2Smart

PRIVACY​ ​POLICY

PLEASE READ CAREFULLY THIS PRIVACY POLICY AS IT AFFECTS YOUR OBLIGATIONS AND LEGAL RIGHTS. THIS PRIVACY POLICY APPLIES TO ALL OUR SERVICES AND/OR PRODUCTS.
This Privacy Policy is an independent legal document. Your rights and obligations when you use the Website (cloud.2smart.com) and/or the Application software (2Smart Cloud) are also defined (may be defined) by the following documents (agreements): Terms of Use, Disclaimer, any other terms we let you know about. This Privacy Policy may contain links to any document listed above. The absence of one document or all of the listed documents doesn’t affect the validity of this Privacy Policy.

SECTION 1 – GENERAL CONDITIONS

Our Privacy Policy governs the privacy terms of using the Website (cloud.2smart.com, hereinafter “Website”) and/or the Application software (2Smart Cloud, hereinafter “Application software” or “Mobile application”), general rules of User’s Personal Data collection, processing, distribution, use and keeping by the Website and the Mobile application Owner.
We follow all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains what information of yours we will collect when you use the Website and/or the Mobile application, how that information will be used, and how we will share and protect the information.
EACH USER MUST CAREFULLY READ AND COMPLY WITH THIS POLICY.
BY USING THE WEBSITE AND/OR THE MOBILE APPLICATION YOU CONFIRM THAT YOU AGREE TO THESE TERMS OF OUR PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR ANY PART OF IT, YOU SHOULD WITHHOLD FROM USING THE WEBSITE AND/OR THE MOBILE APPLICATION. YOU ALSO AGREE THAT YOUR PERSONAL DATA, COLLECTED BY US, IS TRANSFERRED WITH YOUR CONSENT.
You provide and guarantee to us the right to process your personal data, including the right to perform the following actions to process your personal data (fully or partially in an automated system): storing, registration, changing, restoring, and removing. Also you agree that your personal data is included in the personal data base and any additional notification is not required.

SECTION 2 – DEFINITIONS

2.1. In this Privacy Policy the following terms have meanings as described in the Definition section below:
2.1.1. “Website” shall mean the website maintained at cloud.2smart.com and/or all the subdomains of the website «cloud.2smart.com».
2.1.2. “Mobile application” (2Smart Cloud) – is a software application with relevant functional assignment, specified in 2Smart Cloud Terms of Use.
2.1.3. “Personally identifiable information​” (hereinafter – “Personal Information​” or “Personal Data​”) shall mean any information that can be directly associated with a specific person and can be used to identify that person (including the information about Your activities, such as information about Your use of the Website and/or the Mobile application, when directly linked to personally identifiable information, including automatically collected). We do not consider Personal Data to include information that has been anonymized so that it does not identify a specific User.
2.1.4. “Controller” means a legal person, which determines the purposes and means of the processing of personal data.
2.1.5. “Processor” means a natural or legal person, which processes personal data on behalf of the Controller.
2.1.6. “Owner” (“Website Owner”, “Mobile application Owner”) or “Operator” or “we”, ( “us” or “our”) means a legal person (entity) – LLC «TOO SMART TECHNOLOGY» (registration code: 43286855), which owns the exclusive rights for the objects of intellectual property – the Website and/or the Mobile application. LLC «TOO SMART TECHNOLOGY» registered under the legislation of Ukraine (address: 03164, Ukraine, Kyiv, Pidlisna street, 1, office 11).
2.1.6.1. LLC «TOO SMART TECHNOLOGY» is also a legal person, which determines the purposes and means of the processing of personal data and which processes personal data. Accordingly LLC «TOO SMART TECHNOLOGY» is Controller and Processor in the meaning which is specified in paragraphs 2.1.4. and 2.1.5. of this Privacy Policy. However, there is also can be another person which processes personal data on behalf of LLC «TOO SMART TECHNOLOGY» as a Controller.
2.2. The other terms and notions used in this Policy shall be understood in accordance with the Terms of Use (if available), unless other specified in this Privacy Policy.

SECTION 3 — ​INFORMATION WE COLLECT AND​ ​PROCESS

3.1. The User hereby expressly consents to provide to Us, immediately upon Our notice of request, any information (including Personal Data) that We, in Our sole discretion, deem to be required to maintain compliance with any law, regulation or policy.
3.2 Technical (programmatic) means of our Website and/or the Mobile application can collect such Personal Data: first name, e-mail, user location. 3.3. The above mentioned information and documentation, described in paragraph 3.2., may be requested and or collected by us prior to activating Your account on the Website and/or the Mobile application and/or any services available through the Website and/or the Mobile application. Any doubts as to validity, authenticity and genuineness of the documents and information, provided by You shall be considered a valid reason to deny Your access to our Website, the Mobile application and services.
3.4. The User, You hereby expressly consents, represents and warrants that any and all information provided to Us is valid, current, complete and accurate.
3.5. Personal Data Collected from all the Users, including non-registered Users​. We collect the Personal Data from running the Website and/or the Mobile application and use information, provided to Us by You, sent to Us by Your computer, mobile phone, or other access device, which may include Your IP address, device information including, but not limited to, identifier, name, and type, operating system, mobile network information and standard web log information, such as Your browser type, and the pages You accessed on Our Website and/or the Mobile application. You (as a user) give your voluntary and undoubted consent for the collection and processing specified data and its transfer to third parties in order to implement functioning of the Website and/or the Mobile application and its appropriate work.
3.6. We also collect and store such information as: User requests in support regarding the work of the Website and/or the Mobile application, its related services and other issues.
3.7. When You access the Website and/or the Mobile application or use Our products or services We (or Google Analytics or similar service provider on our behalf) may place small data files called cookies on Your computer or other device. We use these technologies to recognize You as our User; customize our Website and advertising; measure promotional effectiveness and collect information about Your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety. You may control the use of cookies within your internet browsers’ settings. If you reject or delete certain cookies, be aware that the performance of the related features and functions of our Websites and services may be impaired.
3.8. YOU AGREE THAT YOUR PERSONAL DATA MAY BE PROCESSED AND STORED BY US OR OUR COUNTERPARTIES DURING THE PERIOD OF TIME THAT IS PRACTICALLY NECESSARY TO FULFILL THE AIMS AND PURPOSES THAT IMPACT WITH FUNCTIONAL PURPOSE OF THE WEBSITE AND/OR THE MOBILE APPLICATION.

SECTION 4 — HOW WE USE YOUR INFORMATION

We use the information we receive from you as follows:
4.1. We collect only the User’s Personal Data that we need for their proper using of the Website and/or Mobile application. In particular, we use Your Personal Data to:
administer Our Website and/or the Mobile application and/or provide services;
develop new products and services;
personalize Our Website and/or the Mobile application for You;
send You technical notices, support and administrative messages;
communicate with You about products, services, promotions, events and other news and information we think will be of interest to You;
monitor and analyze trends, usage and activities in connection with Our Website and/or the Mobile application and/or services;
provide third parties with statistical information about Our Users (but those third parties will not be able to identify any individual User from that information);
verify compliance with the Terms of Use governing the use of Our Website and/or the Mobile application.
4.2. The Website and/or the Mobile application Owner is the only data controller and processor, except for the cases when there is an objective Website (the Mobile application) Owner’s need to control/process or store information at the Website (the Mobile application) Owner’s counterparties or agents.

SECTION ​5 — ​PERSONAL​ ​DATA​ ​PROTECTION​ ​AND​ ​STORAGE

5.1. The Website (the Mobile application) Owner will do any and all efforts and actions prescribed by Applicable Law to store any of Your Personal Data in secrecy by means of, including but not limited to firewalls and data encryption, physical access controls to Our data centers, and information access authorization controls (which are designed to comply with Applicable Law and regulations), authorization of access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities.
5.2. Personal Data of Our users is stored and processed on servers in Netherlands. However, Your Personal Data may be temporarily stored and processed in other jurisdiction, in particular in Ukraine.
5.3. We reserve the right to store, process and transfer Your Personal Data to Our servers in various jurisdictions, where Our facilities and/or Our service providers are located. It may also be processed by staff operating who work for Us and/or for one of Our service providers. Staff may be engaged in the fulfillment of Our services and/or the processing of Your data and/or the provision of support services. By submitting Your Personal Data, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Policy.

SECTION 6 — THIRD​ ​PARTIES

6.1. We may share your personal information with:
service providers under contract who help with parts of our business operations;
Our banking partners;
companies that We plan to merge with or be acquired by (should such a combination occur, We will require that the newly combined entity follow these terms with respect to Your Personal Data);
law enforcement, government officials, or other third parties when We are compelled to do so by a subpoena, court order, or similar legal procedure; or We believe in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of Our policies;
Our Personal Data processing counterparties or agents, hired by or cooperating with Us, whose services are required by Us from the practical point of view;
other third parties — only with Your prior consent or direction to do so.

SECTION 7 — INTEGRATING THIRD PARTY SERVICES AND LINKS TO OTHER WEBSITES

7.1. Our Website and/or the Mobile application may, from time to time, contain links to and from the websites and/or mobile applications of Our partner networks, advertisers, and affiliates (including, but not limited to, websites on which the Website is advertised). If You follow a link to any of these websites and/or mobile applications, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these policies before You submit any Personal Data to these websites or use these services.

SECTION 8 — PROTECTING YOUR CHILD’S PRIVACY

8.1. Our Website and/or the Mobile application are not designed for use by anyone under the age of 13. If you are a child (a person under the age of 13 years), you should withhold from using Our Website and/or the Mobile application. If you are a parent or guardian and believe your child is using Our Website and/or the Mobile application, please contact us to remove your child’s account. We reserve the right to ask you for verification of your relationship to the child before we honor such a request. However, as parent of a child, you should understand that you are legally liable for any actions of your child.
8.2. Some functions of the Mobile application may be available only to persons who have reached the age of full dispositive legal capacity of a natural person.
SECTION 9 -​ ​RETAIN​ ​INFORMATION
9.1. In accordance with applicable laws and as needed to provide services to our Users, we may hold your Personal Data. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. We may retain Your Personal Data for as long as Your account is active. Moreover, Your Personal Data may be hold beyond the abovementioned period till it is indispensable for Us to have relevant information to respond to any issues that may arise later.

SECTION 10 -​ ​SECURITY

10.1. We use relevant electronic and procedural safeguards to protect the privacy of the information you provide to Us from loss, misuse, disclosure, alteration and destruction.
10.2. PLEASE NOTE THAT TRANSMISSION OF DATA OR INFORMATION (INCLUDING COMMUNICATIONS BY E-MAIL) OVER THE INTERNET OR OTHER PUBLICLY ACCESSIBLE NETWORKS IS NOT ONE HUNDRED PERCENT SECURE.

SECTION ​11 -​ ​ PRIVACY POLICY UPDATES AND AMENDMENTS

11.1. We reserve the right to modify or amend this Privacy Policy at any time. You should review this Privacy Policy frequently. Your continued usage of Our Website and/or the Mobile application shall mean your acceptance of those amendments and updates.

SECTION 12 — YOUR RIGHTS AS THE DATA SUBJECT, APPLICABLE LAW

12.1. You as the Personal Data subject have the rights in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679. You agree that the way of implementation of your rights is subject to the terms of this Privacy Policy. The following paragraphs (12.3. and 12.4.) are the way to implement some of your rights under the provisions of the General Data Protection Regulation.
12.2. WE TAKE ALL MEASURES TO COMPLY WITH THE GDPR REQUIREMENTS, HOWEVER, YOU, AS A USER, SHOULD TAKE INTO ACCOUNT THAT THE RELATIONSHIP BETWEEN YOU AND US IS GOVERNED BY THE LEGISLATION OF UKRAINE, IN PARTICULAR THE LAW OF UKRAINE «ON THEPROTECTION OF PERSONAL DATA». UKRAINIAN LEGISLATION IS APPLICABLE LAW UNDER THIS PRIVACY POLICY AND OUR TERMS OF USE.
12.3. “How to remove all of Your Personal Data?”
You have right to require correction of your Personal Data, updating, complete removal or removal of incorrect and/or inaccurate data by sending Us an email to app@2smart.tech. Nevertheless, this request must comply with the aim of using Our Website and/or Mobile application and Our legal obligations.
12.4. “How to prohibit Personal Data processing if you are allow this before? How to get all of Your Personal Data collected by Us?”
If you want to prohibit Personal Data processing or get all of your Personal Data collected by Us, you can send Us a require via email app@2smart.tech.

SECTION 13 — CONTACT US

13.1. If you have any questions regarding this Agreement, please contact us by e-mail – app@2smart.tech.

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