Privacy Notice
Last updated June 9, 2026
This Privacy Notice for LIMITED LIABILITY COMPANY "IQOSA" (doing business as IQOSA) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
Visit our website at https://iqosa.com or any website of ours that links to this Privacy Notice
Engage with us in other related ways, including any marketing, events, client communications, project discussions, or AI-assisted service workflows
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@iqosa.com.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We do not intentionally process sensitive personal information.
Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, analytics providers, advertising partners, and other outside sources.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, support security and fraud prevention, perform analytics and advertising, operate AI-assisted workflows, and comply with law. We process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may share information in specific situations and with service providers and partners, including providers such as Google, Meta, OpenAI, hosting, analytics, communications, security, and business support providers.
Do we transfer information internationally? Yes. Because IQOSA is based in Ukraine and uses international service providers, your information may be transferred to, stored, or processed in Ukraine and other countries where our providers operate.
Do we use cookies, analytics, and pixels? Yes. We may use cookies, Google Analytics, Meta Pixel, and similar tracking technologies for site operation, analytics, advertising measurement, remarketing, and audience-related purposes, subject to your consent and choices where required.
Do we use AI tools? Yes. We may use AI-powered tools, including OpenAI-based tools, for AI automation and related service support. This may involve processing prompts, business context, files, content, outputs, and operational metadata as described below.
How long do we keep your information? We keep your information only as long as reasonably necessary for the purposes described in this Privacy Notice, with specific retention periods listed in the retention section, unless a longer period is required or permitted by law.
What are your rights? Depending on where you are located geographically, applicable privacy law may provide rights to access, correct, delete, restrict, object to, or receive a copy of your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by contacting us at info@iqosa.com. We will consider and act upon any request in accordance with applicable data protection laws.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
In Short: We collect personal information that you provide to us, information collected automatically when you use our Services, and limited information from third-party sources.
Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, participate in activities on the Services, request information, contact us, or otherwise communicate with us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
names
phone numbers
email addresses
mailing addresses
usernames
job titles
contact preferences
contact or authentication data
billing addresses
Sensitive Information. We do not intentionally process sensitive information. Please do not submit sensitive information to us unless we specifically request it and provide the lawful basis and safeguards for that processing.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
We automatically collect certain information when you visit, use, or navigate the Services. This information does not usually reveal your specific identity, but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, approximate location, information about how and when you use our Services, and other technical information.
This information is primarily needed to maintain the security and operation of our Services, for internal analytics and reporting purposes, and, where permitted, for advertising measurement and remarketing. Like many businesses, we also collect information through cookies and similar technologies.
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take, as well as system activity, error reports, and hardware settings.
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address or proxy server, device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device location, which can be either precise or imprecise depending on the type and settings of the device you use to access the Services. For example, we may infer approximate location from your IP address. You can opt out by refusing access to location information or disabling location settings on your device, but some aspects of the Services may not work properly.
Analytics, advertising, and pixel data. Where permitted by law and your consent choices, we may collect online identifiers, cookie IDs, advertising identifiers, page views, referral data, campaign data, button clicks, form interaction data, browser/device data, and other website event information through tools such as Google Analytics and Meta Pixel.
AI workflow data. Where our Services include AI-assisted features or internal AI automation, we may process prompts, instructions, files, messages, business context, generated outputs, and operational metadata necessary to provide, secure, improve, audit, or support those workflows.
Information collected from other sources
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, analytics providers, advertising partners, and other third parties. This information may include mailing addresses, job titles, email addresses, phone numbers, intent data or user behavior data, IP addresses, social media profiles, social media URLs, and custom profiles, for purposes such as targeted advertising, event promotion, relationship management, and service delivery.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, protect our Services, perform analytics and advertising, operate AI-assisted workflows, and comply with law.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries and offer support to users. We may process your information to respond to your inquiries and solve potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To fulfill and manage your orders. We may process your information to fulfill and manage orders, payments, returns, and exchanges made through the Services.
To enable user-to-user communications. We may process your information if you choose to use offerings that allow communication with another user.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
To deliver targeted advertising and measure campaigns. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and online interactions, and to measure the effectiveness of campaigns.
To operate analytics and tracking technologies. We may process cookie, analytics, and pixel information to understand usage trends, improve our website, and measure website and advertising performance.
To operate AI-assisted features and internal AI automation. We may process prompts, uploaded content, messages, files, business context, outputs, and related metadata to generate, summarize, classify, route, draft, analyze, or automate content and workflows.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring, abuse prevention, troubleshooting, and security logging.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
To comply with law and enforce our rights. We may process your information to comply with applicable legal, regulatory, tax, accounting, security, or dispute-related obligations.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.
If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. This may include consent for marketing communications, cookies, analytics, advertising pixels, or certain AI-assisted processing where consent is required. You can withdraw your consent at any time.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or responding to your request before entering into a contract.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information to send users information about special offers, develop and display relevant advertising content, analyze how our Services are used, support marketing activities, diagnose problems, prevent fraudulent activities, improve user experience, and operate secure business workflows.
Legal Obligations. We may process your information where we believe it is necessary for compliance with legal obligations, such as cooperating with a law enforcement body or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission, or in situations where your permission can be inferred. You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without consent, including for investigations, fraud detection, business transactions, legal claims, compliance with court orders, public information, and other purposes permitted by law.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the third parties needed to operate our Services.
We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your 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.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
Service Providers. We may share your information with vendors, consultants, contractors, and other third-party service providers who perform services for us or on our behalf and require access to such information to do that work. These may include hosting, cloud infrastructure, analytics, advertising, CRM, communications, security, payment, legal, accounting, support, and AI service providers.
Specific providers. Depending on the Services and your choices, these providers may include Google for analytics, advertising, cloud, productivity, or website services; Meta for Meta Pixel, advertising, measurement, and audience-related services; and OpenAI for AI-assisted features and automation.
5. ARE YOUR PERSONAL INFORMATION TRANSFERRED
INTERNATIONALLY?
In Short: We may transfer, store, and process your information in Ukraine and in other countries where we or our service providers operate.
IQOSA is based in Ukraine. If you access our Services from outside Ukraine, your personal information may be transferred to, stored, or processed in Ukraine. We also use international service providers, including providers such as Google, Meta, and OpenAI, whose processing operations may take place in the United States, the European Union, the European Economic Area, the United Kingdom, Ukraine, and/or other countries where those providers or their subprocessors operate.
These countries may have data protection laws that are different from, or may not be as comprehensive as, the laws in your country. Where applicable law requires safeguards for international data transfers, we use appropriate measures such as data processing agreements, standard contractual clauses or equivalent transfer mechanisms, transfer risk assessments where appropriate, encryption, access controls, data minimization, and contractual commitments from service providers.
We transfer personal information internationally only when we have a legal basis to do so and when the transfer is necessary for the purposes described in this Privacy Notice, such as providing the Services, operating analytics and advertising technologies, using AI-assisted workflows, communicating with you, securing our systems, and complying with legal obligations.
You may contact us at info@iqosa.com if you would like more information about the safeguards we use for international transfers.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies, pixels, web beacons, analytics tools, and similar tracking technologies to collect and store information, subject to your consent and choices where required.
We may use cookies and similar tracking technologies, such as web beacons, pixels, tags, SDKs, and scripts, to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, tailor advertisements to your interests, measure advertising campaigns, build and measure audiences, and understand how visitors use our website. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites and platforms.
To the extent these online tracking technologies are deemed to be a "sale" or "sharing" of personal information under applicable US state privacy laws, including targeted advertising, you can opt out as described in the section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?" and by using our cookie preference tools where available.
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
Google Analytics
We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include Remarketing with Google Analytics, Google Analytics Demographics and Interests Reporting, and Google Display Network Impressions Reporting. To opt out of being tracked by Google Analytics across the Services, you can use the Google Analytics opt-out browser add-on. You can also adjust Google Ads Settings and device-level advertising settings where available. For more information on the privacy practices of Google, please review Google Privacy & Terms.
Meta Pixel
We may use Meta Pixel and related Meta Business Tools provided by Meta Platforms, Inc. and its affiliates. Meta Pixel helps us understand how visitors interact with our website, measure and improve advertising, build and measure audiences, deliver or improve advertisements on Meta products such as Facebook and Instagram, and understand whether our advertising leads to website actions.
Depending on your cookie settings, consent choices, browser settings, and the way our website is configured, Meta Pixel may collect or receive information such as page URLs, page views, referrer URLs, timestamps, browser and device information, IP address, cookie identifiers, advertising identifiers, campaign information, button clicks, form interactions, and other website event data. We do not intentionally send sensitive personal information to Meta Pixel.
You can control Meta Pixel and similar advertising technologies by using our cookie preference tools where available, changing your browser settings, using device-level advertising controls, and adjusting your advertising preferences in Meta products where those options are available.
7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
In Short: We may offer or use products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.
As part of our Services, we may offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). We may also use AI-assisted tools internally to support our work, automate business workflows, analyze information, draft materials, summarize content, classify requests, assist with customer support, and improve operational efficiency. The terms in this Privacy Notice govern your use of the AI Products within our Services.
Use of AI Technologies
We provide or support AI Products through third-party service providers ("AI Service Providers"), including OpenAI. Your input, output, and personal information may be shared with and processed by these AI Service Providers to enable your use of our AI Products and to support the purposes described in this Privacy Notice. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.
Our AI Products
Our AI Products and AI-assisted workflows are designed for the following functions:
AI automation
Content drafting, summarization, classification, extraction, routing, and workflow support
Internal business support, project support, customer support, analytics, and knowledge assistance
What Data May Be Processed Through AI
Depending on how you interact with us, AI-related processing may include:
prompts, instructions, questions, and messages you provide
documents, files, images, text, project information, business context, or other content you upload or share with us
customer support requests, form submissions, emails, meeting notes, task descriptions, or other communications
AI-generated outputs, summaries, classifications, drafts, recommendations, and metadata
technical metadata such as timestamps, account identifiers, request identifiers, error logs, model configuration data, and usage information needed to operate and secure the AI workflow
We do not intentionally ask you to provide sensitive personal information to AI Products. If sensitive information is included in content that you provide to us, it may be processed only as necessary for the relevant service, subject to applicable law and safeguards.
How We Process Your Data Using AI
We process AI-related data to provide the AI Product or AI-assisted workflow, generate outputs, automate or support business processes, improve the quality and safety of our Services, monitor for abuse or security risks, troubleshoot errors, and comply with legal obligations.
Where practical, we apply safeguards such as data minimization, access controls, confidentiality obligations, contractual protections with AI Service Providers, pseudonymization or redaction where appropriate, security monitoring, and human review for important outputs. We do not rely on AI as the sole basis for decisions that produce legal or similarly significant effects about you unless we provide additional notice and the law allows it.
We do not intentionally allow personal information submitted through our business/API AI workflows to be used to train third-party general AI models unless we separately disclose this and have a valid legal basis. AI Service Providers may process and retain certain data for security, abuse monitoring, service operation, legal compliance, or as otherwise described in their terms and data processing documentation.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We may offer or use products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.
We keep personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Notice, including providing Services, complying with legal, accounting, or reporting requirements, resolving disputes, enforcing agreements, maintaining security, and preserving records where required. Except for legal, tax, accounting, dispute, or compliance reasons, no purpose in this Privacy Notice will require us to keep personal information longer than 2 years.
The following retention periods apply unless a longer or shorter period is required by applicable law, a contract, a pending dispute, a legal hold, or your consent choices:
Type of information
Retention period
Website analytics, cookie identifiers, advertising identifiers, pixel events, campaign data
Website analytics, cookie identifiers, advertising identifiers, pixel events, campaign data
Up to 14 months from collection or last relevant activity, unless you withdraw consent or a shorter provider/browser/device setting applies. Aggregated analytics that no longer identify you may be kept longer.
Up to 14 months from collection or last relevant activity, unless you withdraw consent or a shorter provider/browser/device setting applies. Aggregated analytics that no longer identify you may be kept longer.
Contact forms, inquiry data, lead data, event registration data, and general communications
Contact forms, inquiry data, lead data, event registration data, and general communications
Up to 24 months from the last meaningful interaction with you, unless we need the information to provide ongoing Services or comply with law.
Up to 24 months from the last meaningful interaction with you, unless we need the information to provide ongoing Services or comply with law.
Client, account, project, service delivery, support, and business relationship records
Client, account, project, service delivery, support, and business relationship records
For the duration of the relationship and up to 24 months after the relationship or project ends, unless a longer period is required for legal, accounting, tax, dispute, or compliance reasons.
For the duration of the relationship and up to 24 months after the relationship or project ends, unless a longer period is required for legal, accounting, tax, dispute, or compliance reasons.
Marketing subscription records and marketing preferences
Marketing subscription records and marketing preferences
Until you opt out or withdraw consent, plus up to 24 months to maintain suppression records and document your preferences.
Until you opt out or withdraw consent, plus up to 24 months to maintain suppression records and document your preferences.
AI prompts, inputs, outputs, uploaded content, and AI workflow metadata
AI prompts, inputs, outputs, uploaded content, and AI workflow metadata
Up to 90 days for operational logs, debugging, security, and abuse monitoring, unless the content becomes part of a client, project, support, contract, or legal record, in which case the retention period for that record applies.
Up to 90 days for operational logs, debugging, security, and abuse monitoring, unless the content becomes part of a client, project, support, contract, or legal record, in which case the retention period for that record applies.
Security logs, authentication logs, anti-fraud logs, and system event logs
Security logs, authentication logs, anti-fraud logs, and system event logs
Up to 12 months, unless needed longer to investigate security incidents, fraud, abuse, legal claims, or compliance matters.
Up to 12 months, unless needed longer to investigate security incidents, fraud, abuse, legal claims, or compliance matters.
Billing, accounting, contract, invoice, tax, corporate, and payment-related records
Billing, accounting, contract, invoice, tax, corporate, and payment-related records
For as long as required by applicable legal, tax, accounting, or audit obligations, and normally up to 7 years after the relevant transaction, fiscal year, or business relationship ends.
For as long as required by applicable legal, tax, accounting, or audit obligations, and normally up to 7 years after the relevant transaction, fiscal year, or business relationship ends.
Job applicant or recruitment information, if collected
Job applicant or recruitment information, if collected
Up to 12 months after the end of the recruitment process, unless you consent to a longer retention period or the law requires a different period.
Up to 12 months after the end of the recruitment process, unless you consent to a longer retention period or the law requires a different period.
Backup archives
Backup archives
Usually up to 90 days, after which backup data is overwritten or deleted according to the backup cycle. Where immediate deletion from backups is not technically feasible, backup data is isolated from active processing until deletion is possible.
Usually up to 90 days, after which backup data is overwritten or deleted according to the backup cycle. Where immediate deletion from backups is not technically feasible, backup data is isolated from active processing until deletion is possible.
Legal claims, disputes, investigations, and regulatory requests
Legal claims, disputes, investigations, and regulatory requests
For as long as necessary to establish, exercise, defend, investigate, or resolve the relevant claim, dispute, request, or proceeding.
For as long as necessary to establish, exercise, defend, investigate, or resolve the relevant claim, dispute, request, or proceeding.
When we have no ongoing legitimate business need or legal obligation to process your personal information, we will either delete or anonymize such information. If deletion is not immediately possible, for example because your personal information has been stored in backup archives, we will securely store and isolate it from further active processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of personal information we process. These measures may include access controls, secure storage, encryption where appropriate, internal confidentiality restrictions, vendor review, logging, monitoring, and reasonable administrative safeguards.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age specified by law in your jurisdiction.
We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services.
If we learn that personal information from users less than 18 years of age or the equivalent age specified by law in your jurisdiction has been collected, we will deactivate the account where applicable and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age specified by law in your jurisdiction, please contact us at info@iqosa.com.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state, country, province, or region of residence, you may have rights that allow you greater access to and control over your personal information.
In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have certain rights under applicable data protection laws. These may include the right to request access and obtain a copy of your personal information, request rectification or erasure, restrict processing, object to processing, request data portability, withdraw consent, and not be subject to automated decision-making in certain circumstances.
If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review where required by applicable law. You can make a request by contacting us using the details in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you may also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing before withdrawal, nor, when applicable law allows, processing conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from marketing and promotional communications at any time by clicking the unsubscribe link in emails that we send, or by contacting us using the details below. We may still communicate with you for service-related, support, transactional, or non-marketing purposes.
Cookies and similar technologies: Most web browsers are set to accept cookies by default. You can usually set your browser to remove or reject cookies. If you remove or reject cookies, this could affect certain features or services. You may also use our cookie preference tools where available.
If you have questions or comments about your privacy rights, you may email us at info@iqosa.com.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized.
As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of certain US states, you may have rights to request access to, receive details about, correct, copy, delete, or opt out of certain processing of your personal information.
If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, delete your personal information, and withdraw consent to certain processing.
These rights may be limited in some circumstances by applicable law.
Categories of Personal Information We Collect
The table below shows the categories of personal information we may have collected in the past twelve (12) months. The table includes illustrative examples of each category. For a more complete inventory of personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"
Category
Category
Examples
Examples
Collected
Collected
A. Identifiers
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
YES
YES
B. Personal information as defined in the California Customer Records statute
B. Personal information as defined in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information
Name, contact information, education, employment, employment history, and financial information
YES
YES
C. Protected classification characteristics under state or federal law
C. Protected classification characteristics under state or federal law
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data
NO
NO
D. Commercial information
D. Commercial information
Transaction information, purchase history, financial details, and payment information
Transaction information, purchase history, financial details, and payment information
YES, if you purchase Services or otherwise enter a paid business relationship with us
YES, if you purchase Services or otherwise enter a paid business relationship with us
E. Biometric information
E. Biometric information
Fingerprints and voiceprints
Fingerprints and voiceprints
NO
NO
F. Internet or other similar network activity
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, website interactions, cookie identifiers, pixel events, and interactions with our and other websites, applications, systems, and advertisements
Browsing history, search history, online behavior, interest data, website interactions, cookie identifiers, pixel events, and interactions with our and other websites, applications, systems, and advertisements
YES
YES
G. Geolocation data
G. Geolocation data
Device location or approximate location inferred from IP address
Device location or approximate location inferred from IP address
YES
YES
H. Audio, electronic, sensory, or similar information
H. Audio, electronic, sensory, or similar information
Images and audio, video or call recordings created in connection with our business activities
Images and audio, video or call recordings created in connection with our business activities
YES, if you provide or participate in such communications
YES, if you provide or participate in such communications
I. Professional or employment-related information
I. Professional or employment-related information
Business contact details, job title, work history, and professional qualifications if you apply for a job or engage us at a business level
Business contact details, job title, work history, and professional qualifications if you apply for a job or engage us at a business level
YES
YES
J. Education Information
J. Education Information
Student records and directory information
Student records and directory information
NO
NO
K. Inferences drawn from collected personal information
K. Inferences drawn from collected personal information
Inferences drawn from collected information to create a profile or summary about preferences, characteristics, likely interests, or advertising audiences
Inferences drawn from collected information to create a profile or summary about preferences, characteristics, likely interests, or advertising audiences
YES, if analytics, advertising, or personalization features are used
YES, if analytics, advertising, or personalization features are used
L. Sensitive personal Information
L. Sensitive personal Information
Sensitive personal information as defined by applicable US state laws
Sensitive personal information as defined by applicable US state laws
NO
NO
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of receiving help through customer support channels, participating in surveys or events, facilitating delivery of our Services, responding to inquiries, or using AI-assisted features.
We will use and retain the collected personal information as described in the section "HOW LONG DO WE KEEP YOUR INFORMATION?"
Sources of Personal Information
Learn more about the sources of personal information we collect in the section "WHAT INFORMATION DO WE COLLECT?"
How We Use and Share Personal Information
Learn more about how we use your personal information in the section "HOW DO WE PROCESS YOUR INFORMATION?" and how we share your personal information in the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
Will your information be shared with anyone else?
We may disclose personal information to service providers pursuant to a written contract between us and each service provider.
We may use personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered to be selling personal information for money.
We do not sell personal information for monetary consideration. However, to the extent our use of advertising cookies, Meta Pixel, Google advertising features, or similar technologies is considered a "sale" or "sharing" under applicable US state privacy laws, you may opt out through our cookie preference tools where available and by contacting us at info@iqosa.com.
Your Rights
Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of processing for targeted advertising, the sale or sharing of personal data, or profiling in furtherance of
decisions that produce legal or similarly significant effects
Right to limit the use and disclosure of sensitive personal data where applicable
How to Exercise Your Rights
To exercise these rights, you can contact us by emailing info@iqosa.com or by referring to the contact details at the bottom of this document. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from information already maintained by us, we may request additional information for verification and security or fraud-prevention purposes.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@iqosa.com. We will inform you in writing of any action taken or not taken in response to the appeal, including the reasons for the decision. If your appeal is denied, you may submit a complaint to your state attorney general where applicable.
California "Shine The Light" Law
California Civil Code Section 1798.83 permits users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information, if any, we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact details provided below.
14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the contact details in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the Information Regulator (South Africa): General enquiries: enquiries@inforegulator.org.za; Complaints: PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za.
15. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at info@iqosa.com or contact us by post at:
LIMITED LIABILITY COMPANY "IQOSA"
15, Solomianska street, building A
Kyiv 03110
Ukraine
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You have the right to request access to the personal information we collect from you, details about how we have processed it, correction of inaccuracies, deletion of your personal information, restriction of processing, objection to certain processing, and withdrawal of consent where applicable. These rights may be limited in some circumstances by applicable law.
To request to review, update, or delete your personal information, please contact us at info@iqosa.com.