PRIVACY POLICY

KyivApril 26, 2019

This Privacy Policy (“Privacy Policy”) applies to all information that ​«IT INNOVATIONS» SIA may receive from or about the User when using the Android and/or iOS application “ARENA”, as well as the web-site service “ARENA”.

1.TERMS

1.1 The following terms are used in this Privacy Policy:

1.1.1. “Service Provider” (hereinafter referred to as the Provider) means authorized employees acting on behalf of ​«IT INNOVATIONS» SIA that organize and / or process personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) carried out with personal data.

1.1.2. “Personal data” means any information relating directly or indirectly to a specified or identifiable natural person (the subject of personal data).

1.1.3. “Processing of personal data” means any action (operation) or a set of actions (operations) carried out using automation means or without the use of such means with personal data, including the collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transmission (distribution, provision, access), impersonation, blocking, deletion, destruction of personal data.

1.1.4. “Confidentiality of Personal Data” is a mandatory requirement for compliance with the Service Provider or other persons who have access to personal data, to prevent their distribution without the consent of the subject of personal data or the availability of other legitimate grounds.

1.1.5. The ARENA application (hereinafter referred to as the “Application”) is a computer program intended for installation on Android and iOS mobile platforms and distributed by the Provider through the Google Play Market and App Store web-sites.

1.1.6. The site of the “ARENA” Services (hereinafter “the Site”) is a web-site located at https://www.arena.software

1.1.7. “User of Services (“User”) means a person who has access to the Service through the Program.

1.1.8. “IP Address” is a unique network address of a node in a computer network built on the IP protocol.

2. GENERAL PROVISIONS

2.1. The use of the Program by the User and the Site means acceptance of this Privacy Policy and the terms of processing the User’s personal data.

2.2. In case of non-compliance with the terms of the Privacy Policy, the User shall terminate the use of the Program and the Site.

2.3. This Privacy Policy applies only to the Application and the Site. The Provider does not control and is not responsible for the sites of third parties to which the User may access the links available on the Site and / or in the Appendix.

2.4. The Provider does not verify the authenticity of the personal data provided by the User.

3. SUBJECT PRIVACY POLICY

3.1. This Privacy Policy sets the Provider’s non-disclosure obligation and provides a privacy protection regime for personal data that the User is required to provide at the request of the Provider upon registration on the Site and / or in the Appendix when making an order for the purchase of the Goods and / or Services.

3.2. The personal data allowed for processing under this Privacy Policy is provided by the User by completing registration forms on the Site and / or in the Application and include the following information:

3.2.1. surname, name of the user;

3.2.2. contact telephone numbers of the User;

3.2.3. e-mail address (e-mail);

3.2.4. any additional sensitive data that the User leaves on his personal pages within the system;

3.2.5. payment details, card data or other payment systems;

3.3. The Provider protects the Data that is automatically transmitted during the use of the Service:

• IP address;

• cookie information;

• Information about the browser (or other program that accesses the Site);

• access time;

3.4. The provider collects statistics about the IP addresses of their visitors. This information is used to identify and resolve technical problems, to control the legality of financial payments made.

3.5. The provider collects information about the approximate location of the Custom equipment.

3.6. Any other personal information that is not discussed above (shopping history, used browsers and operating systems, etc.) is subject to reliable storage and non-distribution, except as provided for in pp. 5.2. and 5.3. this Privacy Policy.

3.7. When using the Android-based Application, for the various features of the Application, the User may be requested to access the following personal information and resources: 3.7.1. ACCESS_FINE_LOCATION and ACCESS_COARSE_LOCATION – access the exact and approximate location of the User. This access is required to position the User when specifying a geographic binding that may arise when using the Addendum.

3.7.2. READ_PHONE_STATE – access to the status of the phone. This access is required for the payment service using the LiqPay service or other payment systems.

3.7.3. READ_CONTACTS and WRITE_CONTACTS – access to the user’s contacts. This access is required for the inclusion of a call-center telephone number from the list of contacts from which the user’s voice informs.

3.7.4. WRITE_EXTERNAL_STORAGE – access to the data store. This access is required to save photos or videos that are recorded while using the Add-on.

3.7.5. CAMERA – camera access. This access is required to scan markers and QR codes.

4. OBJECTIVES OF PERSONAL INFORMATION OF THE USER

4.1. The User’s personal information may be used by the Provider for:

4.1.1. Identification of the User registered on the Site or in the Appendix for the execution of the order and / or the conclusion of the Agreement for the sale and purchase of the goods in a remote manner.

4.1.2. Providing the User with access to the personal resources of the Site and the Appendix.

4.1.3. Establishing with the User the feedback, including the direction of messages, requests related to the use of the Site and the Annex, the provision of services, processing requests and requests from the User.

4.1.4. Define the location of the User for security, prevent fraud.

4.1.5. Confirmation of the authenticity and completeness of personal data provided by the User.

4.1.6. Creating an account for making purchases, if the User has agreed to create an account.

4.1.7. Notice to the User of the Order and / or Personal Account of the User.

4.1.8. Processing and receiving of payments, confirmation of tax or tax privileges, denial of payment, determination of the right to receive a credit line by the User.

4.1.9. Providing the User with effective customer and technical support in case of problems arising from the use of the Services.

4.1.10. Providing the User with his consent to product updates, special offers, pricing information, newsletters and other information on behalf of the Provider or on behalf of the Provider’s partners.

4.1.11. Conducting promotional activities with the consent of the User.

4.1.12. Allowing the User access to the Provider’s sites or services for the purpose of obtaining products, updates and services.

5. METHODS AND TERMS OF PERSONAL INFORMATION PROCESSING
5.1. The processing of personal data of the User is carried out without limitation of the term, in any lawful way, including in information systems of personal data using automation means or without the use of such means.

5.2. The User agrees that the Provider has the right to transfer personal data to third parties, including courier services, postal organizations, telecommunication operators, solely for the purpose of executing a User’s order made on the Site or in the Annex, including the delivery of the Goods.

5.3. The personal data of the User may be transferred to the authorized bodies of state power of Ukraine only on the grounds and in the manner prescribed by the legislation of Ukraine.

5.4. In case of loss or disclosure of personal data, the Provider informs the User about the loss or disclosure of personal data.

5.5 The Provider shall take the necessary organizational and technical measures to protect the User’s personal information from unlawful or accidental access, destruction, distortion, blocking, copying, distribution, and other unlawful actions of third parties.

5.6. The Provider, in conjunction with the User, takes all necessary measures to prevent damage or other negative consequences caused by loss or disclosure of personal data of the User.

6. LIABILITY OF THE PARTIES

6.1. User must:

6.1.1. Provide information about the personal data necessary for using the Site or the Application.

6.1.2. Update, supplement the provided information about personal data in case of change of this information.

6.2. The provider must:

6.2.1. Use the information received solely for the purposes specified in clause 4 of this Privacy Policy.

6.2.2. Secure the storage of confidential information secretly, do not disclose without the prior written consent of the User, and not to sell, exchange, publish, or disclose other possible ways of transfer of personal data of the User, except for the item. 5.2. and 5.3. this Privacy Policy.

6.2.3. Take precautionary measures to protect the confidentiality of the User’s personal data in accordance with the procedure normally used to protect such information in the current business turnover.

6.2.4. To block personal data relating to the relevant User from the moment the request or request of the User or his legal representative or authorized body for the protection of the rights of the subjects of personal data for the period of verification, in case of detection of inaccurate personal data or unlawful actions.

7. RESPONSIBILITY OF THE PARTIES

7.1. The provider failing to fulfill his obligations is liable for damages incurred by the User in connection with the unlawful use of personal data in accordance with the legislation of Ukraine, except for the cases provided for in subparagraphs 5.2, 5.3. and 7.2. this Privacy Policy.

7.2. In case of loss or disclosure of Confidential Information, the Provider shall not be liable if such confidential information is given:

7.2.1. Became a public domain for its loss or disclosure.

7.2.2. It was received from a third party until it was received by the Provider.

7.2.3. It was disclosed with the consent of the User.

8. RESOLUTION OF THE SUPERVISOR

8.1. Before a lawsuit is filed in disputes arising from the relationship between the User and the Provider, it is mandatory to file a claim (a written proposal for the voluntary settlement of the dispute).

8.2. The recipient of the claim within 30 calendar days from the date of receipt of the claim, in writing informs the applicant of the results of the consideration of the claim.

8.3. If the agreement is not reached, the dispute will be referred to the judicial authority in accordance with the current legislation of Ukraine.

8.4. This Policy of confidentiality and the relationship between the User and the Provider shall be governed by the applicable laws of Ukraine.

9. ADDITIONAL TERMS

9.1. The Provider has the right to make changes to this Privacy Policy without the consent of the User.

9.2. The new Privacy Policy is effective from the moment it is placed on the Site, unless otherwise provided by the new edition of the Privacy Policy.

9.3. The Provider is obliged to notify the updating of the Privacy Policy no later than 5 (five) days before coming into force.

9.3. All suggestions or questions in this Privacy Policy should be communicated to the Provider using the contacts specified on the Site.

9.4. The current Privacy Policy is located at ​https://www.arena.software