PRIVACY AND PERSONAL DATA PROTECTION POLICY OF WWW.INTEGRITY.COM.UA WEBSITE USERS

Integrity Vision LLC (hereinafter – the “Company”) respects visitors and users of the website www.integrity.com.ua (hereinafter – the “Website”). Therefore, to maintain privacy, to protect and provide appropriate processing of personal data of users/visitors of the Website, the Company has developed and implemented this Policy in the edition of March 16, 2021.

This Privacy and personal data protection policy of www.integrity.com.ua website users (hereinafter – the “Policy”) is developed under the current legislation of Ukraine and the requirements of international rules, including the General Data Protection Regulation (hereinafter “GDPR”). The Company has the right to make changes to the Policy at any time without a separate notice about such changes to the Website users/visitors indicating the redaction date of the Policy.

The Company hereby informs users and visitors of the Website www.integrity.com.ua (hereinafter – “the Website”), what data is collected and how it is used.

This Policy does not apply to other Websites and social media in which links are posted on the Website. Use of any social media or other Internet resources associated with the Company’s Website may also be governed by separate confidentiality regulations or policies posted on relevant websites or social media.

1. Types of information processed

The Company collects, processes and protects personal and non-personal data, as well as uses cookies.

In accordance with art. 2 of Law of Ukraine “On protection of personal data” dated 01.06.2010 No 2297-VI (with further changes and amendments) and p. (2) art. 4 of GDPR, processing of personal data includes collecting, registration, accumulating, storing, adapting, changing, renewal, usage and distribution (sale, transfer), depersonalization, destruction of personal data, including the usage of information (automated) systems.

Personal data – information or collection of information about individuals that is identified, or may be specifically identified. Personal data may include name, surname, date of birth, address, e-mail address, telephone number, education, place of job, position and other identifying information. It also includes the information, which a user/visitor of the Website may provide through the remedy “Online Chat” for communication on the Website. In case of necessity, the Company has the right to process other personal data not listed before, with the full consent of the user/visitor of the Website, or at the initiative of the user/visitor of the Website (in particular, in the form “Feedback” or “Online Chat”).

Personal data may be used by the Company exclusively after the user has permitted to process such data by filling out a registration form. To do this, next to the windows for entering personal data, the Company places a separate window to confirm the user’s consent to the Company’s Policy. After reading the Policy, you must agree to use personal data by clicking on the necessary button (for example, “I consent to the processing of personal data”, “I agree”, etc.).

Personal data of the users/visitors of the Website is stored within the terms stipulated with current Ukrainian legislation and GDPR, in particular, – during the period of need to process such personal data, if it is confirmed by the purpose of processing.

Personal data may be deleted at any time upon the user’s request to the Company. The term for consideration of such application may not exceed 1 (one) month from the date of receipt of the request by the Company.

Besides, any information that the user provides on publicly available resources (blogs, social networks, etc.) and that is publicly available may be collected and used for personalization.

Non-personal data – non-personal information including general information on visiting the Website that is not personal information and does not personally identifies the user. For example, the information about the number of visits to the Website, information about the operating system of the computer/mobile device and the type of browser, type of device, unique device identifier (UDID) or mobile equipment identifier (MEID) of the mobile device, the website where the link to Company and information about the page that the user visited on the Company’s website.

Cookies – the files with a set of non-personal information that is stored in the equipment browser after visiting the Website, and allow the company to track anonymous use of the Website by users, including the use and traffic statistics. But at the same time, cookies do not collect personal data.

The company undertakes to inform visitors/users of the Website about the use of cookies by displaying a notification in a pop-up window immediately after a user visits the Website. After reviewing the information indicated in the pop-up window for the proper operation of the Website on the device, you must accept and agree to the use of cookies, by clicking on the appropriate button in the pop-up window (for example, “allow all cookies”, “ok”, “agree”, etc.).

Cookies are usually divided into session and permanent ones. Session cookies help users to navigate the website efficiently so that once requested during a session, the information should not be requested again. Session cookies are stored in temporary memory and erased when the browser is closed. Permanent cookies store user’s settings for current and future visits (for example, simplify site authorization – allow remember user credentials). They are stored on a computer’s hard drive or a mobile device’s storage and are activated when a user starts the browser.

The company uses permanent cookies to store the information necessary for creating marketing researches without using personal data.

A user may refuse to use cookies or block the previously loaded files on the equipment, but such actions may adversely affect the usability of the Website.

The Company installs a limited period for the usage of cookies. In particular, permanent cookies must be automatically deleted 12 months after installing.

2. Purpose of data collection and guarantees

The company has set out that the legal ground for the processing of personal data of the Website’s users and visitors is consent. Such ground corresponds to cl.1 p.1 art. 11 of Law of Ukraine “On protection of personal data” and cl. (a) of p. 1 art 6 of GDPR.

The Company collects personal data (exclusively on the base of users consent) to use in marketing researches, promotions, marketing mailing, promotional offers, processing requests to the marketing department, sales department and support service. Data collection is also carried out from users who are potential candidates for employment and apply to the person responsible for recruitment to the Company.

The customer’s/user’s consent is provided through clicking on the button “Ok”/“Agree” or through correspondence via “Online Chat”, which is regarded as the automatic consent to the collection and processing of personal data.

By these actions, the user/visitor also confirms that he has sufficient legal capacity under the laws of the country of citizenship/residence to consent to the terms of this Policy. In case of lack of sufficient legal capacity, consent must be given by holders of parental responsibility (parents, guardians, trustees, etc.) who have the full civil capacity and are authorized by the laws of the country of citizenship, residence to provide such consent.

The Company guarantees that the personal data of users/visitors of the Website will not be used for any purpose other than that specified in this Policy.

The Company provides the opportunity for the Website’s users/visitors to refuse marketing mailing and promotional offers. The refuse of personal data use for marketing purposes is provided with feedback, the user/visitor sends the corresponding notice to the Company’s e-mail specified herein.

The Company guarantees that the Website’s user/visitor personal data will not be transferred to third parties, and guarantees to take all necessary measures for personal data protection, except cases provided for by the applicable laws of Ukraine and GDPR (reasoned requests from controlling bodies) and for Integrity Vision LLC legal rights and interests protection.

The exception is the provision of personal data in case if the Company receives an official request from public authorities authorized to collect such information.

3. Storing personal data

The Company guarantees that all necessary measures are taken to protect and avoid unauthorized distribution of personal data.

All files with personal data are encrypted. Access to encrypted personal data is provided to those Company’s employees who directly provide the user with additional information on the Company’s services and products, and provide answers for user’s/visitor’s requests. Such employees are warned about responsibility for the unauthorized distribution of personal data. Disciplinary penalties are applied to employees who violated this Policy or were found guilty for personal data disclosure.

In case of personal data unauthorized disclosure/distribution threat, the user will be notified of such a threat and measures the protection of personal data, which will be taken by the Company.

The user can contact the Company at any time with the request and find out what the user’s data is kept. The request shall be answered within 1 (one) month from the date of receipt by the Company. If the personal data is obsolete and not actual, the user can submit the request and the data will be updated.

The territory of storing and processing the personal data is Ukraine, and other countries of the world, where the Company’s servers and/or servers used by the Company to operate the Website may be located. Any relevant processing and retaining personal data may take place outside the European Economic Area.

4. Targeted advertising

The company may use cookies, Google Remarketing Tag, Facebook Pixel and other advertising technologies to direct users to advertise according to individual interests and preferences.

The User can see personalized Company’s advertising on the Internet, which is based on the interests of the User. This data allows the Company to customize the appeal to the user, as well as to use contextual advertising and personalize the offer of services. The company uses this information to display advertising that may be of interest to the user/potential customer. This process helps the Company evaluate the effectiveness of marketing tools and advertising campaigns. The user can opt-out of targeted advertising by visiting the following sites:

www.aboutads.info/choices/

www.networkadvertising.org/managing/opt_out.asp/

www.evidon.com/

The company draws attention to the fact that even after disabling this feature, the user can still see advertising on the Internet, but it will not be aimed at the individual interests of the User.

5. Contacts

All requests on an understanding of this Policy, applications, notices and offers should be sent to the following e-mail info@integrity.com.ua and/or by telephone: +38 (044) 597 10 70.

The redaction is as of March 16, 2021.