1. Protection of personal data of the Users of the Keira platform is our primary task. We protect your privacy and your private and personal data.
2. We use your personal data based on this Privacy Policy.
3. Your personal data is processed in accordance with the requirements of the Law of Ukraine "On the Personal Data Protection ". The processing of personal data of users who are in the EU or who are EU citizens is regulated, inter alia by the EU General Data Protection Regulation 2016/679 (hereinafter -- "GDPR"). At the same time, the legislation of the countries of whose residents we are in business-partnership relations may establish additional requirements, which will also be considered while processing and saving such personal data.
4. Basic definitions:
• Personal data is all information that relates to the user of our application, data that identifies you personally, alone or in combination with other information available to us, or any other information that is directly or indirectly related to such a category of data, in accordance with the current legislation. For example, your name, phone number, email address, IP address, and other information you may provide while using this application.
• The subject of personal data is you, the user of the Keira platform.
• Processing of personal data is any action we may take with your personal data, including, but not limited to, collection, processing, transfer, analysis, removal, etc.
• General Data Protection Regulation – (GDPR, Regulation (EU) 2016/67), an entity of the European Union legislation related to the protection of personal data of individuals within the EU and the European Economic Area.
• Cookies are pieces of data (text files) that are sent to your device from a web server and stored on it. There are two types of cookies: permanent and temporary (or "session") cookies. Permanent cookies are stored as files on your mobile device for a long period of time. Session cookies are temporary files that are created while visiting our application and are deleted after exit of the application.
• Limitation of processing is the marking of stored personal data to limit their processing in the future.
• The data subject's consent is a voluntary, specific, conscious and unambiguous expression of will in which the data subject, by means of a statement or a clear affirmative action, provides consent to the processing of his personal data.
5. Pursuant to Article 6 of the GDPR, we inform you that we process your personal data only if you express consent to such processing.
6. Please note that the Privacy Policy may change in accordance with the different countries legislation updates, so please visit the "Privacy Policy" section to ensure that you have up-to-date information.
7. This policy applies to personal data and information collected by us when you use the Keira application. By using the application and giving express consent to the processing of personal data, you accept the provisions of this Privacy Policy. If you do not agree with this Policy, please do not use the Keira platform.
8. Personal data that the Company may collect:
• name, surname, patronymic (if available), passport data, of the taxpayer card registration number, date of birth and/or age, gender, marital status, details of the authorized person of the company, name of the company, details of the company, contact telephone numbers, e-mail, company location address, other information provided by User (for example, employment information and business address);
• information about the User's personal account (in particular, login, phone number), e-mail, login and password, account data, other Data necessary to provide service to Users of the application, communication with Users, including the User's interaction with the support service;
• information necessary for communication between Users, including for the conclusion and confirmation of agreements between them;
• information about devices used by Users, such as: IP address; date and time of the application usage by User, information about the software, as well as the Internet browser used by the User, information about the of the mobile device’s operational system, information about the operation of the User's devices, individual identifiers of the devices used by the Users;
• information about the User's actions (while communicating with other Users), including information left by Users as ratings, reviews or any other form of feedback from Users; information on which the Users’ rating is based, which contains user experience and which Users leave on the platform as a result of mutual interaction;
• information legally obtained by the Company from partners and/or third parties.
9. Our company’s personal data procession Principles stipulate (that):
• Data is processed legally, fairly and transparently;
• Data is collected for specific, clear and legitimate purposes;
• Data collected must be adequate and relevant to the purpose of processing and be limited exclusively to the purposes for which they are processed;
• Accuracy of processing;
• Data stored in a form that allows identification of the data subject and for no longer than is necessary for the purposes of processing;
• Processed in a way that ensures proper personal data protection.
10. Purposes of personal data processing:
• Efficient service while using the platform;
• Understanding your needs and providing the information you are looking for;
• Customize the application usage;
• Providing technical support to the user;
• Your security and fraud prevention;
• Providing you relevant notifications about the actions of other users;
• Sharing the information that we consider to be useful to you;
• Improving our service and optimizing the Keira app in the future.
The controller in accordance with Article 4 (7) of the General Data Protection Regulation (GDPR) is the company: Individual entrepreneur Kuzmichov Oleksandr Vyacheslavovych, registered in accordance with the legislation of Ukraine, at the following legal address: 07300, Vyshhorod, Kyiv region, Shevchenko Ave., 9, apartment 44.
11. To contact us regarding the usage of your personal data, please refer the following e-mail address: hi@keira.network, indicating "for data protection officer" in the subject.
12. The company confirms the obligations established by the GDPR, in particular:
• Identifies personal data only for the purposes established by this Privacy Policy and the Public Offer Agreement for use;
• Monitors the presence or absence of the user's consent to such processing;
• Does not receive and does not store information about race, philosophical, religious or political views, medical and other data with a special access regime;
13. User rights:
• The right of access to provided personal data;
• The right to modify or remove your personal data (the right to be forgotten and the right to erasure);
• The right to limit the processing of your personal data;
• The right to object to the processing of your personal data;
• The right to transfer personal data (right to data portability).
• The right to appeal any of our actions to the authorized body for the protection of personal data, in case of reasonable doubt regarding the correctness of the procedure for processing your personal data by our Company.
14. If the User has any concerns regarding the violation by the Company of the current legislation on the protection of personal data during the processing of User’s data, please contact us through the Support Service or by e-mail hi@keira.network, indicating "for data protection, officer" in the subject.
15. According to the Law of Ukraine "On the Protection of Personal Data", being the Buyer, as a subject of personal data, you have the following rights:
• Being informed on the methods of collection, the location of your personal data, the purpose of processing, the location or place of residence of the owner or controller of personal data or give the appropriate instructions to obtain this information to persons authorized by him, except for cases defined by law;
• Being informed about the conditions for providing access to personal data, in particular information about third parties to whom personal data is transferred;
• To access your personal data;
• To receive within thirty calendar days from the date of receipt of the request, except for cases provided by law, an answer on whether User’s personal data is being processed, as well as receive the content of such personal data;
• Submit a reasoned demand to the owner of personal data with an objection to the processing of his personal data;
• Make a reasoned demand for the change or removal of User’s personal data by any owner and administrator of personal data, if these data are processed illegally or are unreliable;
• To protect personal data from illegal processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of data, as well as protection from providing information that is unreliable or damages dignity and business reputation of a person;
• Submit complaints about the processing of personal data to the Authorized Body or to the court;
• Resort to legal remedies in case of violation of the legislation on the protection of personal data;
• Make reservations regarding the limitation of the right to process your personal data when giving consent;
• Withdraw consent to personal data processing;
• Know the method of automatic processing of personal data;
• To be protected against an automated decision that has legal consequences for User.
16. The company guarantees to provide you with an answer to the request regarding the processing of your personal data within 1 (one) month from the moment of receiving the request, free of charge.
17. The term of storage of your personal data shall not be longer than necessary for the purpose for which it is processed or to comply with legal requirements.
18. Personal information is deleted as soon as it is no longer necessary to fulfill the purposes for which it was collected.
19. Use of cookies and other technologies. The application uses cookies to:
• Collection of information about the duration of your interaction with the application;
• Determining the effectiveness and usefulness of advertising on different pages of the application;
• Support for the functionality of the application, for example, for memorizing the user's input information, eliminating the need to set appropriate settings every time when entering the application (page design theme, message volume, etc.).
20. If you do not agree to receive cookies from our application, you must click "I deny the use of cookies" when receiving a request from the application about the use of cookies.
21. When you visit our application, we automatically collect certain personal data from your device, for example:
• Your IP address.
• The name of your Internet Service Provider (ISP) is sometimes recorded depending on the configuration of your Internet Service Provider.
• Date and time of your visit to the application.
• Duration of your session.
• How many times you accessed the app in any given month.
• The operating system your device.
22. When paying through the BlueSnap system, we will first send your payment details to BlueSnap Corporate (800 South St., Suite 640, Waltham MA) where the transaction will be processed. Further information on data privacy can be found in the Privacy Policy on the website of the abovementioned payment system. Please note that we are not responsible for the refusal to accept your payment, if it is canceled by BlueSnap in case of any violations of international payment rules, including by intermediary banks.
23. Along with this, the Company has the right to send you push notifications, messages in applications: Skype, Viber, Telegram, WhatsApp, SMS messages, etc. to notify you on the actions of other users (response to your request, receipt of the request within the network according to your profile, chat notifications with other users, etc.).
24. The Company may provide confidential information and personal data to third parties at the direct request of the User (for example, for integration with other services, payment systems, etc.). In this case, the Company is not responsible for the protection of personal data and does not guarantee the preservation of such information.
25. At the same time, the Company does not sell or otherwise disclose your personal data, except as specified in this Privacy Policy and/or as required by law.
26. In the event of a corporate merger, acquisition, sale or transfer of assets, the Company may transfer information without prior notice. Such corporate decisions will be implemented in accordance with the principle of preserving all rights of application users. Users will be notified by email and/or other means of communication.
27. The company is obliged to disclose personal information without prior notice in response to the request of government bodies, including to meet the requirements of national security, or to fulfill the prescriptions of any regulatory act, court decision, warrant, to expose fraud or illegal activity, protection of safety of other persons or in the case when the disclosure of such information is necessary to minimize financial and/or reputational risks of the Company.
28. The application collects and processes personal data only from its own users who have gone through the appropriate registration procedure in the application and accepted the public offer. Keira does not collect information shared by users and is not responsible for the personal data of third parties who are not users of the platform.
29. The Keira application cannot be used by anyone under the age of 18. If we receive information that the user has not reached the age of 18, his account will be deleted simultaneously with personal data.
30. To prevent unauthorized access or disclosure of your personal data, the Company takes all technical and organizational measures to protect the data security. All personnel and third parties involved in the processing of your personal data are obliged to respect the confidentiality of your data.
31. You have no right to disclose your account access data to any third parties. The Company bears no responsibility in case such data got to third parties, which may become the reason for illegal use of your personal data.
32. The limited access policy is a set of measures implemented by the company to preserve your personal data, which implies limiting access to the database containing personal data only within the limits of the tasks assigned to the police. To implement this policy, we employ management procedures to protect and preserve the security of your personal data.
33. The Company is not responsible for damage or losses bore by the User or third parties because of misreading or misunderstanding of the terms of this Policy.
