Appendix No. 1 to the Terms of Service Agreement for the Website www.arc.ua
What does this policy cover
Information we collect and its use
We collect the following types of information about you:
Information you provide us directly
We may ask for certain information such as a username, your first and last names, birthdate, phone number, profession and e-mail address when you register for an account on the Website, or if you correspond with us. We use this information to correspond with you, and to address any issues you may raise about the Website. We may store your personal information and use it to provide you with our newsletters and for other correspondence with you.
Information we collect from you automatically
We may directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our Website. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Website. We collect and use this analytics information in aggregate form so that it cannot reasonably be manipulated to identify any particular individual user.To help us improve our service we keep information about how you use our service and collect anonymous analytics data about how you use our Website.
When you visit our Website, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer or mobile device that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the Website. A cookie may also convey information to us about how you use the Website (e.g., the pages you view, the links you open and other actions you take on the Website), and allow us to track your usage of the Website over time. You can control or reset your cookies through your web browser, which will allow you to customize your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Website may not function properly if the ability to accept cookies is disabled.
Log file information
Log file information is automatically reported by your browser or mobile device each time you access the Website. When you use our Website, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, pages you entered from/exited from and their URLs, number of clicks and how you interact with links on the Website, domain names, landing pages, pages viewed, and other such information.
Whenever you load a page from the Website, your browser sends us information about itself and your interactions with our Website. That information gets stored on our servers.
Clear GIFs/web beacons information
When you use our Website, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of the Website and newsletter.
When you access the Website by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by the Website. A device identifier may convey information to us about how you browse and use the Website. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Website. Some features of the Website may not function properly if use or availability of device identifiers is impaired or disabled.
When you access the Website by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey to us information about how you browse and use our Website. Some features of the Website, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
How we use your information
We use the information we collect about you for the following purposes:
· To guarantee the quality of service provided by the Website, including the possibility of the delivery of newsletters.
· For data analytics: to help us improve the Website and our users’ experience by monitoring aggregate metrics such as total number of visitors, traffic, and demographic patterns.
· For matters that you have specifically consented to: from time to time the Website may seek your consent to use your information for a particular purpose. If you consent, we will use the information exclusively for that purpose. If you no longer want us to use your information for that purpose you may withdraw your consent at any time.
Legal bases for processing information under the GDPR (for users in the EEA)
For Website users in the European Economic Area (EEA), we process your information in accordance with European laws and regulations such as the General Data Protection Regulation (GDPR). The GDPR governs how the Website may process your information, and the rights that EEA users have in relation to it. This means that the Website will collect and use your information only where:
· We need it to provide you with the Website’s services.
· It is justified because of a legitimate interest such as for research and development or marketing (but only where our legitimate interest is not overridden by your interest and rights in protecting your data).
· You consent to the limited use of your information when requested for a particular purpose by us.
· It is necessary for compliance with our legal obligations.
If you have consented to the use of your information, you may withdraw that consent at any time. Depending on the situation you can either withdraw your consent by emailing us at firstname.lastname@example.org, or through your account settings page. If we are using your information because of a legitimate interest to do so, you have the right to object to that use. However, if you limit that use, it may mean that it is not possible for you to continue using some services on the Website.
Legal bases for processing information under Ukrainian law
For Website users in Ukraine and for Ukrainian citizens, the Laws of Ukraine “On personal data protection” and “On information” will apply.
Sharing your information
We will not rent or sell your information to third parties outside the Website and its group of companies (including any parent, subsidiaries and affiliates) without your consent, except as noted in this section: We won’t share your personal information without your permission except as follows:
Some of the third parties that the Website may share your personal information include providers who assist the Website with functions such as:
· Customer support and customer management;
· Email services;
· Hosting and storage;
· Analytics; and
· Delivery of physical products.
We might share some of your information with our business partners, but only as necessary to provide services to you or to fulfill the Website’s legitimate business interests. The Website may also share your information with third parties in certain circumstances, such as:
· if we are required to do so as a result of a court order, subpoena or other legal requirements;
· if we believe that it is necessary to protect you or the Website, when there is a need to investigate potentially fraudulent or criminal activity; or
· if you have consented to sharing your information with a third party for a particular purpose.
The Website may also share your information with a third party in circumstances where we sell, divest or transfer the Website (including any shares in the Website), or any combination of its products, services, assets and/or businesses to a third party. Information such as customer names and email addresses, User Data and other user information related to the Website may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganisations, liquidations, similar transactions or proceedings involving all or a portion of the Website. If we sell our business, any of the information which we have acquired about you may be part of the sale. We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties. By default all content you post on the Website is private.
Ads on the Website
How we transfer, store and protect your data
Cross-border transfers of information (for users in the EEA)
For Users in the EEA, if we transfer your information to a third party provider that is not located in the EEA, and is not subject to an adequacy decision by the EU Commission, we will require those third party providers to enter into an agreement that provides appropriate safeguards for your information. From time to time we may also seek your consent to transfer your information to a third country outside the EEA.
Keeping your information safe
The Website respects the importance of maintaining the security of your information, and uses appropriate safeguards to preserve the integrity and security of all information collected through the Website. We are not responsible for the functionality or security measures of any third party.
Compromise of information
In the event that any information under our control is compromised as a result of a breach of security, the Website will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other actions deemed appropriate in accordance with any applicable laws and regulations.
Your choices about your information
You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications.
Opting out of collection of your information for Tracking / Advertising
Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents the Website or its business partners from tracking your browser’s activities in relation to the Website, and for use in targeted advertising activities by third parties.
Rights regarding your Personal Information
The laws of some countries grant particular rights regarding personal information. Users in those jurisdictions may have the right to:
· Request a copy of your personal information;
· Request that we correct inaccuracies related to your personal information;
· Request that your personal information be deleted or that we restrict access to it;
· Request a structured electronic version of your personal information; and
· Object to our use of your personal information.
Should you wish to make a request regarding your personal information please contact us at email@example.com.
In some circumstances we may not be able to comply with a request that you make regarding your personal data. For example, we may not be able to provide a copy of your personal information if it infringes on the rights of another User. We may also be required to retain certain information that you ask us to delete for various reasons, such as where there is a legal requirement to do so. In some cases, you may have shared your information with third parties, such as by publishing content on a third party’s webWebsite. In that case we will not be able to delete the information, and you will need to contact that third party directly.
If we are unable to fulfill your request, or if you are concerned about a potential violation, you may be entitled to report the issue or make a complaint to the data protection authority in your jurisdiction.
How long we keep your User Data
Following termination or deactivation of your User account, we may retain your profile information and User Data for a commercially reasonable time, and for as long as we have a valid purpose to do so. In particular, we may retain your information for the purpose of complying with legal and audit obligations, and for backup and archival purposes.
The Website does not knowingly collect or solicit personal information from children and the Website and its content are not directed at children. In the event that we learn that we have collected personal information from a child without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child, please contact us at firstname.lastname@example.org.
Links to other websites and services
How to contact us