Privacy policy

Appendix No. 1 to the Terms of Service Agreement for the Website www.arc.ua

What does this policy cover

Welcome to the online journal www.arc.ua (the “Website,” “we,” “our” or “us”). Our Privacy Policy explains how we collect, use, disclose, and protect information that applies to our Website, and your choices about the collection and use of your information.

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.

Cookies information

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.

Device identifiers

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.

Location data

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 security measures: to monitor activity that we think is suspicious or potentially fraudulent, and to identify violations of this Privacy Policy.

· 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.

· For matters that we are required to use your information by law: the Website will use or disclose your information where we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of the Website, our Users or others.

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 admin@arc.ua, 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:

· Billing;

· 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

We may share certain information such as your location, browser and cookie data and other data relating to your use of the Website with our business partners to deliver advertisements (“ads”) that may be of interest to you. The Website may allow third-party ad servers or ad networks to serve advertisements on the Website. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Website, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear GIFs, see above) to compile information about your browser’s or device’s visits and usage patterns on the Website, and to measure the effectiveness of their ads and to personalize the advertising content. We do not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes. Please note that an advertiser may ask us to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, we determine the target audience and the Website serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. The Website’s Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

How we transfer, store and protect your data

Your information collected through the Website may be stored and processed in the United States or any other country in which we or our subsidiaries, affiliates or service providers maintain facilities. We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. As a result, we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which we or our parent company, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

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 admin@arc.ua.

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.

Children’s privacy

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 admin@arc.ua.

Links to other websites and services

We are not responsible for the practices employed by websites or services linked to or from our Website, including the information or content contained therein. Please remember that when you use a link to go from our Website to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our Website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible for and we do not exercise control over any third-parties that you authorize to access your User Data. If you are using a third-party website or service (like Facebook) and you allow such a third-party access to your User Data you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Website.

How to contact us

If you have any questions about this Privacy Policy or the Service, please contact us at admin@arc.ua.