devices or transferring authorization SMS-codes to the third parties, the User may disclose its personal data. Therefore, the User is obliged to treat confidential information in a responsible manner and keep its passwords and data, required for access, in a place inaccessible to the third parties.

§ 12. Requests for information and data provision

12.1. The Users shall have a right, according to the current laws of Ukraine, to submit a request at any time in accordance with the order provided for by the Company for obtaining information about conditions under which their personal data are stored by the Company.
12.2. The Users who created their Profiles and / or placed an order in Mobile Application may receive appropriate access to their Profile, correct or delete information they provide in accordance with the procedures established by the Company, provided that such Users bear full responsibility for the accuracy of the data provided, or messages posted in Mobile Application.

§ 13. Profile disconnection or change

13.1. If the User`s Profile has been created through the identification provider (for example, Facebook Connect, VK, etc.), the User may also disable or modify its account data through provider identification settings (for example, facebook.com, vk.com). The information posted may be changed or deleted in the User`s Profile in Mobile Application.

§ 14. User`s Statement

The User states as follows:
14.1. It wilfully and voluntarily provides its consent to its personal data processing in any manner for the purpose specified above, and their inclusion in the database, including its personal data transfer to the Company and the third parties.
14.2. It is fully and sufficiently aware of its own rights as a subject of personal data in accordance with art. 8 of the Law of Ukraine “On Personal Data Protection”, understands these rights, and also guarantees that the Company and other third parties having access to the personal data of the User, in accordance with this Confidentiality Policy, are discharged from the obligation to send notice to the User in any form about the rights, purpose of data collection and persons to whom its personal data are transferred.
14.3. It confirms that it will not make any claims to above persons in the future regarding its personal data use, for the purpose set forth above.
14.4. It is fully and sufficiently aware of the procedure and the grounds for its personal data withdrawal, and of the fact that it may withdraw the above consent at any time by sending written / electronic notice to the Company.