PERSONAL DATA POLICY OF STICKER RIDE

Transcription

1 Version of PERSONAL DATA POLICY OF STICKER RIDE This Personal Data Policy (hereinafter the Policy ) contains information about personal data protection implemented by StickerRide Limited, having its office at 7th Floor, 11 Old Jewry, London, EC2R 8DU, United Kingdom (hereinafter "the Company"), that is the operator of the smartphone Application StickerRide (hereinafter the Application ) available at Apple Store and Google Play. The User may use the Application upon registration. During the registration and use of the Application by the User the Company can obtain the User information containing his or her personal data. This Policy regulates the issues related to the protection and processing of personal data of individuals. The definitions used in this Policy beyond those specified in the Preamble of this Policy are determined in the End User License Agreement (hereinafter the Agreement ). 1. GENERAL PROVISIONS 1.1. Personal data refer to any information relating to the User that is voluntarily provided by him or her during the registration in the Application and its use. Personal data may include: Full name of the User; Phone number of the User; Driver s license information; Information about the User s Car and its registration; Other similar information provided by the User as well as his or her photos or videos Along with personal data listed in Article 1.1 herein the User authorizes the Company to collect and process the following data: history of the Company s Website browsing, logs, statistics of actions performed on the Company s Website and in the Application; technical information about the User s devices and their operating systems; IP address and information of the used web browser, access time, search requests, cookies data; information provided by the User when he or she submits request for information or support as well as the information provided to the payment systems including payment amount; geographical coordinates of the User s location and his or her driving routes; other information provided by the User in the course of participation in the promotional activities and surveys Personal data can be collected during the User registration and afterwards (when the User edits his or her information, uses the Application, seeks technical support, receives money). The User hereby allows the Company to collect such personal data The source of information regarding all User s personal data is the User himself or herself. All personal data specified by such person during registration in the Application or in the course of its further use are provided voluntarily by this person. Personal data may be provided by the User or collected automatically by the Application. 1

2 1.5. By filling out the registration form the User gives his or her consent to processing of his or her personal data for the purposes specified in Article 2.1 herein The Company exercises control over personal data and adheres to the policy preventing unauthorized use of personal data collected from the Users The User s personal data are processed by means of the PCs and (or) information technology (IT) based resources in accordance with the organizational procedures and methods directly related to the purposes specified in section 2 herein. In some cases the User data may become available to the particular responsibles of the Company who ensure the functioning of the Application (managers, sales department, marketing department, legal service, system administrators), or external organizations (such as third party technical service providers, postal services providers, hosting providers, IT companies, communication services providers) to which the data processing functions may be assigned by the Company when necessary. The updated list of the persons mentioned above may be obtained from the Company Personal data are retained for one of the following periods, whichever is longer: (i) the Agreement validity period, or (ii) the period required for performance of the Agreement or other contracts entered into pursuant to the Agreement The Company is entitled to amend this Policy at any time with the notification of the Users on the amendments by publishing the relevant information on the Website. In case of disagreement with any amendments of the Policy the User shall cease all use of the Application and may demand from the Company to remove his or her personal data. In the event of use of the data which have been rendered anonimous the removal of such data may be impossible. 2. PURPOSES OF PERSONAL DATA PROCESSING 2.1. The purposes of personal data processing by the Company are as follows: registration of the Users in the Application and their identification in the Application; participation of the Users in the Campaigns; correct representation of the User s data and information related to the use of the Application; further enhancement of the Application and development of new features and services; marketing and statistical studies and other types of research carried out by the Company; contact of the Users by the Company for marketing purposes; responding to the Users requests submitted to the support service, provision of the information about the functions of the Application to the Users, forwarding of the requests concerning the Application The User hereby agrees to the transfer of his or her data including personal data to the Company s affiliated parties and partners for the purposes specified in Article 2.1 of this Policy. 3. MEASURES TAKEN TO ENSURE COMPLIANCE WITH THE LEGAL REQUIREMENTS CONCERNING PERSONAL DATA 3.1. The Company is taking all necessary legal, organizational and technical measures to protect and secure personal data from unauthorized, unlawful or accidental access to them, removal, modification, blocking, copying, provision and distribution of personal data as well as any other illegal actions with respect to personal data which may include: limiting or regulation of the number of employees having access to personal data; familiarizing of the employees, who are directly involved in the processing of personal data, with the provisions of the applicable legislation on personal data, and this Policy; 2

3 password protected access of the Users to the information system storing personal data; control of access to the communication ports, information input-output devices, removable and external data storage devices; antivirus control; usage of firewall; data backup; restoration of personal data modified or removed due to unauthorized access to them. 4. MEASURES TAKEN TO PROTECT AND SECURE PERSONAL DATA 4.1. While processing personal data the Company is taking all necessary legal, organizational and technical measures to protect and secure personal data from unauthorized, unlawful or accidental access to them, removal, modification, blocking, copying, provision and distribution of personal data In order to protect and secure personal data the Company: identifies the threats that menace for the security of personal data during processing; takes organizational and technical measures to ensure safety of personal data; uses information security tools; estimates the efficiency of the measures taken to ensure safety of personal data; detects the events of unauthorized access to personal data and takes adequate measures; restores personal data modified or removed due to an unauthorized access; establishes rules of personal data access, records and registers all actions performed in relation to personal data stored in the information system; controls the measures taken to ensure safety of personal data and the level of protection of the information systems storing personal data. 5. PERSON RESPONSIBLE FOR PROCESSING OF PERSONAL DATA 5.1. The person responsible for organization of personal data processing (hereinafter the Responsible Person ) is the Chief Executive Officer of the Company. The Responsible Person performs the following functions: internal monitoring of the compliance of the Company and its employees with the provisions of the legislation concerning personal data including the legal requirements that regulate personal data protection; informing of the Company s employees about the provisions of the legislation concerning personal data, local regulations for personal data processing, personal data protection requirements; organization of receipt and processing or the Users applications and requests, control of their receipt and processing. 6. USE AND TRANSFER OF USER S PERSONAL DATA 6.1. Unless specified otherwise the Application or the owners of external services engaged by the Application use cookie files (or other tracking technologies) for User identification and recording of the User s global settings only for the purpose of granting the possibility to use the Application In accordance with the applicable law, the Company is entitled to use the User s address for provision of the information about its products and services, as well as similar products and services if the User has not refused to receive such information. 3

4 6.3. Along with the information mentioned in this Policy the Application may provide the User with the additional or contextual information relating to the particular features and services or personal data collection upon request The Application and Company s Website may contain links to third parties and services or goods offered by them. The Company bears no responsibility for the collection of User s data performed by such parties The Company can transfer User s data to third parties only in the following cases: when there is an obligation imposed by the applicable laws, requirements of governmental authorities and law enforcement agencies, or for the purpose of crime prevention; when such transfer is performed to comply with the provisions of the Agreement, to make it possible for the User to use the Application, to ensure safety of other users and persons, to protect the Company s rights and property as well as the rights and property of other users and persons, or in other cases; if the need to perform such transfer arises out of the use of the Application, for example for the purpose of money withdrawal by the User The User hereby agrees that in the above mentioned cases his or her personal data and personal data of the person represented by him or her can be transferred to the countries which are not parties to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data of 28 January USER S RIGHTS 7.1. The User has the right to receive information about the processing of his or her personal data by the Company The User has the right to edit his or her personal data at any time The User may revoke his or her consent to the processing of personal data at any time by sending the relevant notice to the Company The User is entitled to demand from the Company to update, block or remove personal data if they are incomplete, outdated, inaccurate or illegally obtained, or they are recognized as not necessary for the purposes of the processing, as well as resort to legal actions to protect his or her rights The User may request the Company to provide the additional information relating to the collection and processing of personal data For the purpose of enforcement and protection of his or her rights and legitimate interests the User can communicate to the Company by sending an to the address: info@stickerride.com. The Company shall consider any User s applications or complaints regarding personal data, investigate any related events of violation and take all necessary measures to eliminate them, hold responsible any person who is guilty and settle disputes and conflicts through pre-trial negotiations The User is entitled to protect his or her rights and legitimate interests including claiming compensation for his or her pecuniary and / or non-pecuniary damages in court. 8. RESPONSIBILITY 8.1. The control over the compliance with the provisions of this Policy is exercised by the Responsible Person of the Company The employees of the Company who fail due to their own fault to perform their duties related to the processing of personal data may be subjected to penalty in accordance with applicable legislation. 4

5 8.3. The persons guilty of violation of the regulations governing personal data processing and protection of personal data processed by the Company are liable in accordance with applicable legislation. 5