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PRIVACy

Date this Policy last updated: 25 May 2021

POLICY

01

  1. Overview

1.1. This Privacy Policy (“Policy”) together with the Terms of Use form an entire legal Agreement (“Agreement”) between “IQOSA” LLC (“IQOSA ”), a company registered under the Law of Ukraine with registered number 44355934, and you as a user (“you”, “user”). The Agreement applies to our website (“site”) located at: https://iqosa.com/. If you have any questions you can contact us at: privacy@iqosa.com.

02

  1. Who we are?

2.1. Name: IQOSA

2.2. Email address for official notices: info@iqosa.com

2.3. Data Retention Period(s): We Process your Personal Data in order to fulfill obligations rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than 20 years.

03

  1. Words with specific meanings

3.1. In this Policy, there are words and phrases that have a specific meaning or that we are using in a special way.  They are:

3.1.1. “Personal data” any information about an identifiable living human being.

3.1.2. “Process” we process your Personal Data when we do anything with it, which might include:  collecting, recording, organizing, storing, adapting, altering, retrieving, using, combining, disclosing, or deleting it.

3.1.3. “Special category data” is Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, health, genetic or biometric data.

04

  1. Your rights

4.1. You have the right to know what information we are collecting on you, and to amend it if it is inaccurate.

4.2. If you feel for some reason we have information we should not be keeping, or it is out of date or otherwise wrong, please let us know and we will take appropriate action. Most of the information we hold is not based on your individual consent but is based on our needing the information to run our business and provide our products and services.

4.3. If you want to know what information we have about you (if any) email us at the email address set out above and give us your name, email address(es) and we will happily do a search and let you know what information we hold on you and how we are using it/have used it.

4.4. You have a “right to be forgotten”, but that does have some legal limits to it.  If you want us to remove information about you, let us know.

4.5. You can, at any time, object to the processing of your Personal Data on grounds relating to your particular situation. You have the right to object your Personal Data being processed for direct marketing purposes

05

  1. What data do we collect?

5.1. You may browse our Site without providing your personal information.

5.1.1. Data you provide us with. Through our Site, you may provide us with your Personal Data to send your project request or to send your career request. Data which you may provide to us include:

5.1.2. Full name;

5.1.3. Phone number;

5.1.4. Email address;

5.1.5. City;

5.1.6. CV;

5.1.7. Portfolio;

5.2.1. Data collected automatically. We use this data to constantly improve our site. Therefore, when you access our Site, certain data may be collected automatically. Such data include:

5.2.2. Cookies.

5.2.3. Device data (device model, OS type etc.);

5.2.4. IP address;

5.2.5. Connection type (WiFi, LTE, 3G);

5.2.6. Language and region;

5.2.7. Your interactions with Site.

5.3. If you sign up to a newsletter list, you will be sent what you asked for. We operate “double opt-in” lists and you will need to reconfirm your subscription before anything is sent. You can unsubscribe at any time by clicking the unsubscribe button on any email.

5.4. You are not automatically subscribed to any other lists, but may be invited to join an appropriate one.

5.5. If you make an enquiry via our site, we will keep details of that enquiry and response for our data retention period.

5.6. We do not routinely keep special category data.  To the extent we hold this, it was supplied or made publicly available by you.

5.7. Automatically collected data is aggregated and anonymized.

06

  1. How do we use your data?

6.1. We use your data to:

6.1.1. Provide you with an access to our Site;

6.1.2. Provide you with customer support;

6.1.3. Provide you with career opportunities;

6.1.4. Contact you to deliver certain services or data you have requested;

6.1.5. Conduct researches to improve our services;

6.1.6. To improve the content and general administration of our Site;

6.1.7. For analytical purposes.

6.2.1. Compliance with our legal obligations. We may be obliged to store some of your Personal Data to comply with the relevant data protection legislation.

07

  1. Policy towards children

7.1. IQOSA does not provide services to persons under the age of 18. We do not and will not knowingly collect Personal Data from any child under 18. If you are a parent or guardian and are concerned about the Personal Data of your child, please contact us at: privacy@iqosa.com. If we become aware that a minor has provided us with personal data, we take steps to remove such data and terminate that person’s profile.

08

  1. Cookies

8.1. A cookie is a piece of data stored on the user’s hard drive containing information about the user.

8.2. Our cookies help us:

8.2.1. Make our site work as you’d expect;

8.2.2. Offer you free services/content;

8.2.3. Improve the speed/security of the site;

8.2.4. Allow you to share pages with social networks, like Facebook;

8.2.5. Continuously improve our site for you;

8.2.6. Make our marketing more efficient;

8.3. We do not use cookies to:

8.3.1. Collect any personally identifiable information (without your express permission);

8.3.2. Collect any sensitive information (without your express permission);

8.3.3. Pass personally identifiable data to third parties;

8.3.4. Pay sales commissions;

8.4. Turning Cookies Off

8.4.1. You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so, however, will likely limit the functionality of our’s and a large proportion of the world’s sites as cookies are a standard part of most modern sites.

8.4.2. It may be that you concerns around cookies relate to so-called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.

09

  1. How do we share and disclose data?

9.1. If you provide us with your Personal Data, we may share and disclose data that we collect for the following reasons:

9.1.1. In cases where you have provided your explicit consent, we may share your Personal Data, as described at the time of consent.

9.1.2. We will disclose your Personal Data (1) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an ongoing investigation of a governmental authority, (2) to enforce the IQOSA’s Site Terms of Use or user agreements or to protect our rights.

9.1.3. We will not sell your Personal Data to any company or organization, but we may transfer your Personal Data to a successor entity upon a merger, consolidation or other corporate reorganization in which IQOSA participates or to a purchaser or acquirer of all or substantially all of IQOSA assets to which this Site relates. In such an event, we will notify you before your Personal Data is transferred and becomes subject to a different privacy policy.

9.1.4. Through the third party analytics providers and directly through our Site, we may track data that will be maintained, used and disclosed in aggregate form only and which will not contain your Personal Data. For example, without limitation, the total number of visitors of our Site, the browser type. We may analyze this data for trends and statistics in the aggregate, and we may use such aggregate data to administer the Site and gather abroad demographic data for aggregate use.

9.1.5. We may provide your Personal Data and the data generated by cookies and the aggregate data to the vendors and service agencies that we may engage to assist us in providing our services to you for their use solely to provide us with such assistanceю

10

  1. Data sharing – 3rd parties

10.1. We do not sell or exchange your Personal Data with organisations who may want to sell you something or use your data for research or other purposes.

10.2. We keep a list of the software platforms we use to run our business.  If you would like more information on the platforms we use, please email us.

10.3. We only work with Processing partners who are able to ensure the adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.In order to provide a robust and reliable service, we depend on a number of cloud service providers to carry out key operations within our business. This includes things like document storage, payment processing, email processing, marketing assistance, social media management and site security.

10.4. We have a support team for our own business which may include Virtual Assistants, Web Designers, IT support, Sales and Marketing, Accounting and more. They have limited access to your data, where the service they provide to us means they need it. For example, if our IT support wants to check the functionality of a laptop or back up, they may need temporary access to information that may include something about you. Your information/advice is held in the strictest confidence. Our team is all contracted to strict confidentiality clauses.

11

  1. How do we handle your data?

11.1. Retention. We retain your Personal Data on the protected server which is located within the Ukraine.

11.1.1. We generally retain your Personal Data for as long as is necessary for the provision of our service to you and us and to comply with our legal obligations. If you request, we will delete or anonymize your Personal Data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain Personal Data, including situations such as the following:

11. 1.2. Where we are required to retain the Personal Data for our legal, tax, audit, and accounting obligations, we will retain the necessary Personal Data for the period required by applicable law;

11.1.3. Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

11.2. We use operational and technological measures that are generally consistent with industry practice. Such measures are reasonably designed to help protect your Personal Data from loss, unauthorized access, disclosure, alteration or destruction. We may use encryption, secure socket layer and password protection to help prevent unauthorized access to your Personal Data.

11.3. The security of your data is important to us. Nevertheless, we cannot guarantee the absolute protection of your Personal Data. If you have a reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us in writing at: privacy@iqosa.com.

12

  1. Do we transfer your data?

12.1. Due to the international nature of IQOSA in the course of our operations, we may need to process data on a server located outside of the country in which you reside. In such cases, we will use appropriate safeguards to ensure that your personal information will remain protected in accordance with this Privacy Policy.

13

  1. Newsletters and automated emails

13.1. We monitor who opens what in our newsletter lists, and pre-set sequences of information we send you.  We do this, so we can see if content is popular and generate more of it, or if it is not read.

13.2. There may be sub-routines that trigger if you click on links or articles.  These are designed to offer you more information about things you are interested in.

13.3. You can unsubscribe from these sequences at any time.

13.4. Existing customers may receive emails about specific offers relating to things you have already purchased.   You can unsubscribe from these at any time.

13.5. From time to time, we contact individual email newsletter subscribers but it is extremely rare.  This would normally be if something odd were going on and we wanted to check you could see and use the content or find out what was causing a problem.

14

  1. How do we update this Policy?

14.1. From time to time we may update this Policy. For example, we may need to update it for legal reasons or to reflect changes in our services. If we do so, we will make the updated Privacy Policy available in our application.

14.2. We strongly encourage you to periodically review this Privacy Policy for any changes.

15

  1. Contacting us

15.1. If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at: Solomyanska St. 15A, Kyiv, 03110, Ukraine.

Email: info@iqosa.com

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