Definitions and abbreviations
In this Privacy Policy the terms are used in the meanings set out in the laws of Ukraine "On Personal Data Protection",
"On Information".
Database means a named set of organized personal data in electronic form or in the form of personal data files.
Consent of the Data Subject means any voluntary, clear and revocable expression of the will of the Data Subject. It is provided in writing or other documented form. It allows to make a conclusion about its provision, and it allows the processing of personal data of the Data Subject within the defined purpose of such processing (hereinafter - "Consent"). Consent can be canceled.
Change of Personal data is a type of processing of personal data, which consists in introduction of any changes to the personal data of the data subject stored in the subordinate databases.
Depersonalization is the process by which personal data is uncircumcally separated from all identifiers and cannot be further related to a certain person. After that, they are not considered personal.
User is an individual who has registered and joined to the public offer on the Site and agreed to the processing of personal data.
Processing of personal data means any operation or set of operations carried out in whole or in part in the information (automatic) electronic system and / or personal data files, including, in particular, collection, registration, accumulation, storage, adaptation, change, update, use, transfer, depersonalization and destruction of Personal Data. This can be done manually or automatically (processing tools).
Personal data is information or a set of information about an individual who is identified or can be specifically identified.
Privacy Policy is a Policy of NETFRAME LLC on the processing of personal data of visitors to the site/application.
Disclosure means the transfer of personal information to any individual and / or legal entity other than the Data Subject / User or Administrator. This may include, but is not limited to, the transfer of personal information to affiliates or third parties, access (including remote access), distribution or publication.
Transfer of Personal Data means the transfer, disclosure and use of personal data. The term "transfer" may include the physical transfer of personal data or the provision of access to personal data.
The administrator is NETFRAME LLC, which has the right to process personal data in accordance with the law or the consent of the Data Subject.
Data subject is any person whose personal data is provided for processing.
Cookies are small text files that store information about the User's actions on certain resources.
General provisions
You acknowledge that you have read the terms of this Privacy Policy and agree to the processing of your personal data under the following conditions by using the Site and giving your consent to use of personal data.
This Privacy Policy governs the processing and protection of personal data of Site visitors as well as the specifics of using the Site. This Privacy Police is developed in accordance with the Constitution of Ukraine, the General Data Protection Regulation (GDPR; Regulation (EU) 2016/679) on the protection of personal data of all persons within the European Union and the European Economic Area, the laws of Ukraine "On Personal Data Protection", «On information» , «On access to public information", ISO/IEC 27001:2015 "Information technology. Methods of protection. Information security management systems. Requirements", ISO/IEC 27002:2015 "Information technology. Methods of protection. Code of Practices on Information Security Measures", adopted by the order of the State Enterprise" Ukrainian Research and Training Center for Standardization, Certification and Quality "dated 18.12.2015 №193 (as amended), Standard Procedure for Personal Data Processing, approved by the Commissioner of the Verkhovna Rada of Ukraine on human rights from 08.01.2014 №1/02-14, other acts of legislation, as well as internal regulations of the company. If any obligations or rights, conditions, principles of processing are not mentioned in the Privacy Policy, they are defined and regulated in accordance with the legislation of Ukraine.
If certain provisions of this Policy are recognized as contradicting to the current legislation of Ukraine or as invalid, it does not affect of the validity of other Policy provisions.
NETFRAME LLC has the right to update and change the Privacy Policy when it necessary without notice (previous or next) of the Data Subject / User of the Site. Therefore, the Data Subjects and the Users of the Site are obliged to review this Privacy Policy before providing / changing of their personal data.
The date of the last change of Privacy Police will be indicated in the item "Date of entry into force", which will indicate the date of entry into force of the Privacy Policy in the new version.
Collection of personal data
The following types of personal data are subject to collection, storage and use:
- information about your computer, including your IP address, geographic location, browser type and version, operating system;
- information about your visits and use of the Site, including referral sources, length of visits, pages viewed and ways to navigate the site;
- information about your e-mail address that you used to register on the Site;
- information you entered when creating a profile on the Site, for example, your name, profile picture, gender, date of birth, marital status, hobbies and interests, education and place of work;
- information, such as your name and email address, that you provided when subscribing to our emails and/ or mailings;
- information you have entered while using the services of the Site;
- information generated when using the Site, including information about the time, frequency and conditions of its use;
- information about any of your purchases, services or transactions you have made through the Site, including your name, address, telephone number, e-mail address and credit card information;
- information that you have posted on the Site for the purpose of publishing it on the Internet, including your username, profile image and the content of your publication;
- information contained in any messages you send us by e-mail or through the Site, including the content of the message and the metadata;
- any other personal information you provide.
However, you must obtain the consent of third party to both disclose and process of personal information of that person in accordance with this Policy before disclosing this information.
NETFRAME LLC does not verify the accuracy of the information received about users and does not control the legal personality of users.
Use of personal data
Personal information, transmitted through the Site will be used for the purposes specified in this Policy or on the relevant pages of the Site.
NETFRAME LLC may use your personal information for the following purposes:
- the Site and business administration;
- personalization of the Site for you;
- providing you the opportunity to use the services available on the Site;
- supervising goods through the Site;
- provision of services purchased through the Site;
- sending messages, accounts and reminders about payment, and receiving payments from you;
- sending non-marketing commercial messages;
- sending messages, accounts and reminders about payment, and receiving payments from you;
- sending an e-mail, if you ordered it;
- sending marketing notices regarding the business activities of NETFRAME LLC or the business activities of carefully selected third-party companies, which, in our opinion, may be interest to you through publications or, if you have specifically agreed to this. Such agreement may be given by sending e-mail or using similar technology (you can notify us at any time that you no longer wish to receive marketing communications);
- providing third-party companies with statistical information about our users (however, these third-party companies will not be able to identify any individual user from this data);
- processing of requests and complaints made by you or on you and related to the Site;
- in order to ensure the Site security and prevent fraud;
- to verify compliance with the terms and conditions that govern the use of the Site (including monitoring of private messages sent through the private messaging service of the Site);
- for other purposes.
If you have provided personal information for publication on the Site, we will publish it. Otherwise, we will use this information in accordance with the granted permission.
Your privacy settings may be used to restrict the publication of personal information on the Site, and may be controlled by means of privacy management tools on the Site.
Disclosure of personal information
NETFRAME LLC reserves the right to disclose your personal information to any of our employees, managers, insurers, professional advisors, agents, suppliers or subcontractors, to the extent and for the purposes set out in this Policy.
NETFRAME LLC reserves the right to disclose your personal information:
- in cases provided by law;
- in connection with any current or future litigation;
- to establish, exercise or protect our rights (including providing information to other parties to prevent fraud or reduce credit risk).
International transfer of personal information
The information collected by NETFRAME LLC may be stored, processed and transmitted between any countries in which the Administrator operates.
The information collected by NETFRAME LLC may be transferred to the following countries where there are no data protection laws similar to those in force in the European Economic Area: the United States, Russia, Japan, China and India.
Personal information that you publish on the Site via the Internet may be available worldwide. We cannot prevent its use, or misuse for criminal purposes by third parties.
You consent to the transfer of your personal information listed in Section III by agreeing to these rules.
Preservation of personal information
Personal information that NETFRAME LLC processes for a specific purpose or for certain purposes should not be stored longer than necessary to achieve a specific goal.
The personal information is not subject to deletion in these cases:
- in cases provided by law;
- if such information may relate to any current or future litigation;
- to establish, exercise or protect our legal rights (including providing information to other parties to prevent fraud or reduce credit risk).
After the Data Subject has deleted his / her account on the Site, his / her personal data is deleted.
Protection of personal information
NETFRAME LLC is obliged to take sufficient technical and organizational measures to prevent the loss, misuse or forgery of your personal information.
We will store all personal information you provide on our secure (both password and firewall) servers.
All electronic financial transactions made through the Site will be protected by data encryption technology.
You acknowledge that the transmission of information over the Internet is inherently insecure, and we can not guarantee the protection of data transmitted over the World Wide Web.
You are solely responsible for keeping your password for access to the Site confidential. We will never ask for your password (unless you are trying to log in to your account on the Site).
Third-party websites
NETFRAME LLC does not transfer personal data to third parties, except in cases where such transfer is required by law, at the request of the Data Subject or in other cases set out in this Policy.
NETFRAME LLC takes all possible measures to protect the personal information of users, voluntarily and knowingly transmitted by the latter, given that personal information is the value and inalienable content, including personal non-property rights of any individual.
The Site may contain links to other websites (only for informational purposes). This Policy will not apply to such websites if you link to other websites,
Therefore, NETFRAME LLC recommends to review the privacy and personal data policies of each website before transmitting any personally identifiable information
Cookie
A cookie is a text file or files that contain a small amount of information that sent to a web browser and stored on a user's device. Such devices may include a computer, mobile phone or other device with which the user visits the Site.
Cookies can be perpetual (they are called persistent cookies) and stored on the computer until the user deletes them or temporary (such cookies are called session). The session cookies stored until you close the browser. In addition, cookies are divided into core (they are set directly by the site visited) and third-party (set by other websites).
Pay attention:
- when the user visits the Site again, the cookie data is updated;
- the default web browser allows automatic storage of cookies on the user's device in most cases;
- disabling cookies may restrict access to published materials and / or malfunction of the site's services.
According to the classification of the International Chamber of Commerce, NETFRAME LLC uses the following categories of cookies:
- strictly necessary cookies - required for the user to navigate the website and when using certain services. For example, to access secure pages, registration and authorization, search the Site. Also, remember the previous actions of the user when going to the previous page in the same session;
- operational cookies - aggregate information about how the Site is used. This data is stored on the user's device between web browser sessions. Examples of such data are the following metrics: time spent on the Site, most frequently visited pages, understanding which sections and services of the Site were most interesting to the user, how effective this or that advertising and / or marketing campaign, etc. All information collected through operational cookies is intended for statistical and analytical purposes. Some cookie data may be provided to third parties who have the permission of the website and only for the above purposes;
- functional cookies - used to store settings or configurations that are stored on the user's device between web browser sessions. Examples of such data are the following metrics: username, profile photo, information on comments left, language version of the Site, location, information on whether the user has been provided with any information or selected preferences, as well as other settings of the Site . These cookies also allow users to watch videos, participate in interactions (polls, voting) and interact with social networks.
Some cookie data may be provided to third parties who have the permission of the website and only for the above purposes.
Target cookies - used to provide content that may be of interest to the user. This data is stored on the user's device between web browser sessions. Examples of such metrics include tracking recommended text, graphics, audio, and video to avoid reruns, managing targeted advertising, evaluating the effectiveness of advertising campaigns, information about user visits to other resources during conversions, and other Site settings.
The site may share this information with others, including media clients, advertisers, agencies, and related business partners, in order to provide quality targeted advertising.
The company uses services owned by other third-party companies, such as Facebook, Twitter, Instagram, Alphabet Inc., Gemius and others for prompt delivery, better display and detailed analysis of content on the Site,
The listed companies may use cookies on the user's device while working on the Site.
Please note that the Site may not affect the use of cookies used by these services.
Cookie management:
Major web browsers (listed below) are set to automatically accept cookies. To disable them, use the help function in your browser. Help can be called up via the menu or using the F1 key.
Microsoft Edge - https://privacy.microsoft.com/ru-ru/privacystateme
Mozilla Firefox - https://www.mozilla.org/en/privacy/websites/#cook
Google Chrome - https://support.google.com/chrome/answer/ 95647?hl=en
Opera - http://help.opera.com/Windows/11.50/ru/cookies.htm
Safari for macOS - https://support.apple.com/kb/PH21411?locale=en_US
Pay attention:
- the configuration of cookie settings for mobile web browsers may differ;
- it is worth reminding that full-fledged work with the Site is available only when using cookies;
- disabling cookies may lead to limited access to the content and malfunction of the services of the Site.
To contact NETFRAME LLC regarding the use of cookies, send an e-mail.
If the user does not enable the use of cookies or intentionally deletes all cookies from his web browser, then the next time you visit the Site, the user will be re-invited to enable and use cookies.
Information about users obtained through cookies is not sold or distributed in the public domain, and is owned by the company that owns the resource.
Minor safety
The site is not intended for minors. NETFRAME LLC appeals to parents to explain to their children about Internet security issues, their specific purpose and the need to use certain services of the Site.
Confidentiality of the activity of the personal data subject on the Site
Information about the activity (traffic) on the Site of users who go through the network or e-mail of the user is protected in accordance with the law. The secret of "activity" of the user when using the latest services of the Site is not violated.
Terms of access to personal data
The procedure for access to personal data of third parties is determined by the conditions
of the user's consent provided to the owner of personal data for the processing of such data, or in accordance with the requirements of the law.
The user has the right to receive any information about himself from any subject of relations related to personal data, provided that the surname, name and patronymic, place of residence (location) and details of the document certifies the natural person who submits the request, except in cases established by law.
The user has access to personal data free of charge.
Deferring the user's access to their personal data is not allowed.
Deferment of access to personal data of third parties is allowed if the necessary data can not be provided within thirty calendar days from the date of receipt of the request. In this case, the total term for resolving the issues raised in the request may not exceed forty-five calendar days.
The notice of deferment shall be notified to the third party who submitted the request in writing with an explanation of the procedure for appealing such a decision.
The decision to postpone or deny access to personal data may be appealed to the Commissioner of the Verkhovna Rada of Ukraine for Human Rights or a court.
Rights of the subject of personal data
NETERFAME LLC informs you about your rights as a subject of personal data, which are regulated by the Law of Ukraine "On Personal Data Protection", namely:
- to know about the sources of collection, location of personal data, the purpose of their processing, location or place of residence (stay) of the owner or controller of personal data or give appropriate instructions to obtain this information to authorized persons, except as provided by law;
- to receive information on the conditions for granting access to personal data, in particular information on third parties to whom his personal data is transferred;
- to access to their personal data;
- to receive no later than thirty calendar days from the date of receipt of the request, except as provided by law, an answer as to whether his personal data are processed, as well as receive the content of such personal data;
- to make a reasoned request to the owner of personal data with an objection to the processing of their personal data;
- to 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;
- to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or tarnishes the honor, dignity and business reputation of the physical persons;
- to appeal to the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or to the court with complaints about the processing of their personal data;
- to apply legal remedies in case of violation of the legislation on personal data protection;
- to make reservations regarding the restriction of the right to the processing of their personal data during the consent;
- to withdraw consent to the processing of personal data;
- to know the mechanism of automatic processing of personal data;
- to protect against an automated decision that has legal consequences for him.
Feedback
To update, access, modify, block or delete your personal data, revoke your consent to the processing of personal data provided by you to the Company in accordance with this Policy, or in the event of any comments, wishes or claims regarding your personal data, which are processed by the Company, please contact the Company: by e-mail or write a letter to: [email protected].
