Privacy Policy

Hereby is described the practice of collecting and processing of personal data provided by persons (hereinafter User or you, your) accessing an internet website www.inbase.com.ua  (hereinafter the Website) managed by LLC “INTECRACY BASE”, registration number 35635588, registered at  2 Vytrianska str. building 6, 08132, Kyiv region, Vyshneve, operating under the service mark InBase (hereinafter the Company or we, us and our).

We gladly  inform you that the provisions of this Privacy Policy are subject to the up to date edition of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the Regulation) and certainly the Law of Ukraine “On personal data protection” №2297-IV dated 01.06.2010 (hereinafter the Law).

INTRODUCTION

 

We understand the importance of protection of your privacy and personal data and commit a lot of effort to develop and maintain high standards of internal security measures and technologies to provide you with secure processing and storage of the data we collect from you; and protect your data against unauthorized or unlawful processing and against accidental loss, destruction or damage.

  1. PERSONAL DATA WE COLLECT AND OBJECTIVE

1.1. When you access the Website we may collect and further process the following categories of data:

  • Information requested during the use of the Website, for example, your name,
  • Information, which we may collect through automated means. Through your use of the Website, we may also monitor and collect tracking information related to usages such as access date & time, device identification, operating system, browser type and IP address. This information may be obtained directly by the Company or through third-party services,
  • Contact information, i.e. your email address.

We do not collect any information that may identify you without your permission.

Pay attention that we use Google Analytics on our Website for analysis and improvement of the website performance. If you want to know more about Google Analytics service and its “do not track” policy, please visit https://www.google.com/analytics/terms/us.html

We neither solicit nor collect Personal Information from anyone under the age of 16 or under the legal age of your country if it is higher. If you are under 16 or you are not of legal age in your country, do not enter any personal information on our Website.

1.2. The term we keep the personal information you provide depends on the type of information, the purpose of its use, nature of sensitiveness, etc. To the general rule, we will retain your personal information for the length of time reasonably needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will also retain and use your information for as long as necessary to resolve disputes and/or enforce our rights and agreements.

1.3. We collect and process the aforementioned data to fulfill our obligations and realize legitimate interest before you, namely to:

  1. provide access to the website;
  2. inform on any changes and updates to the services we provide;
  3. comply with applicable legislation;
  4. maintain actions in relation to legal claims;
  5. provide additional or supportive services, as well as perform User surveys, statistical analysis;
  6. to ensure marketing activities (send you news, updates, promotions, product information, event announcements, and other).
  7. improve the performance and functionality of our services.

The above list may be extended depending on the development of the services.

  1. PROCESSING OF YOUR PERSONAL DATA

2.1. Your personal data may be received and processed:

(a)               by the Company within our internal systems of processes compliant to technical and organizational measures in a manner that meets applicable requirements of the Regulation and security standards; and/or

(b)               by outsourcing service providers and processors who access and use the data only to the extent required to perform the obligations subcontracted to them by the Company (hereinafter Subprocessors).

2.2. Those Subprocessors perform tasks on our behalf and are contractually obliged not to disclose or use collected information for any other purposes, other than specified in this Policy, and may storage and assistance in the facilitation of technical aspects of our services or performance of functions related to the administration of services (collection and analysis) or other indicated under contractual closes.

2.3 You give your explicit consent that the Company may on its own discretion to engage Subprocessors, who comply with technical and organizational measures in a manner that meet applicable requirements of the Law and Regulation and security standards implied under this Privacy Policy and also the policies used in the Company.

2.4. If such Subprocessors are outside of the Swiss Confederation or the European Union or European Economic Area, the processing of personal data is done or will be done in accordance with applicable laws.

2.5. Subprocessors remain fully liable for their acts and omissions and all obligations subcontracted to them. The Company is not responsible in the event that information is disclosed as a result of a breach or security lapse by any such Subprocessors, or for such Subprocessors' non-compliance with the foregoing requirements.

  1. INCIDENTS NOTIFICATION

3.1. If the Company becomes aware of any breach of our security leading to the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of, or access to (excluding unsuccessful attempts or activities) personal data of Users on systems managed or otherwise controlled by us we will notify you promptly and without undue delay and in compliance to the procedure prescribed under respective Law and Regulation.

3.2. The notification will be made to your email address. It is the sole responsibility of the User to provide us with the email address and ensure that this email address is valid and current.

3.3. None of the data incidents notification from the Company may not be and will not be construed as an acknowledgment of any fault or liability with respect to data incidents by us.

  1. USER’S SECURITY COMMITMENTS

4.1. User agrees that without prejudice to our security measures and data incidents that it is the User’s responsibility to make appropriate use of our services to ensure a level of security appropriate to the risk in respect of your personal data and securing your system and devices which you use to access the website.

4.2. We are not obliged to protect your personal data that you choose to store or transfer outside the Company and our Subprocessors’ systems.

  1. USER’S RIGHTS IN RESPECT TO PERSONAL DATA

5.1 You have the following rights in relation to your personal data:

1) Right to access

You have the right to obtain from us information as to whether your personal data is being processed, and, where that is the case, access such personal data.

2) Right to withdraw consent

When we rely on your consent for the processing of your personal data, you have the right to withdraw your consent at any time. However, the withdrawal of your consent will not affect the lawfulness of the Company’s processing based on consent acting prior to the withdrawal.

3) Right to rectification

You have the right on the accuracy of your personal information. For this purpose, you are obliged to notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.

4) Right to restriction of processing

You have the right to ask us to stop processing your personal data at any time.

5) Right to erasure

Asking us to delete all of your personal data will result in the Company deleting your personal data without undue delay (unless there is a legitimate and legal reason why we are unable to delete certain of your personal data, in which case we will inform you of this). Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use our services.

6) Right to data portability

You have the right to request that the Company provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so and the processing is based on consent or contractual performance.

7) Right to complain

You have the right to lodge a complaint to our responsible person designated in our internal regulations or to the authorized body, all contacts for the submissions specified hereinbelow.

5.2. We will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above, however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you a reasonable fee taking into account the administrative costs in order to process such requests or we may refuse to act on such requests.

5.3. The User may also send a request to receive the information which has been processed, amended, deleted or locked and information about any parties to which we transmit your personal data.

5.4. In some cases, we may charge a fee (based on our reasonable costs) if the requests are excessive considering the nature of the request itself or nature and functionality of our services.

  1. COOKIE & SIMILAR TECHNOLOGIES

6.1. We also use Cookie and similar technologies to collect technical information, which contains unique identifiers from you. In brief, we automatically receive the web address of the site that you came from and the IP address of the computer or device that you are using to access. This information helps us to understand your preferences, navigate the Website efficiently, and allows to develop and improve our services and to manage the load on our servers.

6.2. If you prefer not to allow cookies, please use your browser settings, most browsers give you an ability to manage your cookies or provide you with “incognito mode” or similar options, which allows you not to record your visits and downloads in your browsing and download histories. In this mode, any Cookie is created while this type of session is deleted after you close all “incognito” windows.

For more details, please check our Cookie Policy, which is also a part of this Privacy Policy.

  1. CHANGES TO THIS PRIVACY POLICY

7.1. Please note that we may amend this Privacy Policy from time to time at our sole discretion. Therefore, please check this document from time to time to get updates. If any significant updates in regard to data processing terms are made here we will notify you additionally within reasonable time via email provided by you for the case or as your contact email.

  1. CONSENT

By using the website, you consent to the collection, processing and receipt of your personal data, as described in this Privacy Policy.

  1. CONTACT DETAILS

If you require any additional information or have any further questions concerning this Privacy Policy, please contact us at info@inbase.com.ua

10. AUTHORIZED CONTROLLING BODIES

 

The supervising authority for privacy issues in Ukraine this is Ukrainian Parliament's Commissioner for Human Rights (Ombudsman)

Postal address: 21/8 Instytutska str., Kyiv-08, 01008

Telephone: 044-253-75-89

Email: hotline@ombudsman.gov.ua

Website:  http://www.ombudsman.gov.ua

The EU's independent data protection authority is the European Data Protection Supervisor

Postal address: Rue Wiertz 60, B-1047 Brussels

Telephone: +32 2 283 19 00

Email: edps@edps.europa.eu

Website: www.edps.europa.eu