PRIVACY AND PERSONAL DATA PROTECTION AND PROCESSING POLICY

This Privacy and Personal Data Protection and Processing Policy (hereinafter referred to as the "Policy") has been developed by the Individual Entrepreneur LIODA Maryna Ihorivna, acting on the basis of the Extract from the Unified State Register of Legal Entities, Individual Entrepreneurs, and Public Organizations (registration number 2 119 000 0000 041091, registration date: March 13, 2020) (hereinafter referred to as the "Site Owner") in accordance with the current legislation of Ukraine, including, but not limited to, the Law of Ukraine "Personal Data Protection" No. 2297-VI dated June 1, 2010, for the purpose of application in the process of business, and shall establish the procedure for obtaining, collecting, accumulating, storing, processing, using, safekeeping and disclosure of Users' personal data on the website located on the Internet at fematch.com (hereinafter referred to as the "Website")

Please read this Policy carefully to understand the principles of User Data processing. This Policy sets out the procedure for the Site Owner to process Data, types of Data collected, purposes of using such Data, interaction of the Site Owner with third parties, security measures to protect Data, conditions of access to Data, as well as contact details for the User to gain access, make changes, block or delete their Data, and address any questions that may arise regarding Data protection.

1. DEFINITIONS

  • Personal Data Database — a named set of organized personal data in electronic and/or card file form.
  • Responsible Person — a designated person who organizes work related to the protection of personal data during their processing, in accordance with the law.
  • Owner of the Personal Data Database — a natural or legal person to whom, by law or with the consent of the personal data subject, the right to process such data has been granted. The owner approves the purpose of processing personal data in this database, establishes the composition of such data, and procedures for their processing, unless otherwise provided for by law.
  • Public sources of personal data — directories, address books, registers, lists, catalogues, and other systematized collections of open information containing personal data, placed and published with the knowledge of the personal data subject. Social media and internet resources where personal data subjects leave their personal data are not considered public sources of personal data (except when the personal data subject explicitly states that personal data are posted for their free distribution and use).
  • Consent of the personal data subject — any documented, voluntary expression of the will of a natural person to grant permission for processing of their personal data in accordance with the formulated purpose of their processing.
  • De-identification of personal data — removal of information that allows identifying a person.

User — a legally capable individual (including, but not limited to, citizen of Ukraine, foreigner, stateless person, individual entrepreneur) who wishes to receive services offered on the Website.

  • Processing of personal data — any action or set of actions carried out in whole or in part in an information (automated) system and/or in personal data files related to collection, registration, accumulation, storage, adaptation, modification, updating, use, and dissemination (distribution, implementation, transmission), de-identification, and destruction of information about an individual.
  • Personal data (hereinafter - "Data") — information or a set of information about an individual who is identified or can be specifically identified.
  • Administrator of the personal data database — a natural or legal person to whom the Owner of the personal data database or the law has granted the right to process such data. A person who is entrusted by the Owner and/or Administrator of the personal data database to perform technical work on the Database without access to the content of personal data is not considered to be the Administrator of the personal data database.
  • Data subject — an individual whose personal data are processed in accordance with the law.
  • Third party — any person, except for the Data subject, the Owner, or the Administrator of the Personal Data Database and competent public authority for protection of personal data, to whom the transfer of personal data is carried out by the Owner or Administrator of the personal data database in accordance with the law.
  • Special categories of data — personal data about racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties and professional associations, as well as data related to health or sex life.
  • For the purposes of this Policy, all definitions mentioned in it shall be used exclusively in the meaning defined in this Policy, regardless of whether these definitions are used in singular or plural, or in other grammatical forms, cases, and/or constructions.
  • All other definitions not specifically mentioned in this Policy shall be construed and interpreted in their literal grammatical meaning, based on provisions of the current laws of Ukraine and customary business practices.


2. GENERAL PROVISIONS

This Policy shall cover activities of the Website Owner both on the Internet and beyond, including Data collected by the Website Owner through various channels such as websites, applications, social media, etc. This Policy shall not apply to websites accessed through hyperlinks on the Website.

The owner and administrator of personal data shall be Individual Entrepreneur LIODA Maryna Ihorivna (taxpayer identification number: 3502212487).

Cookies are used on the Website. With each visit to the Website, the Website Owner may collect information related to devices used by Users and networks they connect to when using related services. This may include information such as: IP address, login information, browser type and version, type and version of browser plugins, operating system, and platform, information about User visits, including the route through URL addresses to, from, or through the Website, products/services viewed or searched for, loading errors, length of visits to specific pages, and more. The Website Owner collects this information using various technologies, including cookies.

A cookie is a small text file stored on User devices when visiting the Website. Cookies may be used on the Website to understand what content interests the User and memorize it if they use the Website again. The Website Owner stores cookies to ensure the technically optimized provision of services. Cookies used by the Website Owner cannot harm User devices. If the User consents to Data processing, this automatically allows the Website Owner using cookies every time the User uses the Website.

3. SOURCES OF PERSONAL DATA

This Policy shall apply to Data that the Site Owner receives from the User or about them from the following sources:

  • The website controlled by the Site Owner under their own domains/URLs and pages launched by the Site Owner on social media such as Instagram, etc.;
  • Email, text, and other electronic messages;
  • Electronic registration forms or similar forms collected by the Site Owner via email or direct use of the website;
  • Marketing research (if feedback is not provided on an anonymous basis).


4. 4.COLLECTION AND USE OF PERSONAL DATA

The Site Owner collects and uses the following Data and information:

  • Personal contact details provided by the User to the Site Owner, enabling the Site Owner to contact such User, such as last name, first name, patronymic, mailing address, email address, social media data, or phone number;
  • User login data, including phone number, email address, login, and password, as well as other Data necessary for servicing Users of the Website, communicating with Users, including when the User contacts the website's support service;
  • Demographic information, such as date of birth, age or age range, gender, and geographical location;
  • Information from the User's computer/mobile device about the computer system or other technological device that the User uses to access the Website or applications, such as IP address used to connect the computer or device to the Internet, type of operating system, type and version of the web browser. If the User accesses the Website through a mobile device, such as smartphone, information collected will also include, where permitted, the unique identifier of the User's device, advertising identifier, geographic location, and similar mobile device data;
  • Any information voluntarily shared by the User with the Site Owner about their experience using services and other products, leaving feedback, comments, contacting customer support, complaints, claims, and other inquiries;
  • Any information from social media, platforms, and video hosting sites that the User publicly shares in social media, platforms, and video hosting sites, or information that is part of the User's profile in social media, platforms, and video hosting sites (e.g., Facebook, Instagram, YouTube, TikTok). To opt-out of providing such information in social media, platforms, and video hosting sites, the User needs to visit the website of the respective social medium, platform, or video hosting service;
  • Information that Users provide to the Site Owner when entering into service agreements by accepting a public offer posted on the Website and/or entering into agreements for additional services on the Website;
  • Information necessary for communication between Website Users, including for order confirmation and processing, receiving and sending messages, posting reviews, comments, and making payments;
  • Data obtained as a result of surveys conducted by the Site Owner and/or third parties, related to improving the provision of Services to Users;
  • Information obtained by the Site Owner as a result of marketing activities.


5.PURPOSES OF COLLECTION, USE, AND PROCESSING OF PERSONAL DATA

The Website Owner shall collect and process data for the following purposes:

  • Website administration, ensuring the website's update and technical support of services;
  • Creation and identification of User Accounts;
  • Contacting users to provide services, process payments, conduct financial transactions, implement user protection programs, and send postal or email newsletters, including commercial offers, announcements of promotions, and other news;
  • Analyzing the market and services provided by the Website Owner, improving service quality, forming ratings, analyzing user activity, conducting keyword searches, managing website traffic, analyzing and predicting user preferences and interests;
  • Direct provision of services ordered and/or paid for by the User;
  • Sending email messages upon User request;
  • Reviewing user requests and complaints regarding website usage;
  • Ensuring website security and preventing fraud;
  • Checking compliance with website usage terms, including monitoring personal messages sent through the website if Users are provided with the option of exchanging private messages;
  • Any other purposes necessary for the quality provision of services and ensuring the implementation of civil, commercial, and tax relations.

Additionally, the Website Owner shall use User Data for marketing purposes in accordance with Ukrainian legislation. When using your data for direct marketing purposes (commercial mailings and marketing messages about new products, services, and offers that we believe may be of interest to you), we provide you with the opportunity to opt-out of receiving such messages by sending a request to the email address: info@fematch.com.

6. PROTECTION OF PERSONAL DATA

The Website Owner shall ensure the application of all relevant obligations regarding confidentiality, as well as technical, operational, and organizational security measures to prevent unauthorized or unlawful disclosure or processing of information and data, their accidental loss, destruction, or damage. However, please note that there is no absolutely secure and error-free way to transmit data over the Internet.

The Website Owner shall not be responsible for functioning of servers, Internet service providers, operation of other parties that may cause access to the website to be impossible or restricted, possible leakage of information due to the fault of others, as well as for disclosure of User Data, including authentication data on the website, in application programming interfaces, and applications.

The User acknowledges that in case of their careless attitude to security and protection of their data, including but not limited to personal access identifiers to the account (password, login), other individuals may gain unauthorized access to the account and user data. The Website Owner shall not be held liable for any damages caused by such access.

7. INTERACTION OF THE WEBSITE OWNER WITH THIRD PARTIES REGARDING PERSONAL DATA

The Website Owner shall not transfer data to third parties, except in cases where such transfer is required by law, at the request of the data subject, or in other cases outlined in this Policy.

The Website Owner hereby reserves the right, in accordance with requirements of applicable Ukrainian legislation, to exchange data with government authorities for the purposes of preventing fraud on the website, resolving disputes, and clarifying circumstances that are or may become the cause of violations of existing legislation. This also applies in the event of the Website Owner discovering unlawful actions by website users and/or receiving claims, complaints, and inquiries from other individuals.

The Website Owner understands that personal information is a valuable and integral asset, including personal non-property rights of any individual – the User. Therefore, all possible measures shall be taken to protect personal information voluntarily and consciously provided by Users to the Website Owner.

The website may contain links to other websites (solely for information purposes). When following a link to other websites, the terms of this Policy will not apply to those sites.

However, the Website Owner may transmit information received from users in the course of the services to other individuals for the proper performance of their duties.

In connection with this, the Website Owner recommends reviewing the privacy, protection, and personal data processing policy of each website before providing any personal data that could identify the User.

8. TERMS OF ACCESS TO DATA

Disclosure of data occurs when the User places any text information, as well as graphic/photo/audio/video materials in their user account, proposals to the Website Owner, etc., but only to the extent necessary for User identification. In specific cases, for the purpose of demonstrating the effectiveness of the website and enhancing the owner's image, the Website Owner may disclose statistics of user accounts without revealing data and information that constitutes trade secrets

9. USER RIGHTS

The User shall have the right, in particular, but not exclusively, to:

  • Know about the sources of data collection, location of their data processing, purpose, and procedure of their processing, location or residence (stay) of the data controller or processor, or to give a relevant mandate to authorized persons to obtain this information, except as provided for by the law;
  • Receive information about the terms of access to data;
  • Have access to their data;
  • Present a motivated request to the data controller with objections to processing of their data;
  • Present a motivated request for change or destruction of their data by any data controller and processor if such data are processed illegally or are inaccurate;
  • Protect their data from illegal processing and accidental loss, destruction, damage due to deliberate concealment, failure to provide or untimely provision, as well as protection from providing information that is untrue or discredits the honour, dignity, and business reputation of the individual user;
  • Lodge complaints about processing of their data with the Authorized Representative of the Verkhovna Rada of Ukraine for Human Rights or the court;
  • Apply legal protection measures in case of violation of personal data protection laws;
  • Make reservations regarding limitation of the right to process their data when giving consent;
  • Withdraw consent for data processing;
  • Know the mechanism of automated data processing.

10. USER RESPONSIBILITIES

The User shall, in particular, but not limited to:

  • Not engage in actions aimed at deceiving other users;
  • Not provide access to their data to other individuals if it may result in unauthorized access to the user account or any other negative consequences that may harm the data;
  • Not collect, systematize, store, process, or distribute the personal information of other users;
  • Not attempt to access the data of other users by any means, including but not limited to deception, abuse of trust, or use of authentication and identification data.

If a user registers on the website, in application programming interfaces, or applications on behalf and in the interests of other individuals or uses the website by providing their data, by giving such consent, the user confirms that they have sufficient authority to take such actions, including providing consent on behalf of such individuals for data processing under conditions outlined above, as their representative.

11. CHANGES TO PRIVACY AND PERSONAL DATA PROTECTION AND PROCESSING POLICY

Periodically and without prior notice to users, changes and additions may be made to this Policy, including when there are changes in legal requirements. If the Website Owner changes the way user data are processed, they will update this Policy. The Website Owner also reserves the right to make changes to the approaches to data processing and to this Policy at any time.

If any provisions of this Policy, clauses, or parts thereof are deemed to contradict the current laws of Ukraine or are considered invalid, this shall not affect other provisions of this Policy. They shall remain fully valid and effective, and any other invalid provision or provision that cannot be executed shall be deemed amended to the extent necessary to ensure its validity and enforceability without further action by the parties.

12. PERSONAL DATA STORAGE PERIOD

The User's consent for the processing of data shall be valid for an indefinite period. Data storage period shall be unlimited. User data shall be processed for a period not longer than necessary for their lawful purpose and the purposes defined by this Policy.

The information posted on the website is protected by the current laws of Ukraine, governing intellectual property rights. Reproduction, translation, archiving, copying to other electronic media of the information posted on the website shall be prohibited.

13. USER CONSENT

By registering on the website, in application programming interfaces (APIs), and applications, the data subject (User) provides their consent, thereby confirming that they are familiar with and agree to the terms of this Policy. This includes the processing of data outlined in this Policy, as well as the rights granted to Users (data subjects) in accordance with the current laws of Ukraine, and the use of data by the Website Owner. This consent is given by activating the "Register" button through the website form and/or checking the box in the "I Agree with the Public Offer and Privacy Policy" field.

The User shall not have the right to use the website if they do not agree with the terms of this Policy.

To update, access, make changes, block, or delete their data, revoke consent for data processing given to the Website Owner, or in case of any comments, wishes, or claims regarding the processed data, the User shall send a relevant request to the email address: info@fematch.com. At the same time, the operation of some website features that require the User's data may be discontinued upon their deletion.

If there are any questions regarding the Privacy Policy, please send an email to: info@fematch.com.