For Client

Privacy Policy

 

This privacy and personal information Policy (hereinafter referred to as the “Privacy Policy”) is an official and public document of “Applead” LLC (registration data…) represented by the Administration of the web site with the unique address (http://applead.net/) within the global network (hereinafter referred to as the “Administration”), acting as the Owner of personal data who defines the order and terms of collection, accumulation, storage and use of any information (as defined in Art. 1 of the Law of Ukraine No. 2657-XII), including personal data (as defined in Art.2 of the Law of Ukraine No. №2297-VI) that Administration may receive about the User who acts as the Subject of personal data (hereinafter referred to as the “User”) who uses “Applead” LLC web site and web server for the purposes specified in the User Agreement (link to User Agreement) and by means of author’s apps for mobile terminals for Apple iOS or Android in the process of advertising distribution.

 

1.Definitions

 

 Definitions used in this Privacy Policy are formalized in the Civil Code of Ukraine, Law of Ukraine “On Advertising” No. 270/96-VR, Law of Ukraine “On Information” No. 2657-XII, Law of Ukraine “On Telecommunications” No. 1280-IV (as amended on 07.08.2015), DSTU 2226-93 “Automated Systems. Terms and Definitions”, ND TZI 1.1-003-99. “Terminology of information security in computer systems against unauthorized access”, including the following:

 • Privacy policy (or information security policy) means an aggregation of laws, rules, restrictions, recommendations, instructions, etc., that specify the order of information processing.

 • Administration means  the staff members of “Applead” LLC that has an official legal status of owner of personal data authorized by the management of “Applead” LLC to:

     - collect, accumulate, store, process and use personal data and/or other confidential information by means of server software of the web site that has a unique address within the global network (https://applead.net/) and/or when using authors’ software apps for mobile terminals for Apple iOS or Android in the process of advertising distribution;

    - define goals for personal data collection, accumulation, storage, processing, use, and content of User personal data and/or other confidential information;

    - define and execute actions with due regard to personal and confident information

• User means a legal entity (Art.80 of the Civil Code of Ukraine) or legally capable (Art. 30 of the Civil Code of Ukraine) natural person including individual entrepreneurs (Art. 50 of the Civil Code of Ukraine), who interacts with the web server through the interface provided on the web page, registered on the web site with the unique address within the global network (https://applead.net/) and accepted this Privacy Policy.

• Personal data (according to Art. 2 of the Law of Ukraine No. 2297-VI) means “data or an aggregation of data on an individual who is identified or can be precisely identified but having no special risk for rights and freedoms of personal data subjects in accordance with the amendments of Art.7 of the Law of Ukraine No. 2297-VI, provisions of the Law of Ukraine “On Amendments to Certain Legislative Acts of Ukraine on Improvement of the Personal Data Protection System” No. 383-VII dated 03.07.2013, according to which it is prohibited “to process personal data with regard to racial or ethnic origin, political, religious ideological convictions, participation in political parties and trade unions, accusation in criminal offences or conviction to criminal punishment as well as data relating to health or sex life of an individual”.

• The Owner of personal data (as defined in Art. 2 of the Law of Ukraine No. 2297-VI) means “a natural person or a legal entity, who defines the purpose of processing of

personal data, establishes their composition and procedures for processing thereof, unless otherwise provided by the law”.

• The Subject of personal data (as defined in Art. 2 of the Law of Ukraine No. 2297-VI) means “a natural person or a legal entity, whose personal data are processed”.

• The consent of personal data subject (as defined in Art. 2 of the Law of Ukraine No. 2297-VI) means “a voluntary declaration of will, provided by a natural person (if he/she has been properly informed) to grant permission to process his/her personal data in accordance with the purpose of processing, stated in writing or in any other form that allows to conclude that the permission has been granted”.

• The Third Party (as defined in Art. 2 of the Law of Ukraine No. 2297-VI) means “any person, with the exception of the subject of personal data, the owner or the administrator of personal data, and the Commissioner of the Verkhovna Rada of Ukraine for Human Rights, to whom the owner or the administrator transfers their personal data”.

• The processing of personal data (as defined in Art. 2 of the Law of Ukraine No. 2297-VI) means “any action or set of actions such as collection, registration, accumulation, storage, adaptation, alteration, updating, use and dissemination (distribution, sale, transfer), depersonalization, or destruction of personal data which may involve the use of information (automated) systems”.

• Confidential information (as defined in Art. 21 of the Law of Ukraine No. 2657-XII) means “a personal information, as well as information which access is limited by natural person or by legal entity, except the authorities”.

• Web server means a server that serves requests from users (customers) according to HTTP protocol (Hyper Text Transfer Protocol), provides updates, webpage data storage, other servers connection.

• Web page (Web site) means a network information resource, provided to user in the form of HTML document, and has a unique address within the global network.

• Internet address means in effect defined in the Internet International standards for digital and/or symbolic identifier domain names in a hierarchical system of domain names.

• Authorization means an access permission to a user provided by Administration.

• Link (Hyperlink) means an address of another network information resource in the URL (Universal Resource Location) format that thematically, logically or in any other way relates to the document where this link is defined.

• Cookies means a small fragment of data that is sent by the web server to be stored on personal computer or mobile terminal for Apple iOS or Android for further easier access to server.

• “IP address” means a unique User’s network address in a computer network built on IP protocol.

 

2.General Provisions

 

2.1. This Privacy Policy is harmonized with international laws and regulations, drafted in compliance with the Ukrainian Laws, regularly updated with the amendments and supplements introduced by the Civil Code of Ukraine, the Law of Ukraine “On Advertising” No. 270/96-VR (last amended in accordance with the Laws of Ukraine No. 386-VIII (386-19) dated 12.05.2015 and No. 422-VIII (422-19) dated 14.05.2015), the Law of Ukraine “On Telecommunications” No. 1280-IV (as amended on 07.08.2015), the Law of Ukraine “On Copyright and Related Rights” No. 1587-14 3792-12 (as amended by the Law No. 2627-III (2627-14) dated 11.07.2001 with amendments introduced by the Law No. 5460-VI (5460-17) dated 16.10.2012), the Law of Ukraine “On Information” No. 2657-XII (as amended by the Law No. 2938-VI (2938-17) dated 13.01.2011 with amendments introduced by the Law No. 5029-VI (5029-17) dared 03.07.2012), the Law of Ukraine “On Distribution of Copies of Audiovisual Works, Phonograms, Videograms, Computer Programs, Databases” No. 1587-14 (as amended by the Law No. 1098-IV (1098-15) dated 10.07.2003 with amendments introduced by the Law No. 222-VIII (222-19) dated 02.03.2015), the Law of Ukraine “On Protection against Unfair Competition” No. N 237/96-VR dated 01.01.1997 (with amendments and supplements introduced by the Law No. 642/97-VR dated 18.11.1997, the Law No. 783-XIV dated 30.06.1999, the Law No. 2783-III dated 15.11.2001, the Law No. 762-IV dated 15.05.2003 and the Law No. 689-VI dated 18.12.2008), the Law of Ukraine “"On Ratifying the Convention for the Protection of Individuals Regarding Automatic Processing of Personal data and the Supplementary Protocol to the Convention for the Protection of Individuals Regarding Automatic Personal Data Processing by Supervisory Authorities and Transborder Data Flows” No. 2438-VI dated 06.07.2010, as well as standards and regulations of ND TZI 2.5-010-03 “Requirements for Web Page Content Protection Against Unauthorized Access”, ND TZI 1.1-002-99 “General Provisions On Protection of Information in Computer Systems against Unauthorized Access”, ND TZI 1.1-004-2003 “Countermeasures for Scientific and Technical Intelligence” and ND TZI 1.1-005-07 “Protection of Information on the Objects of Information Activity”.

2.2. Registration and User Status are only accessible to natural persons and legal entities specified in Art.30, 50 and 80 of the Civil Code of Ukraine and accepted this Privacy Policy.

2.3. By accepting this Privacy Policy, a natural person or a legal entity, the subject of personal data gives his full and unconditional consent to the collection, accumulation, storage, processing and use of personal data and/or other confidential information for the purposes specified in the User Agreement.

2.4. This Privacy Policy is applicable only for web site that has a unique address within the global network https://applead.net/ used for advertising distribution by means of author’s software apps mobile terminals for Apple iOS or Android.

2.5. Administration shall not bear any legal or other liability for protection of personal data and/or other confidential information on the third party web sites that User may follow by clicking a hyperlink on the web site with a unique address within the global network https://applead.net/. Protection of User personal data or and/or other confidential information on the third parties web sites is subject to the Privacy Policy of these web sites.

2.6. Administration shall not check the completeness, adequacy and verity of the information provided by the User and shall not bear any legal or other responsibility for intentional or unintentional User corruption of personal data and/or other confidential information.

 

3.Subject of Confidentiality

 

3.1. This Privacy Policy shall define and formalize all Administration obligations of non-disclosure and protection of confidentiality of personal data and/or other confidential information provided by the User on Administration request when registering, using web interface and web server software, as well as author’s software apps for mobile terminals for the purposes specified in the User Agreement.

3.2. For the purpose of this Privacy Policy, the Administration shall collect, accumulate, store, process, use and protect the following:

• personal data entered by natural person or legal entity into registration form, particularly last name, first name, email, mobile phone number;

• personal data automatically defined by the server software upon User registration and authorization including User IP address, Cookies, data for browser, visited pages, access time.

 

4. Purposes of Collection, Accumulation, Storage, Processing and Use of User Personal Data and/or Other Confidential Information

 

Administration shall collect, accumulate, store, process and use personal data and/or other confidential information provided by the User for the following purposes:

• Registration and further identification of the registered User when he authorizes on the web site that has a unique address within the global network https://applead.net/ and when User accesses his personal account from the User personal computer, notebook, tablet and mobile terminals;

• provide authorized User with the opportunity to use interface of the web site that has a unique address within the global network https://applead.net/ and server software for the purposes specified in the User Agreement;

• establish User feedback for consultative and information support, notifications, responses, as well as (if necessary) for the confirmation of accuracy and completeness of personal data and/or other confidential information provided by the User;

• payment processing, service provision, etc.

 

5.Conditions, Methods and Terms of Collection, Accumulation, Processing, Storage and Use of User Personal Data and/or Other Confidential Information

 

5.1. Administration shall collect, accumulate, process, store and use personal data and/or other confidential information provided by the User without limitation as to time and in any way accessible and convenient for Administration, not contradicting the applicable Laws of Ukraine.

5.2. Administration shall have the right to transfer the required (limited) volume of User personal data and/or other confidential information to the third parties for service proper functioning and opportunity to use interface of the web site that has a unique address within the global network https://applead.net/ and server software for the purposes specified in the User Agreement.

5.3. Administration shall have the full and unconditional right to transfer User personal data and/or other confidential information on reasoned and legally sound request of the Commissioner of the Verkhovna Rada of Ukraine for Human Rights and the competent public authorities to the extent and in the manner specified by the applicable Laws of Ukraine.

5.4. Administration shall inform User of any loss, disclosure or destruction of User personal data and/or other confidential information (in accordance with the provisions of Art.15 of the Law of Ukraine No. 2297-VI) by email or mobile phone mentioned on the registration form.

 

 6. Obligations of the Parties

 

6.1. The User shall be obliged to:

• provide Administration with User personal data that according to paragraph 2 of Art.6 of the Law of Ukraine No. 2297-VI “ shall be accurate, authentic, and updated where necessary for the stated purpose of their processing”.

• update, change and add (if necessary) personal data and/or other confidential information.

6.2. The Administration shall be obliged to:

• use personal data and/or other confidential information provided by the User only for the purposes specified in Sec.4 of this Privacy Policy;

• collect, accumulate, store, process, distribute, delete or destroy User’s personal data and/or other confidential information in accordance with the provisions of Art. 12, 13, 14 and 15 of the Law of Ukraine No. 2297-VI;

• delete or destroy User’s personal data and/or other confidential information on the request of User or his legal representative, as well as on the request of the competent  authority for protecting the rights of subjects of personal data.

 

7. Liabilities of the Parties

 

7.1. User shall bear full legal liability for validity, accuracy and completeness of personal data and/or other confidential information provided to Administration.

7.2. Administration shall be legally liable for collection, accumulation, storage, processing, use, disclosure, deletion and destruction of personal data and/or other confidential information that comply with the requirements of Art. 12, 13, 14 and 15 of the Law of Ukraine No. 2297-VI.

7.3. Administration shall not bear any legal or other liability if User personal data and/or other confidential information:

• were transferred to third parties in situations specified in items 5.2 and 5.3 of this Privacy Policy;

• were public information before loss or disclosure;

• were disclosed or transferred to the third parties with the permission of User;

• were lost or stolen as a result of hackers break into web server.

 

8. Dispute Resolution

 

8.1. Any legal or other collisions between the Administration and the User shall be resolved through negotiations and agreement conclusion between the Administration and the User up to production before courts of competent jurisdiction.

8.2. Administration shall consider User’s proposals, claims, notes and complaints within 60 days and shall notify the User about their decision and/or taken measures at email address mentioned on the registration form.

 

9. Additional Provisions

 

9.1. Administration shall have the full and unconditional right to change, add or modify the text of this Privacy Policy without prior notice to User and without prior User consent.

9.2. This Privacy Policy shall come into force as it is published and accepted by legal entity or natural person at the moment of User registration on the web site.

9.3. Invalidity of any item specified in this Privacy Policy shall not in any way affect applicability and validity of any other item and/or this Privacy Policy in general.

9.4. Administration considers any proposals, claims, notes and complaints related to internal and external meanings and text of this Privacy Policy at the following email address: submit@applead.net.