PRIVACY POLICY

Introduction

1. The privacy of the users of the ZEZMAN Group of Companies' websites (hereinafter referred to as the Company) is of great importance to the Company, which makes every effort to ensure the protection of this privacy. These rules explain how the Company uses the personal information of the Website User.

2. The Site Administration is guided by the Ukrainian legislation on the protection of Personal Data.

3. This Privacy Policy has been developed in accordance with the requirements of the Law of Ukraine «On Personal Data Protection» dated June 01, 2010 No. 2297-VI and other regulatory acts of Ukrainian legislation governing legal relations related to the collection, processing, storage of personal data, as well as the right of citizens to privacy and establishes the procedure for obtaining, collecting, accumulating, storing, processing, using, ensuring the protection and disclosure of personal data (hereinafter referred to as «Data«) through the Site, Company resources and/or mobile phones.

4. The Company, taking care of the development of customer relations, realizing the importance of ensuring the protection of the Personal Data of the Site User, in order to resolve possible contradictions and misunderstandings, offers this Privacy Policy. Please read this page carefully. The information contained herein is important for the Website User.

1. DEFINITION OF TERMS

1.1 The following terms are used in this Privacy Policy:

1.1.1. «Site» means a set of web pages and related content available on the Internet, which are united both in content and navigation under a single domain name.

1.1.2. «Site Administration» means employees of the ZEZMAN Group of Companies authorized to manage the Site, acting on behalf of the Site (Company), who organize the processing, storage, editing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions or operations performed with personal data.

1.1.3. «Company» means the ZEZMAN group of companies.

1.1.4. «Website User» — hereinafter referred to as the «User«. This is a person who has access to the Website via the Internet and uses this Website to obtain any information.

1.1.5. «Company Service» — any online or offline tool that allows you to communicate, contact potential customers of the Company and Site Users, or the same services: social networks, messengers, advertising and social events organized by the Company, etc.

1.1.6. «Cookies» — a small piece of data sent by a web server and stored on the user's computer, which the web client or web browser sends to the web server each time in an HTTP/HTTPS request when trying to open the page of the corresponding site.

1.1.7. IP address — a unique network address of a node in a computer network based on the IP protocol.

1.1.8. «Personal Data» means any information relating directly or indirectly to a specific or natural person (personal data subject). Personal Data means any information relating directly or indirectly to a particular User. This may include: first name, last name, 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 Website and other resources of the Company, IP address, data on the devices used by the User (computer, browser type, mobile device operating system), and provided by them through the registration form and/or when filling out their profile on the Website, writing a message and/or feedback, or information received by the Company. Users may provide the Data independently by posting it on the Website 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 otherwise) or the Data may be provided from other sources, for example, User feedback (ratings, comments, confirmation of information) or other information from third parties provided during the submission of claims, complaints and/or dispute resolution, and/or information from publicly available sources on the Internet.

1.1.9. «Processing of personal data» means any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data and other methods of using data.

1.1.10. «Confidentiality of personal data» — a requirement for the Site Administrator or other person who has gained access to personal data to comply with the requirement not to allow their dissemination without the consent of the personal data subject or other legal basis.

2. SUBJECT OF THE PRIVACY POLICY

2.1. By visiting the Website for the first time or communicating through other Internet resources of the Company, the User automatically grants the Company permission to use cookies and other public information specified in social networks, messengers or when visiting the Company's office.

2.2 By using the Website or leaving his/her contact details on the Website, as well as answering the necessary questions in the questionnaire when visiting the Company's offices, the User confirms that he/she consents to the Website Administration and its authorized persons to process his/her personal data. The User shall not use the Website if he/she does not agree to the terms of this Privacy Policy.

2.3. The User gives his/her consent to the Website Administration to process the information received, including collection, systematization, accumulation, storage, clarification (update, correction), use, distribution, depersonalization, blocking, destruction of personal data specified in the questionnaire, for the purpose of measures aimed at forming a database of participants, compiling statistical reports, conducting market research, as well as interacting with the User, including via telecommunication networks, including sending messages via SMS, messenger

2.4. The User confirms his/her agreement that the Website Administration has the right to interact with the User by making direct contacts through various means of communication, including, but not limited to: postal mail, e-mail, the Internet, instant messengers, social networks, etc.

2.5. Personal data permitted for processing under this Privacy Policy includes, but is not limited to, the following information: it may be: first name, last name, 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 Site, IP address, data on the devices used by the User (computer, browser type, mobile device operating system); provided by them through the registration form and/or

2.6. 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 Website Administration shall not be liable for any damages caused by such access.

3. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA

3.1. The Website uses the User's personal data for the following purposes:

3.1.1. identification of the User registered on the Website;

3.1.2. providing the User with effective customer support;

3.1.3. providing the User with personalized Services of the Company;

3.1.4. communication with the User, including sending messages in social networks and messengers, requests and information regarding the use of the Services, the provision of services, as well as processing requests and applications from the User;

3.1.5. improving the quality of the Company's Services, their usability, developing new Services and services;

3.1.6. providing information about goods and services, promotions, responding to inquiries, as well as fulfilling its obligations;

3.1.7. conducting statistical and other research based on impersonal data.

3.2. The Site Administration may exchange data with affiliates of the Site Administration (companies acting on the basis of joint ownership), which may process and use the Data for the purposes specified in this section of the Privacy Policy.

3.3 The Site Administration does not process data related to race, nationality, political views, religious and other beliefs, membership in public associations. Information characterizing the physiological characteristics of the Users, on the basis of which it is possible to establish their identity, is not processed.

4. CATEGORIES OF DATA COLLECTED

4.1.The categories of Personal Data collected by the Website (independently or through third parties) include: Cookies and data on the use of network resources.

4.2. Personal data may be provided by the User independently or may be collected automatically by the Website during its use. Unless otherwise specified, the Website uses cookies (or other tracking tools) to identify Users and remember the global settings they set.

4.3. The Users are responsible for the Personal Data of third parties that they receive, publish or provide to others using the Website, and confirm that they have the consent of the third party to provide the Data to the Website.

5. METHODS AND TERMS OF PERSONAL DATA PROCESSING

5.1. The processing of the User's personal data is carried out without any time limit in any legal way, including in personal data information systems using automation tools or without using such tools.

5.2. The User agrees that the Website Administration processes the Data on a legal and fair basis: The Data is not disclosed to third parties and is not distributed without the consent of the User, 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 government agencies that have the right to request and receive such data, or if the Site Administration has reasonable suspicion that the User has violated the terms of this Privacy Policy and/or other contracts and agreements concluded between the Administration and the User.

5.3. The Website contains links to other web resources when Users navigate to them, which are not covered by this Privacy Policy.

6. USER RIGHTS

6.1. Users have the right to:

6.1.1. to find out whether their Personal Data has been stored;

6.1.2. contact the Website Administration to find out about their content and origin;

6.1.3. verify their accuracy or ask to supplement them;

6.1.4. delete, update or correct Personal Data;

6.1.5. object to their processing on all legal grounds without exception.

6.2. Relevant requests should be sent to the Site Administration at the address indicated in the contact information on the Site.

7. POLICY ON COOKIES

7.1. The Site collects information about the User's visits to the Company's websites in order to obtain statistics on visits and the effectiveness of their use, to form a personalized approach and adapt to the interests of each user. The Company does this with the help of various technologies, one of which is cookies. This is data that the website can send to the User's browser and will be stored on the User's computer for further identification by the website.

7.2. Cookies are used to evaluate the effectiveness of websites (for example, to measure the number of visitors and the duration of their stay on the Website), to identify the most interesting and visited topics and pages, as well as to ensure the convenience of navigation and use of the Website, without collecting any personal information. Cookies can also be used to form a personalized approach based on the User's existing experience of interaction with the Website and its preferences. Over time, this information allows us to improve the user experience.

8. SECURITY OF PERSONAL DATA

8.1. The Site Administration takes the necessary organizational and technical measures to protect the User's Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

8.2. If the User follows the links posted on the Website of the latter to the resources of third parties, the Website Administration shall not be liable for his/her actions.

8.3. The User's personal data may be used for legal purposes in court or at the stages leading to a possible appeal to the court because the Website or services were used improperly or the User does not fulfill its obligations.

The User is aware that the Website Administration may be obliged to disclose Personal Data at the request of public authorities.

9. ADDITIONAL INFORMATION ABOUT PERSONAL DATA OF USERS

9.1. In addition to the information contained in this Privacy Policy, the Website may provide the User, upon request, with additional and contextual information regarding specific services and services or the collection and processing of Personal Data.

9.2. In order to ensure the operation of the Website and its maintenance, the Website and any third-party services may maintain files that record the interaction of the Website with Users (system logs), or use other Personal Data (in particular, IP address) for this purpose.

9.3. The User may change/delete the Data or withdraw consent to its processing.

9.3.1 Users can change/delete personal information or unsubscribe from receiving notifications or withdraw their consent to the processing of Data at any time by sending a message to the e-mail address specified in the contact information on the Website.

9.3.2 Upon receipt of such a notice, the processing of the User's Data will be terminated and his/her Data will be deleted, unless such processing may be required in accordance with the current legislation of Ukraine.

10. ADDITIONAL TERMS AND CONDITIONS

10.1. The Site Administration has the right to make changes to this Privacy Policy without the consent of the User.

10.2. The new Privacy Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Privacy Policy.

10.3. In case of disagreement with any changes made to the Rules, the User must stop using the Site and may demand that the Data Site Administration delete his Personal Data.

10.3.1 The Site Administration shall not be liable for any losses or damages incurred by the User or third parties as a result of misunderstanding or misunderstanding of the terms of this Privacy Policy.

10.4. In the event that the provisions of this Privacy Policy, clauses or part thereof, are recognized as contrary to the current legislation of Ukraine, or invalid, this fact will in no way affect the other provisions of this Privacy Policy, they remain fully valid and continue to be in full force and effect, and any invalid provision or provision that cannot be fulfilled without further action by the Parties shall be considered amended, corrected to the extent necessary to ensure its validity and enforceability.