PRIVACY POLICY
(effective from October 1, 2023)
1. General provisions
1.1 This Privacy Policy (hereinafter referred to as the "Policy") has been developed by UAPROM LLC (identification code code: 36507036, address: 02121, Ukraine, Kyiv, Kharkivske Shosse, 201-203, letter "4G", hereinafter referred to as the "Company" and/or the "Marketplace Administration") in accordance with the requirements of the current legislation of Ukraine, including, but not limited to, the Law of Ukraine "On Personal Data Protection" dated June 01, 2010 No. 2297-VI, taking into account the principles and rules of the General Data Protection Regulation (GDPR) of the European Union regarding Users of the Made With Bravery Marketplace (https://shop. brave.ua/) and establishes the procedure for obtaining, collecting, accumulating, storing, processing, using, ensuring the protection and disclosure of personal data (hereinafter referred to as the "Data") through the Marketplace and/or related services and tools.
According to this Policy,
“Data” means any information that directly or indirectly relates to a particular User. This may include: first name, surname, patronymic (if any), information about the type of activity, marital status, education, e-mail address, telephone number, region of residence, address of residence/stay, information about the User's actions on the Marketplace, IP address, device data (computer, browser type, mobile device operating system used by the User), messages (information contained in correspondence between Users, as well as in correspondence with the Marketplace Administration), other information, which is used for communication, which, at the request of the User, is provided by him/her in the registration form and/or when filling out his/her own profile (Personal Account) on the Marketplace, when completing a survey (by filling out a questionnaire or otherwise), when writing a message or feedback, or information received during oral communication between the User and the Marketplace Administration, as well as information provided when making payment and/or using any service provided by the Company.
“Data processing” means any actions with the Data, including, but not limited to: access, provision, distribution, collection, systematization, storage, accumulation, recording, transfer, blocking, deletion, clarification, updating and/or modification, depersonalization and other ways of using the Data by the Company. UAPROM LLC is the Data Controller.
1.2. By registering on the Marketplace and/or entering their personal Data and/or providing this Data in another way, and/or performing any actions within the Made With Bravery Marketplace (https://shop.brave.ua/) and/or using any part of the site, and/or by giving consent (ticking the box) when clicking the "register" button through the site form, and/or as a result of placing an order, and/or communicating regarding the Bravery Services (https://shop.brave. ua/), leaving mobile phone number or other Data on the Marketplace (https://shop.brave. ua/), and/or by entering the Data independently, namely: payment card number, card expiration date, the User expresses its consent to the terms of this Policy and grants UAPROM LLC, Marketplace Sellers, as well as third parties providing services to UAPROM LLC, in particular, but not exclusively, processing payments, providing financial services, delivery services - permission to process their personal data.
Users may provide the Data independently by posting such data on the Marketplace and/or using their Facebook account, Google account, thus providing access to their Data or by notifying through telephone channels and/or to the Company's e-mail and/or postal address, by filling out questionnaires (filling out a questionnaire or in any other way). The Data may also be provided from other sources (in accordance with clause 3 of this Policy), for example, from User reviews (assessment, comments, confirmation of information) or other information from third parties provided in the course of submitting claims, complaints and/or disputes, and/or information from publicly available sources on the Internet.
1.3. The User has no right to use the Marketplace (https://shop.brave.ua/) if he/she does not agree to the terms of this Policy.
1.4. The User acknowledges that in case of his/her negligence to the security and protection of his/her Data and authorization data (password, login), third parties may gain unauthorized access to the User's account and Data. The Company shall not be liable for any damages caused by such Access.
2. What Data may be collected
The Company may collect the following Data:
- first name, surname, patronymic (if any), passport data, taxpayer registration number, date of birth and/or age, gender, marital status, place of actual residence, image, data of the authorized representative of the company, company name, company details contact phone numbers, e-mail address, address of the company's location, other contact details at the request of the User (for example, place and/or address of work), payment card numbers, payment card tokens (USB keys intended for the User's information security);
- information about the User's account (including login and password, phone number, e-mail address, account processing data), other Data necessary for the provision of services to the Users of the Marketplace, communication with the Users, including in the process of the User's contacting the Marketplace support service;
- information provided by the Users to the Company when entering into service agreements by accepting a public offer posted on the Marketplace and/or entering into agreements for the provision of additional services on the Marketplace;
- information necessary for communication between the Users of the Marketplace, including for the implementation and confirmation of transactions between sellers and buyers, receiving and sending messages, posting reviews, comments, making payments to fulfill requests from Users and receiving feedback from Users, if necessary, information posted by Users based on the results of their service, reviews, comments, requests to the support service, complaints, claims, other requests;
- information about the devices used by the Users, information about the mobile devices of the Users (if the User uses a mobile device when entering the Marketplace) such as: IP address; date and time when the User uses the site, information about the software and Internet browser used by the User, information about the operating system of the mobile device, information about the operation of the User's devices, individual identifiers of the devices used by the Users);
- data obtained as a result of various surveys conducted by the Company and/or third parties authorized by the Company in order to improve the provision of services to Users;
- information received by the Company as a result of marketing activities;
- information about the User's actions on the Marketplace (consumer behavior regarding purchased goods, works, services);
- information posted or provided to the Users in the course of their participation in bonus programs, quizzes, promotions, special offers that take place on the Marketplace and are organized by the Company;
- information received from the Users by filling out questionnaires or otherwise communicated to the Marketplace Administration (this may include, but is not limited to, information about: citizenship, place of birth, education, profession, specialization, work experience, social status, family composition (surnames, names, patronymics of such persons, their gender, age, place of registration and residence, contact details), photos, video images of the User (and/or the User's authorized representative, etc;)
- information received by the Company in a legal way from partners and/or third parties.
The Company may also process Data using the following technologies:
1) Cookies (cookies are a small piece of data that is sent to the User's computer when accessing a web page and/or viewing an advertising module on a web page and stored on the User's computer and/or mobile device);
2) pixels (pixels - digital images, an element of the display matrix that forms an image), which allow tracking the frequency of use of the web page by the User in order to determine the User's browser and provide the service, for example, storing Data in the shopping cart between visits, as well as to eliminate errors in the Marketplace initiated by the User. At the same time, all information is processed "as is" and does not change in the process of collecting the Data.
3. Use, exchange and purposes of Data processing
The Company uses and processes the Data for the following purposes:
- to perform the functions, powers and duties assigned to the Company in accordance with the requirements of the current legislation of Ukraine, as well as to ensure the implementation of civil, economic and tax relations;
- to identify the client as the User of the Marketplace, to communicate with the User, including for the provision of services, payment processing, sending, conducting settlement operations, reporting, accounting and management accounting, creating and implementing bonus programs, loyalty programs, sending mailings, e-mail, including for the purpose of sending commercial offers, notifications of promotions and other news of the Made With Bravery Marketplace (https://shop.brave.ua/), as well as other portals / sites with which UAPROM LLC has a partnership and/or common ownership structure and/or common ultimate beneficial owners, and/or to notify the Marketplace Users about financial services provided by third parties and/or partners of UAPROM LLC, in order to improve the quality of services, form ratings, analyze User activity, perform keyword searches, manage traffic on the Marketplace, analyze and predict preferences and interests of Users; conduct research and analytical activities, as well as ensure compliance with the terms of the Marketplace Rules;
-for the purpose of making phone calls and/or sending by means of telephone, through messengers, mail, e-mail newsletters, commercial offers, notifications of promotions, loyalty programs, bonus programs and/or for the purpose of sending messages in the above ways, making phone calls regarding the functioning of the Made With Bravery Marketplace (https://shop. brave.ua/) and/or other portals/sites with which UAPROM LLC has partnerships and/or a common ownership structure and/or common ultimate beneficial owners;
- to ensure that the Company provides online services of the Marketplace, exchange of information.
The Company may exchange Data with the Company's affiliates (companies acting on the basis of common ownership), which may process and use the Data for the purposes specified in Section 3 of this Policy.
The Company does not process data related to race, nationality, political views, religious and other beliefs, or membership in public organizations. Information that characterizes the physiological characteristics of Users, on the basis of which their identity can be established, is also not processed.
The terms of Data processing and storage shall be determined based on the purposes of Data processing, as well as on the terms specified in the agreements concluded with the Users in accordance with the requirements of the current legislation of Ukraine.
4. Conditions for granting access to the Data
The Data is disclosed when Users order goods on the Made With Bravery Marketplace (https://shop.brave.ua/), but only to the extent necessary to identify the User and his/her order.
In some cases, in order to demonstrate the efficiency of the Marketplace and enhance the Marketplace's image, the Company may disclose statistics on the operation of the Users' Personal Accounts without disclosing personal data and information that is a commercial secret.
The Made With Bravery Marketplace (https://shop.brave.ua/), in addition, provides opportunities to use the API of the Youtube service. The personal data of Users using the Youtube API services are processed, stored and transferred in accordance with the Terms of Use of the Youtube API services, available at the following link: https://www.youtube.com/t/terms, as well as in accordance with the Google Privacy Policy, which is available at the following link: https://policies.google.com/privacy.
The Marketplace contains links to other web resources that are not covered by this Policy.
The Company processes the Data on a lawful and fair basis: The Data is not disclosed to third parties and is not distributed without the User's consent, except as provided by the current legislation of Ukraine and only in the interests of national security, economic welfare and human rights, in particular, but not exclusively:
- at the reasonable request of public authorities that have the right to request and receive such Data;
- in case UAPROM LLC has reasonable suspicions that the User has violated the terms of this Policy and/or other contracts and agreements concluded between UAPROM LLC and the User.
The Company reserves the right, in accordance with the requirements of the current legislation of Ukraine, to exchange Data with public authorities in order to: prevent fraud in the Marketplace; resolve disputes and clarify circumstances that are/may cause violation of the current legislation, as well as in case the Company detects illegal actions of Users and/or receives claims, complaints, appeals from third parties.
5. How to change/delete Data or withdraw consent
Users can change/delete personal information (full name, place of actual residence, gender, etc.) at any time, or unsubscribe from receiving notifications, or withdraw consent to the processing of Data through their Personal Account or by sending a message to the email address [email protected] or postal address: 02121, Ukraine, Kyiv, Kharkivske Shosse, 201-203 letter "4G". Upon receipt of such notification and upon termination of use of the Marketplace (https://shop.brave.ua/), the processing of the User's Data will be terminated and his/her Data will be deleted, unless such processing may be necessary in accordance with the requirements of the current legislation of Ukraine.
The functioning of some features of the Made With Bravery Marketplace (https://shop.brave.ua/), which require information about the User, may be suspended from the moment the Data is changed/deleted.
The Company shall process and store the Data for the purposes specified in this Policy for the period necessary to process the Data, but not more than 5 (five) years from the date of the last interaction of the User with the Marketplace.
6. Data protection
When processing the Data, the Company shall apply all necessary technical, organizational, legal measures to protect the Data from unauthorized and/or unauthorized access to such Data, including from changes, deletion, provision, distribution, as well as other illegal actions.
The Company shall monitor the security measures taken on an ongoing basis.
7. Additional terms and conditions
The Company reserves the right to change the terms of this Policy at any time. In this case, the updated version will be posted on the page at: ТУТ МАЄ БУТИ ЛІНКА НА АНГЛОМОВНУ ПОЛІТИКУ. If the User does not agree to the changes, he/she undertakes to immediately cease any use of the Made With Bravery Marketplace website (https://shop.brave.ua/).
UAPROM LLC shall not be liable for any damage or losses incurred by the User or third parties as a result of misunderstanding or misunderstanding of the terms of this Policy.
If the provisions of this Policy, clause or parts thereof are recognized as contrary to the current legislation of Ukraine or as invalid, this fact shall not in any way affect the other provisions of this Policy, they shall remain fully valid and continue to be fully effective and valid, and any other invalid provision or provision that cannot be enforced, without further action by the Parties, shall be deemed amended, corrected to the extent necessary to ensure its validity and enforceability.
The terminology used in this Policy has the same meaning as in the Public Service Agreement (offer) (https://shop.brave.ua/uk/terms-of-service) and the User Agreement https://shop.brave.ua/page/user-agreement, unless otherwise specified.