Personal Data Processing Policy
Last updated: November 5th, 2020
1. General provisions
- The Company sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of Personal data, including the protection of rights to privacy, personal and family secrets.
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
- “User” — the individual accessing or using the Service, or the Company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
- “Company” (referred to as either "the Company", "We", "Us" or "Our" in this Policy) — owner of the website, for more info refer to: firstname.lastname@example.org.
- “Affiliate” — an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- “Website” — https://spayz.io/.
- “Service” — the Website and applications connected hereto.
- “Service Provider” — any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- “Personal Data” — any information that relates to an identified or identifiable individual.
- “Cookies” — small files that are placed on User’s computer, mobile device or any other device by a website, containing the details of User’s browsing history on that website among its many uses.
- “Device” — any device that can access the Service such as a computer, a cellphone or a digital tablet.
- “Usage Data” — data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- “Depersonalisation of personal data” - actions making it impossible to determine the ownership of personal data by a specific User or another personal data subject without the use of additional information.
- “Personal data processing” — any action (operation) or a set of actions (operations) performed with personal data using automation means or without the use of such means, including collection, recording, systematisation, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data.
Types of Data Collected
- While using Our Service, We may ask User to provide Us with certain personally identifiable information that can be used to contact or identify User. Personally identifiable information may include, but is not limited to:
• Email address
• First name and last name
• Phone number
• Usage Data - when website also collects and processes depersonalised data about visitors (including cookies) using the Internet statistical services (Google Analytics and others);
- Data mentioned above is hereafter united by the general concept of Personal data.
- Usage Data is collected automatically when using the Service.
- Usage Data may include information such as Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that User visits, the time and date of the visit, the time spent on those pages, unique device identifiers and other diagnostic data.
- When User accesses the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device, mobile device unique ID, the IP address of mobile device, mobile operating system, the type of mobile Internet browser, unique device identifiers and other diagnostic data.
- We may also collect information that User’s browser sends whenever User visits our Service or when accesses the Service by or through a mobile device.
Tracking Technologies and Cookies
- User can instruct the browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if User does not accept Cookies, User may not be able to use some parts of our Service.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on the personal computer or mobile device when User goes offline, while Session Cookies are deleted as soon as User closes web browser. Learn more about cookies: All About Cookies.
Legal basis of personal data processing
Purposes of personal data processing
- The Company may use Personal Data for the following purposes:
• To provide and maintain our Service, including to monitor the usage of our Service.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services that User has purchased or of any other contract with Us through the Service.
• To contact User: To contact by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide User with news, special offers and general information about other goods, services and events which we offer that are similar to those that User have already purchased or enquired about unless User have opted not to receive such information.
• To manage User’s requests: to attend and manage requests to Us.
- We may share Personal Data in the following situations:
• With Service Providers: We may share Personal Data with Service Providers to monitor and analyze the use of our Service, to contact User.
• For Business transfers: We may share or transfer User’s personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
Retention of Personal Data
- The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Personal Data
- Personal Data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of User’s state, province, country or other governmental jurisdiction where the data protection laws may differ than those from User’s jurisdiction.
- Cross-border transfer of personal data into the territory of foreign states that do not meet the requirements above can be carried out only if the personal data subject agrees in writing to cross-border transfer of their personal data and/or in case of the execution of a contract, to which the personal data subject is a party.
Disclosure of Personal Data
Under certain circumstances, the Company may be required to disclose Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Personal Data in the good faith belief that such action is necessary to:
• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
Protect against legal liability
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 fully comply with the requirements of the current legislation in the field of personal data protection.
- The Company ensures the safety of Personal Data and takes all possible measures to prevent access of unauthorized persons to personal data.
- In case of revealing inaccuracies in personal data, the User can update the data independently by sending a notification to the Company's email address email@example.com marked "Updating of personal data".
- The period of personal data processing is unlimited. The User can at any moment withdraw their consent to the processing of personal data by sending a notification to the Company via email to the Company's email address firstname.lastname@example.org marked "Withdrawal of consent to the processing of personal data".
Detailed Information on the Processing of Personal Data
Service Providers have access to Users’ Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service providers to monitor and analyze the use of our Service, like Google Analytics.
Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If User is a parent or guardian and is aware that a child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.
Links to Other Websites
- We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
- The User can get any clarifications on issues of interest relating to the processing of their personal data by contacting Us via e-mail email@example.com.
- The current version of the Policy is available for public access on the Internet at https://spayz.io/privacy-policy.