Personal Data Policy

Introduction

PersonaClick Group uses personal information to fulfill its obligations in order to provide a high-quality service.

Because PersonaClick Group treats personal information as confidential information, We ask You to familiarize yourself with Our Privacy Policy.

The policy is elaborated in compliance with international acts based on the “Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data” of the Council of Europe dated 28th January 1981.

I. General definitions

“Personal Data” – any information directly or indirectly is related to a natural person.

The following information is regarded as “Personal Data”: the first and last names, date of birth, e-mail address, address, phone number or any other contact information, Your photo or video image, payment card data, transaction data, bank statements, public utility bills, as well as any other information, directly or indirectly related to a natural person.

 “Processing of Personal Data” – any action (operation) or a chain of action (operation), involving the use Personal Data, including use by means of electronic facilities, inter alia gathering, recording, systematization, accumulation, storage, specification (updating, modifying), extraction, usage, sharing (circulation, provision, access), depersonalization, blocking, deletion, elimination of Personal data.

“Consent” – a statement of a natural person or their representative, containing consent for the processing of their Personal data, including by means of electronic facilities.

II. Principles of Personal Data Processing

PersonaClick Group performs the processing of Personal Data on a lawful and fair basis in accordance with the following principles:

• legitimacy of the purposes and ways of Personal data processing and bona fides;
• accordance of the purposes of Personal data processing with the purposes, previously defined and stated for Personal data gathering;
•  accordance of the volume and type of the processed Personal data, methods of processing with the purposes of Personal data processing;
• accuracy of Personal data, its sufficiency for the purposes of processing, inadmissibility of the processing of Personal data, excessive towards the aims, stated for Personal data gathering;
• inadmissibility of consolidation of Personal data databases, created for incompatible purposes.

III. Purposes of Gathering, Processing and Use of Personal Data

The main purposes of gathering, processing and use of Personal data are as follows:

• to fulfill Our obligations;
• to improve the quality of the provided Services;
• to maintain a high level of security;
• to perform identity checks;
• to inform about Our advertising and promotional events;
• to design advertising and/or promotional materials;
• to design and conduct surveys;
• for any other purposes, related to the functioning of PersonaClick Group. 

IV. Gathering of Personal Data

1. PersonaClick Group obtains Personal data only from Our Partners and Online retailers providing that Our Partners and Online retailers got the personal consent of the natural person for the processing of their Personal data, or from their representatives.
2. By securing consent of a natural person, PersonaClick Group reserves the right to obtain Personal data from a third party. In case of absence of such consent, PersonaClick Group may notify the natural person about the necessity of obtaining this information stating purposes, expected sources and ways of obtaining Personal data, as well as the nature of data and the consequences of a refusal to grant consent for obtaining such data.
3. In the event of changes in a Personal Data he/she shall notify PersonaClick Group about these changes and provide appropriate documents.
4. PersonaClick Group has the right to gather, store, circulate and use Personal Data, as well as the information about the private life of the individual, provided that this information has already been released to public or disclosed by the individual himself or at his/her own will.

V. Processing and Sharing of Personal Data

1. While processing Personal Data PersonaClick Group ensures accuracy of the Personal Data, its sufficiency, and whenever necessary its relevance towards the purposes of Personal data processing. PersonaClick Group undertakes all necessary measures, or secures their taking to delete or specify incomplete or inaccurate data.
2. To achieve the purposes stipulated by the present Personal Data Policy, PersonaClick Group reserves the right to share Your Personal data with Our trusted partners.

VI. Cross-border Sharing of Personal data

Since PersonaClick operates in different countries, by using Our Services, You guarantee that You have necessary consent of natural person for cross-border sharing, including jurisdictions with underdeveloped Personal data protection legislation. However, PersonaClick Group endeavours to provide high standards of Personal Data protection by Our partners regardless of their location.

VII. Personal Data Storage

PersonaClick Group stores Personal Data in a form that allows to identify a natural person, as long as it is required for the purposes of Personal Data processing. The processed Personal Data are subject to deletion or depersonalization upon accomplishing of the purposes or in case accomplishing of the purposes is no longer required.

VIII. Personal Data Protection

To ensure Personal Data protection PersonaClick Group takes the following steps:

• security equipment;
• hardware facilities and software packages for data protection;
• the list of the personnel, whose responsibilities require access to the Personal Data, is strictly restricted and regulated;

IX. Restrictions

At any time a natural person may restrict the usage of his/her Personal Data for advertising and promotional activities. If a natural person has any concerns regarding Our use of Personal Data, such a natural person may contact Us in accordance with the procedure specified by the Terms and Conditions.

X. Personal Data Disclosure

PersonaClick Group does not disclose Personal Data, except for the cases, stipulated by the Privacy Policy.

XI. Final Provisions

1. By clicking “Confirm” or “I Agree”, as well as by a continued use of Our Services, You confirm that You fully understand the content of the Personal Data Policy and that You personally, freely, knowingly, willfully and for your own benefit accept it in the form it is presented on Our website with all amendments that may be introduced to it. The amendments that are introduced to the Personal Data Policy will be immediately published on Our website, therefore We highly recommend You to visit this web-page on a regular basis.
2. Personal Data Policy, Terms and Conditions, The Privacy Policy, Cookie Policy form an integral part of the Agreement and shall be considered only in conjunction with each other.
3. The original text is composed in English and may be translated into other languages solely for the information purpose. In the event of discrepancies between the versions in other languages and the English version of the Personal Data Policy, the English version shall prevail.