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Privacy Policy

Last Updated: March 19, 2019

Please read carefully this Privacy Policy as it affects your obligations and legal rights.

This Privacy Policy is an independent legal document. Your rights and obligations when you use any of Applications are also defined (may be defined) by the following documents (agreements): Terms of Use; Disclaimer; any other terms we let you know about. This Privacy Policy may contain links to any document listed above. The absence of one document or all of the listed documents doesn’t affect the validity of this Privacy Policy.

SECTION 1 – GENERAL CONDITIONS

The Privacy Policy governs the privacy terms of using Applications, general rules of User’s Personal Data collection, processing, distribution, usage and keeping.

We follow all the legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains what information of yours we will collect when you use the Applications, how the information will be used, and how we will share and protect the information.

EACH USER MUST CAREFULLY READ AND COMPLY WITH THIS POLICY.

By using Applications you confirm that you agree to these Terms of Our Privacy Policy. If you do not agree with this Privacy Policy in general or any part of it, you should withhold from using Applications. You also agree that any information about you collected by us is transferred with your consent.

You provide and guarantee to us the right to process your personal data, including the right to perform the following actions to process your personal data (fully or partially in an automated system): storing, registration, changing, restoring and removing. Also you agree that your personal data is included in the personal data base and any additional notification is not required.

SECTION 2 – DEFINITIONS

2.1. In this Privacy Policy the following terms have meanings as described in the Definition section below:

2.1.1. “Applications” – applications, websites, tools or services, including but not limited:

Mobile and desktop applications

2.1.2. “Personally identifiable information” (hereinafter – “Personal Information” or “Personal Data”) shall mean any information that can be directly associated with a specific person and can be used to identify that person (including the information about Your activities, such as information about Your usage of the Applications, when directly linked to personally identifiable information, including automatically collected). We do not consider Personal Data to include information that has been anonymized so that it does not identify a specific User.

2.1.3. “Controller” (data controller) means a natural or legal person, which determines the purposes and means of the processing of personal data.

2.1.4. “Processor” means a natural or legal person, which processes personal data on behalf of the Controller.

2.1.5. “Owner” (“Applications Owner”) or “Operator” or “we” (“us” or “our”) means a natural or legal person, which owns the exclusive rights for the objects of intellectual property – Applications.

2.2. The other terms and notions used in this Policy shall be understood in accordance with the Terms of Use, unless other specified in this Privacy Policy.

SECTION 3 – INFORMATION WE COLLECT AND PROCESS

3.1. The User hereby expressly consents to provide Us, immediately upon Our notice of request, the information (including Personal Data) that is required to maintain compliance with any law, regulation or policy.

3.2 Personally Identifiable Information that is provided directly by you or via the third parties. Technical (programmatic) means of Applications can collect such Personal Data: first name (maintained only if the user agreed to receive information on a new products release and special offers), email, messages to technical support, data entered to the Applications when working with them (it is stored on our servers only for synchronization between user’s devices and it is not being used by us, in request for removing an account data are also removed with it). We may also obtain information about you from the third parties such as identity verification services. You (as a user) give your voluntary and undoubted consent for the collection and processing specified Personal Data and its transfer to the third parties in order to ensure functioning of the Applications and their appropriate work.

3.3. You (as a user) hereby expressly consent, represent and warrant that any and all information provided to Us by you is valid, current, complete and accurate.

3.4. Information relating to your usage of the Applications. We may track, collect, process and compile the Information, when you use the Applications, and use information, provided to Us by you, sent to Us by your computer, mobile phone or other access device, which may include: your IP address, device information including device model, identifier, version and type of operating system, the application installation ID, title and version number of the application, date of the installation and date when the application was last launched, “Pro” or “Lite” version of the application is used, data about the user behavior in the application, mobile network information, region and locale data. You (as a user) give your voluntary and undoubted consent for the collection and processing specified information relating to your usage of the Applications and its transfer to the third parties in order to implement functioning of the Applications and their appropriate work.

3.5. We also collect and store such information as: User requests to support regarding the work of the Applications and their related services, and other issues as well as similar texts of the User requests.

3.6. YOU AGREE THAT YOUR PERSONAL DATA MAY BE PROCESSED AND STORED BY US OR OUR COUNTERPARTIES DURING THE PERIOD OF TIME THAT IS PRACTICALLY NECESSARY TO FULFILL THE AIMS AND PURPOSES THAT IMPACT WITH FUNCTIONAL PURPOSE OF THE APPLICATIONS.

SECTION 4 – HOW WE USE YOUR INFORMATION

We use the information we receive from you as follows:

4.1. We collect and process the User’s Personal Data and Information relating to your usage of the Applications in order to ensure proper functioning of the Applications. In particular we use such Information in order to:

administer Applications and or provide services; develop new products and services; personalize Applications for you; send you technical notices and support and administrative messages; communicate with you about products, services, promotions, events and other news and information which we think will be interested to you; information relating to your usage of the Applications is used to monitor and analyze trends, usage and activities in connection with the Applications and or services, including the maintenance of analytics concerning: usage of the Applications across regions, users “retention”, number of the installation, behavior of users in the Applications; provide to the third parties with statistical information about Users (but those third parties will not be able to identify any individual User from that information); verify compliance with the Terms of Use governing the usage of the Applications; link or combine Personal Data We collect from or about You. 4.2. Such Your Personal Data as name, email and messages to technical support are processed (used) as follows:

4.2.1. Name and email are used to dispatch information about a new products release and special offers (only if the user gave his consent at the data entering).

4.2.2. We also use email of a user to create user's account, reset the password to account and authorize user in the account.

4.2.3. Messages that came to technical support service are used directly to respond to them. After reply to the message that came to technical support service, we save it in order to solve the problems more quickly in case of repeated requests. For the reply to a user's request to technical support, we can use his email.

4.3. The Applications Owner is the data controller and processor, except for the cases when there is an objective Owner’s need to process or store information at the Applications Owner’s counterparties or agents.

SECTION 5 - PERSONAL DATA PROTECTION AND STORAGE; APPLICABLE LAW

5.1. The Applications Owner will do any and all efforts and actions prescribed by Applicable Law to store any of Your Personal Data in secrecy by means of, including but not limited to use of secure data transfer protocols, physical access controls to Our data storages, information access authorization controls (which are designed to comply with Applicable Law and regulations), authorization of access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities.

5.2. Personal Data of users is stored and processed on servers in the United States. Accordingly Your Personal Data may be temporarily stored and processed in other jurisdiction. If you are accessing the Applications from countries of the European Union, Asia or any other region with laws or regulations governing the collection of Personal Data, usage and disclosure, please be advised that through your continued use of Applications, this Privacy Policy, and Terms of Use, you give your consent for resolving of all the possible disputes in accordance with Ukrainian law.

5.3. We reserve the right to store, process and transfer Your Personal Data to our servers in various jurisdictions, where our facilities or our service providers are located. It may also be processed by staff operating who work for Us or for one of Our service providers. Staff may be engaged in the fulfillment of Our services and or the processing of Your details and the provision of support services. By submitting Your Personal Data, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Policy. Third parties may be located in other countries where the laws on processing of Personal Data may be less stringent than in Your country.

SECTION 6 – THIRD PARTIES

6.1. We may share your personal information with:

service providers under contract who help with parts of our business operations; companies that We plan to merge with or be acquired by (should such a combination occur, We will require that the newly combined entity follow these terms with respect to Your Personal Data); third party identity verification services for fraud prevention purposes; law enforcement, government officials, or other third parties when We are compelled to do so by a subpoena, court order, or similar legal procedure; or We believe in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of Our policies; Our Personal Data processing counterparties or agents, hired by or cooperating with Us, whose services are required by Us from the practical point of view; other third parties only with Your prior consent or direction to do so. 6.2. We will not provide Your Personal Data to any other Users without Your consent or direction.

SECTION 7 - INTEGRATING THIRD PARTY SERVICES

7.1. Applications may contain links to third party websites, applications or services. Applications also may have integration with third party websites, applications or services. If You follow one of these links or use integration with any of these websites, applications and or services, please note that they and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites, applications or services. Please check these policies before You submit any Personal Data to these websites or use these applications or services.

SECTION 8 – PROTECTING YOUR CHILD'S PRIVACY

8.1. Applications are not designed for use by anyone under the age of 18 (and even over if the legislation of Your jurisdiction provides acquiring the full dispositive legal capacity of a natural person over the age of 18), though we realize we may have a Child attempt to use Applications. If you are a Child, you should withhold from using Applications. If you are a parent or guardian and believe your Child is using Applications, please contact us to remove your Child's account; we reserve the right to ask you for verification of your relationship to the Child before we honor such a request. If we discover that a Child has created an account in Applications, we will immediately delete the account as soon as we discover it, we will not use the information for any purpose, and we will not disclose the information to the third parties. However, as parent of such a Child, you understand that you are legally liable for any transactions created by the Child.

SECTION 9 – RETAIN INFORMATION

9.1. In accordance with applicable laws and as needed to provide services to Users, we may hold your Personal Data. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. We may retain Your Personal Data for as long as Your account is active. Moreover, Your Personal Data may be hold beyond the abovementioned period till it is indispensable for Us to have relevant information to respond to any issues that may arise later.

SECTION 10 – SECURITY

10.1. We use relevant electronic and procedural safeguards to protect the privacy of the information you provide to Us from loss, misuse, disclosure, alteration and destruction.

10.2. All the data is transmitted under the protected protocol https, passwords to users accounts are stored as a «hash» (it means that users passwords never passed in the clear from user devices).

10.3. PLEASE NOTE THAT TRANSMISSION OF DATA OR INFORMATION (INCLUDING COMMUNICATIONS BY EMAIL) OVER THE INTERNET OR OTHER PUBLICLY ACCESSIBLE NETWORKS IS NOT ONE HUNDRED PERCENT SECURE. PLEASE NOTE THAT WE ARE NOT LIABLE FOR THE SECURITY OF ANY DATA YOU ARE TRANSMITTING (WHICH MEANS IN THE PROCESS OF DATA TRANSFERRING) OVER THE INTERNET OR OVER THE OTHER METHOD WHICH IS BEYOND OUR CONTROL (IN PARTICULAR, NETWORKS THAT PROVIDES INTERNET ACCESS).

SECTION 11 – PRIVACY POLICY UPDATES AND AMENDMENTS

11.1. We reserve the right to modify or amend this Privacy Policy at any time. You should review this Privacy Policy frequently. Your continued usage of Applications shall mean your acceptance of those amendments and updates.

SECTION 12 – CONTACT US

12.1. “How to remove all of Your Personal Data?” You have right to require correction of Your Personal Data, updating, complete removal or removal of incorrect and or inaccurate data by sending Us an email to richohios@gmail.com Nevertheless, this request must comply with the aim of using Applications and legal obligations.

12.2. “How to prohibit Personal Data processing if you are allow this before? How to get all of Your Personal Data collected by us?” If you want to prohibit Personal Data processing or get all of Your Personal Data collected by us, you can send us require to email richohios@gmail.com.

12.3. If you have any other questions concerning this Privacy Policy, please contact us – richohios@gmail.com.

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