PRIVACY POLICY

Accepted: 01.11.2024
In this Policy, the following terms are used:
1. Privacy Policy (hereinafter – the Policy) – this document, posted on the Internet at https://zezman.ua/app-privacy-policy/, details what information We collect when You use the Application, how We use such information, and what the methods for protecting Personal Data are.
2. Application Developer, Personal Data Processor – Limited Liability Company “ZEZMAN GROUP”, EDRPOU code: 43501923, located at: 20 Lva Tolstoho St., off. No. 11, Odesa, 65020, Ukraine. The Developer has the right to process Personal Data on behalf of the Owner under the terms and within the limits defined by the Owner.
3. Personal Data Controller – Limited Liability Company “ZEZMAN GROUP”, which determines the purpose of processing personal data, establishes the scope of such data and the procedures for their processing; is the customer of the Application.
4. Application – the ZEZMAN mobile application, downloaded (installed) on Your device from the official internet resources AppStore, Google Play Market.
5. Personal Data – information or a set of information about an individual who is identified or can be specifically identified.
6. Consent to the processing of Personal Data – an active action of the User by installing the Application and undergoing authorization.
7. Personal Data Subject – an individual whose personal data is processed on the basis of and in accordance with their consent.
8. Recipient – an individual or legal entity to whom Personal Data is provided, including a third party.
9. Processing of Personal Data – any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, renewal, use and dissemination (distribution, sale, transfer), depersonalization, or destruction of Personal Data, including with the use of information (automated) systems.
10. Services – electronic services provided by the Company through the Application, the list of which is not exhaustive and, in particular, includes: ordering and paying for parking services, ordering and paying for handyman services, informing about tariffs and paying for utility services, informing about current news, creating and submitting requests to the cooperative, informing about the status of request processing, providing consultations, etc.

1. General Provisions

This Privacy Policy is developed in accordance with the provisions of the current legislation of Ukraine, the Constitution of Ukraine, the Law of Ukraine “On Personal Data Protection” dated 01.06.2010 No. 2297-V with amendments and additions, the Order “On Approval of Documents in the Field of Personal Data Protection” dated 08.01.2014 No. 1/02-14, and other secondary legislation.
The Personal Data Controller pays great attention to the protection of Personal Data, understanding the importance of maintaining data privacy, and collects the minimum amount of information necessary for the Personal Data Subject to use the Application.

2. Legal Basis for Personal Data Processing

The Personal Data Processor, in accordance with the terms and within the limits defined by the Personal Data Controller, and/or the Personal Data Controller processes Personal Data on the basis of and in accordance with one of the following legal grounds:
  1. the direct consent of the User for the purpose of comfortable and high-quality provision of Services;
  2. to ensure the legitimate interests of the Personal Data Controller regarding the Application, provided that these interests do not override the fundamental rights and freedoms of the Personal Data Subject related to data privacy. The Personal Data Controller has a legitimate interest in processing Personal Data, developing the Application, and providing relevant Services to the Personal Data Subject. Furthermore, the Personal Data Controller has a legitimate interest in processing Personal Data to prevent fraud and ensure network and information security.

3. Methods of Data Collection

Personal Data may be obtained by the Personal Data Controller in one of the following ways:
  1. provided by the Personal Data Subject while using the Application, including through authorization and filling out relevant forms within the Application;
  2. provided by the Personal Data Subject through other means;
  3. automatically collected by third-party servers.

4. Types of data being collected

The Personal Data Controller, either personally or with the involvement of the Personal Data Processor, collects and processes Personal Data of the following categories. Taking into account the continuous legitimate strive to improve the Application and the quality of Services, the Personal Data Controller notes that the listed categories of Personal Data are not exhaustive.
4.1. Data of Personal Data Subjects who have undergone the authorization procedure in the Application:
  1. last name, first name, and patronymic;
  2. date of birth;
  3. residential address;
  4. phone number;
  5. email address.
4.2. Data of Personal Data Subjects collected for the purpose of providing specific Services available in the Application:
  1. vehicle registration plate number;
  2. query history;
  3. payment history;
  4. size and schedule of payments;
  5. identification data of the asset for which the relevant personal memorandum has been concluded;
  6. payment information.
4.3. Data of Personal Data Subjects reported by other Personal Data Subjects for the purpose of and within the scope of forming social connections:
  1. last name, first name, and patronymic;
  2. contact phone number;
  3. email address;
  4. type of connection (cohabitant, family member, tenant, etc.).
Confirmation of consent for the Processing of Personal Data in this case is likewise established by installing the Application and completing the authorization process.
4.4. Also, some data may be obtained by the Personal Data Controller through automated systems when the Personal Data Subject uses the Application, such as:
  1. technical device data (device type and model, operating system type and version, unique device identifiers);
  2. connection data (IP address, connection type);
  3. behavioral usage data (usage time, button clicks or interface interactions, performance data, metadata).
In this case, not all of the data mentioned in the paragraph above is Personal Data by its nature; however, in combination with other data, it may be sufficient to identify a natural person and, therefore, is equally subject to special care and protection by the Personal Data Controller.

5. Purposes of Collection and Use of Personal Data

The Personal Data Controller uses the information provided by you only within the scope of specific purposes.
5.1. Provision of Services. The Personal Data Controller uses the information to provide timely and quality access to the Application’s Services. In addition, in order to:
  1. transfer them to the Personal Data Recipient who directly provides the Service to the Personal Data Subject;
  2. complete the payment process for the Service by transferring Personal Data to payment organizations involved in conducting transactions through the Application;
  3. ensure timely informing and high-quality interaction with Personal Data Subjects;
  4. for other purposes provided for by the regulatory legal acts of Ukraine.
5.2. Improvement of the Application. The Personal Data Controller constantly strives to improve the functions of the Application, for which purpose audits and other internal research are periodically conducted.
5.3. Support of Personal Data Subjects. Providing effective customer and technical support in case of problems related to the use of the Application and the provision of Services.
The Personal Data Controller does not collect Personal Data regarding racial or ethnic origin, political, religious or ideological beliefs, data on membership in political parties and trade unions, facts of criminal conviction, as well as data relating to health, sexual life, biometric or genetic data.

6. Retention of Personal Data

The Personal Data Controller uses various means to preserve the confidentiality and integrity of Personal Data, prevent unauthorized use or disclosure of Personal Data, and protect it from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
In particular, the following measures have been developed:
  1. all employees of the Personal Data Controller and Processor are familiarized with the provisions of the legislation of Ukraine on the protection of Personal Data;
  2. differentiation of access rights for internal employees to Personal Data has been implemented;
  3. regular monitoring of Personal Data Processing compliance with the provisions of the legislation of Ukraine is carried out.
Please note that no method of data transmission over the Internet can guarantee a 100% guarantee of preventing information leakage.
The Personal Data Controller stores Personal Data for the period necessary to fulfill the purposes set forth in this Policy.
When determining the duration of such periods, the Personal Data Controller first decides whether it is necessary to collect Personal Data at all, and if such a need indeed exists, the specified Personal Data shall be stored for the period necessary to achieve the purpose of collection, except in cases where the law establishes a different storage duration or if the Personal Data Subject has withdrawn consent for the processing of Personal Data or has sent a request for their deletion.

7. Disclosure of Personal Data

Except as provided in this Policy, the Personal Data Controller does not provide, sell, or disclose Personal Data to third parties.
As previously stated, disclosure of Personal Data may occur to employees of the Personal Data Controller and/or Processor, officials, managers, service providers, and subcontractors within reasonable limits, based on necessity and the purposes set out in this Policy. Such disclosure is carried out on the basis of an agreement concluded with such parties, which includes obligations to ensure all measures for the protection of Personal Data specified in this Policy.
Disclosure of Personal Data may occur:
  1. in cases where it is a direct obligation under the law;
  2. in connection with any current or future legal proceedings;
  3. for the purpose of establishing, exercising, or defending the legal rights of the Data Controller (including for the purpose of providing information to third parties for fraud prevention purposes).

8. Rights of the Personal Data Subject.

According to the Law of Ukraine “On Personal Data Protection” dated 01.06.2010 No. 2297-V, the Personal Data Subject has the following rights regarding their Personal Data, namely:
  1. to know the sources of collection, the location of their Personal Data, the purpose of its Processing, and the location of the Company, or to give an appropriate instruction to authorized persons to obtain this information, except in cases established by the Law of Ukraine “On Personal Data Protection”;
  2. to receive information about the conditions for providing access to Personal Data, including information about third parties to whom their Personal Data is transferred;
  3. to access their Personal Data;
  4. to receive, no later than 30 (thirty) calendar days from the date of receipt of the request, except in cases provided for by the Law of Ukraine “On Personal Data Protection,” a response as to whether their Personal Data is being processed, as well as to obtain the content of such Personal Data;
  5. to submit a justified request to the Company objecting to the Processing of their Personal Data;
  6. to submit a justified request for the Company to amend or delete their Personal Data if such data is being processed unlawfully or is inaccurate;
  7. to protect their Personal Data from unlawful Processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide, or delayed provision of such data, as well as protection against the disclosure of inaccurate information or information that discredits their honor, dignity, and business reputation;
  8. to submit complaints regarding the Processing of their Personal Data to the Ukrainian Parliament Commissioner for Human Rights or to a court;
  9. to apply legal remedies in the event of a violation of the current legislation of Ukraine on Personal Data protection;
  10. to include reservations regarding the restriction of the right to Process their Personal Data when providing consent;
  11. to withdraw consent to the Processing of Personal Data;
  12. to know the mechanism of automated Processing of Personal Data;
  13. to be protected from an automated decision that has legal consequences for them.
To exercise the above-mentioned rights, you may contact the Data Controller at the following address: Ukraine, Odesa, Lev Tolstoy Street, building 20, office No. 11.

9. Resolution of Disputes

In the event of any dispute arising directly from this Policy, the Personal Data Subject is obliged to submit a claim (a written proposal for dispute resolution), which shall be considered within 30 calendar days from the date of its receipt.
In the event that an agreement is not reached, the dispute shall be referred to a court in accordance with the current legislation of Ukraine.

10. Policy Updates

The Data Controller has the right to periodically make changes to this Policy in order to bring it into compliance with the current legislation of Ukraine, as well as with the applicable methods of Processing Personal Data.
When changes are made to this Policy, the Personal Data Subject shall be notified by publication of a new version of the Policy. The changes shall enter into force from the moment of publication, unless otherwise expressly provided by the Policy.
The Personal Data Subject, by continuing to use the Application, provides their explicit consent to the current version of the Policy.

11. Contact Information

ZEZMAN GROUP LLC
65020, Odesa, 20 Lva Tolstoho St, Office No. 11
EDRPOU Code: 43501923
[email protected]
Phone: (048)701-02-88