New version updated 9 of May 2019
“Personal Data” - data that directly, or when used in conjunction with other provided data, enables the identification of a specific individual.
“Non-Personal Data” – data in a form that does not, on its own, permit direct association with any specific individual.
“Information” – both Personal and Non-Personal Data.
“Sensitive Data” – Personal Data regarding individual’s: (i) racial or ethnic origin; (ii) political, religious or philosophical beliefs; (iii) membership in political parties and trade unions; (iv) sentencing to criminal penalties; (v) health, sexuality; and (vi) biometric or genetic data.
“Services” – intermediary services in the field of mobile marketing, connection of advertisers with publishers, placement of advertising offers on a platforms, providing other intermediary outsourcing services in the field of mobile marketing, information and software / technology support of the activity of advertising platforms and companies, etc.
“Regulation” – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).
“Law” – data protection and other laws and regulations of Ukraine applicable to the subject matter (including, but not limited to, the Law of Ukraine “On Protection of Personal Data” of 1st of June 2010), and Regulation as determined above.
As you use and/or interact with the Site, we may collect and process Information from and about you. The scope of such Information and our activities regarding it are defined in Sections 1.A, 1.B, 1.C and 2.A below.
Moreover, we may receive and process the Information due to the nature of Services that we are providing to our Commercial Partners (as defined below). This does not apply to you and your use of our Site. The scope of such Information and our activities regarding it are defined in Sections 1.D, 2.B below.
We obtain such Information from various sources described below.
Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so.
If we do combine Non-Personal Data with Personal Data the combined data will be treated as Personal Data for as long as it remains combined.
When you access or otherwise use the Site, we may collect certain Information from you (e.g. through our contact forms). Please, notice that you are not obliged to provide us with such Information. We are asking you not to provide us with Personal Data that is intended for a limited circle of people or that falls under the definition of Sensitive Data. If you decide to provide us with any Information through our contact forms and/or other channels, you voluntarily provide us with your consent to the processing of such Information. Hereby you agree that your consent to the processing of your Personal Data by us does not require any additional notifications from us regarding the transfer of your Personal Data to third parties in accordance with the provisions of Art. 21 of the Law of Ukraine "On Protection of Personal Data".
We may receive the following categories of Information from you.
Contact Information. When you are connecting with us via email, phone and/or our contact forms (such as vacancies forms, blog subscription form etc.), we may receive certain contact information from you, including full name, email address, phone number, location (city) or other similar contact details. As it was mentioned above, the provision of such Information is voluntary and it’s up to you only. We collect such Information in order to be able to respond to your request, question, complaint etc. or to provide you with a requested service (e.g. our newsletter).
NOTE: We are keeping a charitable initiative – TapCare, which supports various social projects on a monthly basis. We provide you with the ability to contact us via the TapCare form on our Site and inform us about the issue with which we can help. However, we are asking you to provide us only with the general description of the problem in order to provide us with the understanding of purpose of your filing and information how to answer to you. Please, do not provide us with any Sensitive Data and/or any third-party individual’s Personal Data. We do not process such categories of Information.
Professional Skills Information. We are providing you with the ability to become the part of our team. In order to apply for a position, you may provide us with your CV via our vacancy form. The provision of such Information is voluntary and it’s up to you only. If you decide to apply for a position, we may receive and process the Information regarding your professional skills, such as, information about your education (degree, specialty), language skills, work experience, other information regarding your professional development, which you decided to provide us with. Your CV also may contain information about your age, citizenship salary expectations, relocation interests. Still we strongly ask you not to put any Sensitive Data in your CV.
Cookies and Similar Technologies. We use “cookie” technology to collect additional website usage data and to improve the Site, the Software and the Services.
Log Data. When you use the Site, our servers automatically record information that your browser sends whenever you visit Site (“Log Data”). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting, language preferences, the web-pages you visit, the search terms you use, and any advertisements you may click on. We use this Information to understand and analyze trends and improve the Site, to administer the Site, to learn about user behavior on the Site and to gather demographic information about our user base as a whole. We may also use this Information in our marketing and advertising services as described below.
Links to Other Websites. The Site may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer/other device, collect data or solicit Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Data you submit to them. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services to which links or access are provided through the Site. We encourage you to read the privacy policies or statements of the other websites you visit.
The Site may contain links to other websites, including Social Media, such as Facebook, Twitter, LinkedIn, Instagram and Telegram. Such links provide you the ability to connect with us through Social Media channels.
Please, notice that when you click on such Social Media links and leave the Site, we do not have any control over such third party Social Media. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services (including Social Media) to which links or access are provided through the Site. We encourage you to read the privacy policies or statements of the other websites you visit.
When you use the Site, or post on forum, chat room, board (if any), or Social Media service, the Personal Data and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the Personal Data you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features. By submitting actions pointed above you grand us, our partners and affiliates a non-exclusive, unlimited, worldwide, royalty-free license to use, display, perform, copy, transmit, distribute, promote, alter, modify, manipulate or create derivative works with materials, texts, words, impressions and other information provided by you in such a way.
If you do not wish to have this information to be shared, do not initiate these connections and actions.
As we are providing Services to our commercial partners, counterparts, customers, related parties, etc. (hereinafter “Commercial Partners”), we may obtain Information about end users of our Commercial Partners’ products (due to the nature of the Services). This does not apply to your use of our Site.
Our Commercial Partners may collect and transfer to us (for the processing under the provision of the Services by us) certain types of Information including Personal Data. This Information covers the information collected from users of our Commercial Partners’ products, software and/or services. We may receive from our Commercial Partners Contact and Account Information (such as user’s full name, email, phone number, mailing address, company name etc.), Billing Information (banking details, PayPal/Payoneer account details), Service Information (such as device and location details), Other Information (that is provided voluntary via the various forms and surveys).
Such Information is received and processed by us under the contractual arrangements between us and our Commercial Partners. We process and store the abovementioned categories of Information for the sole purpose of the provision of Services to our Commercial Partners under the applicable agreements. We adhere to the highest industry standards regarding such processing and retention. We delete such Information as soon as contractual obligations are fulfilled. Our usage and security practices are disclosed in the Sections below.
We may use Information collected from as described above in the Sections 1.A, 1.B, 1.C in the following ways:
Communications. In case if you have contacted us via our contact forms on the Site and/or via the email/phone, we may process Contact Information that you have provided to us to be able to answer your question, request, inquiry or other communication, to organize your participation in interactive features of our services when you choose to do so, to organize your participation in our training programs etc.
Promotional Offers and other Marketing Purposes. We may use Information obtained from you (e.g. your Contact Information) for the Marketing Purposes. For example, by subscribing to our newsletter you may receive tips and announcements straight to your email account. We may also send you promotional material concerning the Site and/or our solutions, services or our partners’ services (which we believe may interest you).
In some of our email messages, pop-ups, banners and other advertising materials we may use a “click-through URL” linked to content on the Site. When users click one of these URLs, they pass through a separate web server before arriving at the destination page on the Site or the Software. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format end users can read, and they tell us whether mail has been opened. We may use this Information to reduce or eliminate messages sent to users/customers.
We may also use Log Data and Information obtained via Cookies and Similar technologies in order to carry out marketing research and to analyze the characteristics of the Site visitors, to assess the impact of our marketing communication and to adjust it to the detected tendencies, to plan our future marketing activities, to prepare analytics for business intelligence, to personalize service and communications for you, to target our advertising.
Analytics, surveys, researches. Service Improvement. From time to time, we may conduct surveys, question forms, test features etc. (“Improvement Activities”), and analyze the data we have to develop, evaluate and improve these features, all in order to improve the Site, our services and solutions and think of new and exciting features for our users. We may use any Information collected from you by such Improvement Activities (including Information obtained with Cookies and similar technologies, Log Data, Service Information, Other Information): (i) to personalize user's experience and to allow us to deliver the type of content and service offerings in which you are most interested in; (ii) to improve our services and solutions; (iii) to administer the Site and to diagnose possible problems; (iv) for statistical and analytical purposes.
We may collect information regarding users’ activities on the Site. This information is aggregated (so no end-user can be identified) and used to help us provide more useful information to our users and to understand which parts of the Site are of most interest.
We may collect information such as occupation, language, zip code, area code, device identifiers, referrer URL, location, and the time zone where Software is used so that we can better understand user/customer behavior and improve the Site and advertising.
Trainings and similar events. In case if you have contacted us via our Mobillionaire form or via forms received at our events, we may process your Contact and Professional Skills Information to invite you and to organize your participation in our training programs and other events. Please note that we reserve right to publish the group photos and videos from our events on our Site, Social Media profiles or other channels for marketing purposes.
Recruitment. If you contact us via our vacancies forms on the Site, we may process your Contact and Professional Skills Information to assist you apply for a job and provide with our help regarding your possible employment in our Company.
Business relations. If you contact us as a representative of our current/potential client or business partner we may process your Contact Information in order to establish/maintain our business relations with you (company, which you represent), to provide you with the details regarding our products, services and solutions, to promote our new products, services and solutions.
Protection of our interests, Safety. We may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of the Site and protect the rights and property of our Company, its users and/or partners.
Compliance with Legal and Regulatory Requirements. We may also use/disclose your Information collected by us in order to comply with applicable legal requirements, industry standards and our policies. We may disclose your Information in situations that we believe to be: (1) emergencies involving potential threats to the physical safety of any person or property if we believe that your Information in any way relates to that threat; (2) you use the Site in a way that we believe may be illegal or inappropriate.
Note: This does not apply to your use of the Site
Provision of the Services. We may use Information received from Commercial Partners in order to provide them with our Services. Such Information may include Contact and Account Information, Billing Information, Service Information. We do not sell, trade, rent or otherwise transfer to outside parties this categories of Information. Our Company commits to only obtain and process Information that is useful and necessary for the goals for which they are being processed.
The purposes and duration of such processing are highlighted in our Commercial Partners’ Privacy Policies.
Note to Users Resident in the European Economic Area: If you are located in the European Economic Area or Switzerland, we may process your Personal Data for the abovementioned purposes when:
We pay particular attention to the protection of Personal Data. We may disclose the Information we collect about you as described herein or otherwise share your information with the following entities, including those outside the European Union or the European Economic Area:
Internal Concerned Parties. We may share your Information with companies, who are our subcontractors, as well as with our employees, in order to provide you with requested Services and/or access to the Site. Our employees have limited access to the Information on a “need to know” basis and are bound with non-disclosure contractual obligations.
Service Providers. We may use third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) to perform certain business-related functions. Examples of such functions include, but are not limited to: data storage services, database maintenance services, analytics services. When we use such third party to perform services on our behalf, we will only provide them with access to Personal Data that they need to perform their specific function. We will make sure that each third party will be required by contract to keep such Personal Data confidential, make necessary steps to protect such Personal Data and not to use it for any purpose other than providing services to us and other provisions as required by law and Regulation.
Our third party service providers are based mainly in the European Economic Area (EEA) and USA. If the Data Subject is located in the EEA or Switzerland, when transferring such Subject’s Personal Data outside the EEA or Switzerland, we will comply with applicable legal requirements for the transfer of Personal Information to countries outside of the EEA or Switzerland and make sure that our third party service providers can guarantee a high level of Personal Data protection. These guarantees may include, e.g. use of standard contractual clauses adopted by the Commission (EU) or participation in the “Privacy Shield” program established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of protection provided by the EU-US Privacy Shield.
We use such third-party service providers:
|Yandex.Metrica||Yandex, LLC||Analyzing Data for marketing purposes and improvement of the Site and Services||https://yandex.ru/legal/confidential/index.html|
|Mixpanel||Mixpanel Inc.||Analyzing Data for marketing purposes and improvement of the Site and Services and maintaining customer/client base and messaging||https://mixpanel.com/legal/privacy-policy/|
|amoCRM||AMORCM, JSC; QSOFT, LLC (parent company)||Maintaining customer/client base and messaging||http://www.amocrm.com.ua/confidence/|
|MailChimp||The Rocket Science Group, LLC||Mailing||https://mailchimp.com/legal/privacy/|
|Linkedin insight tag||Linkedin, LLC||Analyzing Data for marketing purposes and improvement of the Site and Services||https://www.linkedin.com/legal/privacy-policy|
|Facebook Pixel||Facebook, LLC||Analyzing Data for marketing purposes and improvement of the Site and Services||https://www.facebook.com/about/privacy|
|CleverStaff||CleverStaff, LLC||Recruitment management and analytics||https://cleverstaff.net/privacy.html|
|MeisterTask||MeisterLabs GmbH||Project management||https://www.mindmeister.com/ru/privacy|
|Hetzner Online||Hetzner Online GmbH||Data storage and database maintenance services||https://ru.hetzner.com/hosting/legal/datenschutz|
|Servers.com||Servers.com||Data storage and database maintenance services||https://www.servers.com/legal/privacy-policy|
We may also share the Information with other service providers for the abovementioned purposes, with which we will establish cooperation.
Compliance with laws and law enforcement entities. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable Law and Regulation, we may disclose any Information received by us to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of Company or a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Site, our Services and any equipment used to make the Site and Service available, or to comply with the law. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. If we will be required by law to disclose any of your Personal Data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by applicable law, statute, court or administrative order.
Other Third Parties.v We may also make certain Non-Personal Data available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, statistics and other use. This is not linked to any Personal Data that can identify any individual person.
We will make commercially reasonable efforts to store Personal Data of individuals in the regions where they live or operate in cases if we are required by Law and/or Regulation to do so (e.g. Personal Data of EU citizens in EU or countries acknowledged by relevant authority as having appropriate level of data protection). However, please, note that some data recipients may be located outside the EEA and Switzerland, as it was mentioned above. By submitting your Personal Data, you give us your free unambiguous consent to store your Personal Data (and Non-Personal Data, if applicable) outside of your country of residence (registration, domicile, center of vital interests, economic region, etc.). We will comply with applicable legal requirements for the transfer of Personal Data to countries outside of the EEA or Switzerland. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection. As well, we will ensure that such agreement contains obligation of processor to adopt necessary provisions into his agreements with sub-processors (if any). Moreover, before transferring any Personal Data to third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) we shall make reasonable check of such third party regarding its compliance with law and Regulation.
We use such measures to keep your Information safe:
Employees. We chose our employees after a strict background check regarding their business reputation, whether involved in scandals, etc. Each employee has to take probation during which we check his skills, but also his reliability, honesty, his fit for our corporate culture, law abidingness, etc. We limit access to your Information for our employees on a “need to know” basis. The employee gets access only to that Information that he directly needs to perform his work. Moreover, each employee is bound with contractual non-disclosure obligations (NDA), which will remain in force even after the termination of the relationship between the employee and the Company.
Data transmission between Company’s subdivisions and employees is not allowed, except when directly authorized by the top management personnel or expressly provided in their job description.
Staff training. To make sure Personal Data is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Company. We give our employees a briefing (training) regarding the following: on safety and rules for handling Data (including the requirements of the GDPR); when moving away from the workplace, the employee blocks his/her computer; it is forbidden to install any software on the workstations without the permission of the system administrator; it is forbidden to store Data (in any form) in unprotected locations (environment); it is forbidden to take Data carriers outside the office.
We constantly improve our Data protection mechanisms and methods of training employees.
Access control. We maintain industry-standard physical, electronic and procedural safeguards designed to protect Personal Data in our possession from loss, misuse, and unauthorized access. We provide following security measures: access to the building by an individual card through the security point; access to the offices through code and fingerprint; in different offices there are different codes and fingerprints for access, which allows the employee to enter only to the office assigned to him (access to all offices is provided only to the top management personnel); access to the working computer by password and login (only the employee knows); access to the software with Data only by the employees user ID and password.
Relations with contractors and third party service providers. In addition to abovementioned security measures that we provide when cooperate with third party service providers, we also choose our contractors (subcontractors) on the same principles, on which we select employees. Contractors come for a specific task. They delete all received Data after the job is completed. They also sign the NDA on the same principles as our employees. They receive access only to the Data that is directly necessary for the task.
We choose only those contractors and third party service providers that have long been on the market and have established themselves as exceptional companies with a perfect reputation. An exception may be the need to use a contractor from a completely new sphere in which there is still no established market and companies a long time working on it; in such cases, we will implement all the necessary additional measures of data control and protection, as required by law.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of storage, is 100% secure. While we strive to use commercially acceptable means to protect your Information, we cannot guarantee that the Site or the Data stored during your use of the Services is invulnerable to hacking and will not be subject to a security breach. We make no warranty, guarantee, or representation that the Site is or will be absolutely protected from all viruses, security threats or other vulnerabilities or that your Personal Data and Non-Personal Data will always be secure.
Regarding your Information you are entitled to:
A. the right to express and withdraw consents, including reading or registering cookies,
B. the right to objection, including:
C. the right to access your Data, including obtaining a copy of the Data to be processed (at our choice: in written, or by providing access to your Personal Data on our server (other type of storage), or sending it to you by email or on CD/DVD/other device, or in other applicable way, etc.);
D. the right to rectify (correct) your Personal Data if your Data in our possession is inaccurate or incomplete;
E. the right to delete your Data if your Data is no longer necessary for the purpose for which it was collected, and Company has no grounds for its processing, e.g. based on your consent or legal obligation. Moreover, you may ask to delete your Data at any time, but in such case it may lead to impossibility to use the Site, Service, Platform, Software and/or may lead to termination of our contractual relations with you (if any);
F. the right to transfer your Data provided to us by you in a machine-readable format, e.g. if you want to share it with another service provider;
G. the right to restrict processing of your Personal Data by us.
However, please, note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
In addition to the abovementioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable Law.
In order to fulfill your request, we are required to verify your identity so that your Information does not go to an unauthorized person. In case if you send a relevant request on behalf of company (in cases where Personal Data may be applicable to the company as pointed in Law and/or Regulation), we should be sure you are duly authorized to receive such data about such company and may ask you to provide some additional information or verification.
Company, within ten days of receiving your request, shall provide you with information about the actions taken in connection with your request. Deadline for response to your request is 30 days. Still, if necessary, the deadline for your request can be extended up to 45 days due to the complex nature of the request or the number of requests.
If your request turns out to be unreasonable or excessive, in particular due to its repeated nature, we may request a reasonable fee for the fulfillment of the request or refuse to take action in connection with the request.
In cases of breach of security which lead to unauthorized access to your Personal Data, we will let you and the relevant data protection authority know about this incident without undue delay as soon as we become aware of such breach and make all reasonable efforts to minimize the harm and restore necessary safety measures. We can notify (inform) you about breach of your Personal Data at our sole discretion in the following ways we consider most appropriate: via your contact email, by phone, in national news, on the Site or any other way which allows you to make necessary steps to minimize the possible harm without undue delay. Such notification will include general information about the breach, possible risks and our steps to minimize them – to the extent possible in relevant circumstances. You are solely responsible to notify your third parties if their Personal Data is part of such breach (if you are the one who provided such information to us). Our notifications shall not constitute our acknowledgment of any kind of fault (guilt, liability) for the breach.
We will retain your Personal Data for as long as necessary to provide you with access to the Site and/or the Services (such as subscription to our newsletter or participation in our training program etc.), and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Information at the earliest reasonable time. We make commercially reasonable efforts to store your Personal Data no longer than for 3 months. After such period, we make a revision of it. However, as it was mentioned above, we may delete your Personal Data at any time before such 3-month period terminates, in case if purpose we collected it for is no longer applies. We make no warranties your Personal Data will be available for any specific period of time (3 months, or less or more etc.). Please consider that we have no obligations to notify you when deleting your Personal Data and can do it at our sole discretion.
Please, notice that under applicable regulations, we may keep records containing client/customer/user Personal Data, billing information, communications and anything else as required by applicable laws and regulations or on a basis of legitimate interest (e.g. for defending our interests).
We understand the importance of taking extra precautions to protect the privacy and safety of children accessing the Site. Children under the age of 16, or equivalent minimum age in the relevant jurisdiction, are not permitted to use Site and receive our Services, unless their parent provided verifiable consent. We do not knowingly collect Personal Information from children under 16, or equivalent minimum age depending on jurisdiction. If we learn that we have collected the Personal Data of a child under 16, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible, unless we are obliged to keep such data in order to comply with Law and/or Regulation.
We use the usual types of tracking systems that are a standard practice in advertising, e.g. Google AdWords to track you over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals. As well, be aware that some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
You acknowledge and voluntarily agree that we have no obligation of sending you via email or otherwise any notification regarding such change, though we have right to do so if consider it appropriate (e.g. in the event that the modifications materially alter your rights or obligations hereunder).