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This Policy in the field of personal data processing and personal information confidentiality (hereinafter referred to as the “Policy”) applies to all information that ADV BIZ Ltd, a company, established and operating in accordance with the laws of the Republic of Cyprus, registered under number HE 353920, located at: Agios Fylaxeos & Christoforou Perevou, 2, Kalia Court, Flat/Office 601, 3025, Limassol, Cyprus, hereinafter referred to as the “Service Organizer”, can receive information about the website visitor (hereinafter referred to as the “Data Subject”) during use of the Website hosted on the Internet at https://offergate.pro/ (hereinafter – the “Service”).

Obtaining access to the Service, as well as using the Service, means the User’s unconditional consent to this Policy and specified therein conditions of its personal information processing. In case of disagreement with these conditions, the User shall refrain from using the Service.

When carrying out its activities, the Service Organizer shall comply with all the conditions and requirements under the current legislation of the Republic of Cyprus, European legislation, including, but not limited to, GDPR, as well as other international legislative acts related to data protection.

The Service Organizer shall ensure the security of personal information received from the Service Users. This Policy is developed in order to indicate a list of data that may be requested from the Service Users, as well as such data processing methods of the Service Organizer. This Policy also indicates the purposes for which the Users’ personal information may be requested or disclosed. Separate agreements with the Users may provide for other purposes for which the Users’ personal information may be requested or disclosed. The Service Organizer may act as the Controller and Data Processor.

This Policy applies to all employees of the Service Organizer, independent contractors, Users, interested parties and all other entities directly or indirectly participating within the scope of the Service Organizer in the personal data processing, including Data Subjects, who visit the Website https://offergate.pro/.

1.TERMS AND DEFINITIONS

1.1.User” is an individual, legal entity, Website Visitor, accepting the terms of this Policy and the End-User License Agreement posted at: https://offergate.pro/terms, who wants to receive the services of the Service Organizer and third parties in accordance with the legal documents of the Service Organizer published on the Website;

1.2.Website Visitor” is a person visited the Website with no intent of posting or accepting the Offer;

1.3.Data Subject” is any person who is the subject of personal data whose personal data is processed by the Service Organizer, including Users, Visitors, independent contractors/ employees and other interested parties;

1.4.User Account”, “Account”, “Personal Account” is a set of data about the User stored in the Service necessary for its authentication (identification), as well as a web interface provided to the User to use the Service and provide access to its personal data and settings. The account is created as a result of the User’s registration.

1.5.Personal data” is the information provided by the Data Subject that allows establishing the identity of the Data Subject. These include name, e-mail address, payment details and other information that the Service Organizer may consider as identifying;

1.6.Data Controller (Controller)” is an individual or legal entity, state body or other authority that independently or together with others determines the goals and means of personal data processing.

1.7.Data Operator (Operator)” is an individual or legal entity, state body, agency or other authority that processes personal data on behalf of the Controller.

1.8.Processing” is any operation or sequence of operations that are carried out with personal data or sets of personal data with or without the use of automatic means, such as collection, registration, organization, structuring, storage, adaptation or change, search, use, disclosure by transfer, distribution or other provision, alignment or combination, limitation, deletion or destruction.

PRINCIPLES OF PERSONAL DATA PROCESSING

When collecting and processing personal data, the Service Organizer shall adhere to the principles determined by the GDPR. The policies and procedures of the Service Organizer are developed in order to ensure compliance with the principles:

legitimacy

The data controller determines the legitimacy of the grounds before the start of the personal data processing (for example, availability of consent).

fairness

In order to process data fairly, the Controller shall make certain information available to the Data Subjects, as practical. This applies to whether personal data was obtained directly from the data subjects or from other sources.

transparency

Any information regarding the personal data processing shall be accessible and understandable, as well as in plain language.

purpose limitation

Personal data shall be collected for specific, legitimate purposes and not be processed in ways incompatible with these purposes; processing in the public interest, scientific, historical, research or statistical purposes is not considered incompatible with the original purposes.

data minimization

Personal data shall be sufficient, relevant and limited to the extent of required in relation to the purposes for which it is processed.

accuracy

Personal data shall be accurate and, if necessary, updated; all appropriate measures shall be taken to immediately delete or correct personal data that is inaccurate, considering the purposes for which it is processed.

storage restriction

Personal data shall be stored in the form that allows identification of data subjects not longer than it is required for the purposes for which personal data is processed. Personal data may be stored for longer periods, while it is processed solely for the achieving public interest goals, scientific or historical research or statistical goals, provided that the relevant technical and organizational measures required by the GDPR are implemented to protect the rights and freedoms of the Data Subject.

integrity and confidentiality

Personal data shall be processed in such a way as to ensure the proper security of personal data, including protection against unauthorized or illegal processing, as well as from accidental loss, destruction or damage using appropriate technical or organizational measures.

3. USERS’ PERSONAL DATA WHICH THE SERVICE ORGANIZER RECEIVES AND PROCESSES, PURPOSES OF ITS PROCESSING

The Service Organizer collects and stores only that personal data that is necessary for the Service provision and services provision (including performance of agreements with the User). The Service Organizer collects, uses, stores and processes data to increase the level of services provided, creating reliable and safe environment for work with data in accordance with statutory regulations of applicable legislation.

The Service Organizer may use the User’s personal information for the following purposes:

Personal Data

Purposes

Name and surname

It is required for a polite address to the User, for authorization on the Website and in the Service, identification of the party under the agreements with the Service Organizer and Users, compliance with the tax and accounting legislation of the Republic of Cyprus;

E-mail

It is required for creating a User account, subsequent identification and provision of access to customized resources of the Service;

Login (phone number) telegram/skype

It is required for communication with the User, including sending notifications, requests and information regarding the use of the Service, provision of services, as well as processing the User’s requests and applications;

IP address

It is required for the Service Organizer for internal control, to improve operation and content of the Service, prevent and stop any errors that may occur when using the Service, prevent fraud associated with the Service provision, notify the User of the changes in the Service and customized use of the Service (including for ad view).

Creation and maintenance of a reliable and safe environment:

  • Detection and prevention of fraud, spam distribution, other abuses, security violation and other malicious actions;
  • Conducting security violation investigations and risk assessments;
  • Compliance with applicable law;
  • Settlement of any disputes and enforcement of agreements, contracts with third-party service providers;
  • Ensuring compliance with the conditions and norms of other legal documents of the Service Organizer.

Copy of the User’s passport or other document proving its identity – containing its name, surname and the number of the main identity document of the User.

The Service Organizer may need it to identify the User, verify its Account, prevent abuse and violation of the User’s rights or other persons’ rights. For example, the Service Organizer may use this information to confirm the User’s identity if its Account Data is lost and it wants to gain access to its Account.

Confirmation of the accuracy and completeness of personal data provided by the User.

The Service Organizer may, but shall not, take additional verification measures, which the Service Organizer considers reasonable to verify the User Account.

Cookies files

They are required for quick authorization of the User in the Service, for generating statistics and optimizing advertising messages.

Information required for payment of remuneration, billing (payment details)

Depending on the payment method chosen by the User, taking into account the requirements of the payment system specified by the User, as well as fulfillment by the Service Organizer of the mandatory requirements of the tax and accounting legislation of the Republic of Cyprus, the following information may be required by the Service Organizer to pay remuneration to the User:

  • User’s surname, name (name of wallet holder, bank card holder);
  • Date of birth;
  • Address of the place of residence, including: zip code, country, city, street, house and apartment number;
  • Wallet number of the selected payment system (WebMoney, QIWI, ePayments, Yandex.Money), bank card number;
  • Bank card expiry date (year and month)

Personal data of the Website Visitors and Users

Personal Data

Purpose

Technical data that becomes available to the Service Organizer in the process of using the Service: device, device model, device type

The Service Organizer collects information about the User’s devices – computer or other devices used to access the Services. This information about device includes the connection type and parameters, operating system, browser type, IP address, URLs of referral pages and exit pages. The Service Organizer uses this data for internal control in order to improve the Service operation and content, prevent and stop any errors that may occur when using the Service, notify the User of changes in the Service and customize the use of the Service (including ad view).

Browser type and version, type and version of operating system

The Service Organizer uses this data to prevent fraud associated with the provision of services or use of the Service.

The Service Organizer may store the abovesaid information until the User stops using the Service and deletes its Account, unless the storage of personal data is necessary for the Service Organizer to fulfill its legal obligations, to resolve disputes, to fulfill other agreements of the Service Organizer, to support business activity and to continue the Service development and improvement.

4. LEGITIMACY AND TERMS OF THE USER’S PERSONAL DATA PROCESSING AND ITS TRANSFER TO THIRD PARTIES

4.1 Users’ personal data is collected when the corresponding User visits the Website. In this case, personal data is collected in accordance with the consent of the User. Consent is considered granted after the User clicked the button “I agree to the personal data processing” before completing the registration procedure in the Service. By giving consent, the User confirms and accepts all the conditions specified in this Policy.

4.2 The Service Organizer collects information worldwide and stores this information in the EU, the Netherlands. The Service Organizer may transfer, process and store the User’s information outside the User’s country of residence, wherever the Service Organizer or service providers carry out their business activities in order to provide services to the User.

4.3 The Service Organizer does not collect and/ or process sensitive data (personal data revealing racial or ethnic origin, political views, religious or philosophical beliefs, trade union membership, as well as processing genetic data, biometric data in order to only identify an individual, health data, sexual life or sexual orientation data).

4.4 The Service Organizer does not collect from the Data Subjects any other personal data than for the purposes established by this Policy. The Service Organizer also does not collect personal data except for the processing purposes specified in this Policy.

4.5 Collecting and processing the personal data of the Users, Visitors, the Service Organizer acts as a controller, whereupon an appropriate range of rights and obligations arises. The Service Organizer is not a controller or processor of personal data of Third Parties.

4.6 The Service Organizer does not sell personal data to legal entities or individuals.

4.7 It is understood that the Service Organizer transfers personal data based on GDPR. Personal data is transferred for the purposes and on the conditions provided for in this Policy.

4.7 The Service Organizer may provide the Users’ information to third parties for the purposes indicated above. Moreover, these third parties shall adhere to this Confidentiality Policy.

4.8 The Service Organizer may transfer User’s Personal Information to third parties in the following cases:

  • The User has expressly consented to such actions.

The express consent of the User means that the User agrees to the disclosure or transfer of personal data and notifies thereof by clicking the check box before the registration procedure.

  • Data is transferred to third parties, third party service providers.

The Service Organizer contacts various third-party service providers in order to provide services to the Users. Service providers can be located inside and outside the European Economic Area (“EEA”), for example, in the CIS countries. Third-party service providers may:

  • carry out special data verification to prevent fraud and analyze resulting risk situations;
  • carry out the development, maintenance and troubleshooting arisen during the provision of services and operation of the Service;
  • provide services with the help of third parties – third-party platforms and software (for example, through integration with the Service Organizer’s API);
  • provide services for the Users, advertising or payment services.

A third-party service provider may require the User’s personal data to provide its integrated services through the Website or Services, or if the services provided by the Service Organizer to the User are included in the services of third-party providers, for example, payment and transaction processing services, etc.

  • Transfer is provided for by applicable law.

In the framework of the procedure established by legislation, including execution of court decisions or legal requirements, requests of state bodies, to prevent violation and protect the User’s rights and the Service Organizer.

  • Data transfer to affiliated legal entities of the Service Organizer.

Submitting personal data to the Service Organizer, the User agrees that this information is also provided to all affiliated entities of the Service Organizer, that shall maintain its confidentiality and are guided by this Policy.

  • Social networks

Certain personal information of the User can be collected and used to attract potential customers, attract traffic to websites and to promote products or services of the Service Organizer. Social networks are not controlled and not verified by the Service Organizer, therefore, any questions regarding the use of social networks and their User’s personal data processing shall be sent to the owner of social networks or to the data processor or operator.

  • Consolidated data

The Organizer may collect generalized anonymized data of the Users as a result of its own analysis and comparative studies of the Service, but without further sale of certain User personal information. In accordance with this provision, all information is processed anonymously.

  • Researching User Messages

The Service Organizer reserves the right to view, scan or analyze the User’s messages in the Service in order to prevent fraud, assess risks, verify compliance with regulatory requirements, increase the level of service provision and support users. These actions are carried out in strict compliance with applicable legislation and legal documents of the Service Organizer.

5. RIGHTS OF THE USER

The User owns all the following rights and it can exercise them by sending an e-mail to support@offergate.pro or changing the confidentiality settings in the User Account.

5.1. Data Management

The User may at any time update or change (update, supplement) information about it (or part of it) in the User Account. Any inaccurate or incorrect information can also be changed by sending a corresponding request to e-mail: support@offergate.pro.

5.2. Data Access and Copying Information

The User may receive a copy of all information about itself collected and stored by the Service Organizer by sending corresponding request to e-mail: support@offergate.pro.

5.3. Data Storage and Deletion

The Service Organizer stores the User’s personal information for the period required to provide the Services and comply with other obligations. The User may at any time request the deletion of personal data and account. In this case, this user’s information shall be deleted by the Service Organizer as soon as possible and cannot be stored longer than it is necessary for the Service Organizer to fulfill its obligations.

5.4. Consent Withdrawal and Data Processing Restriction

The User may at any time withdraw its consent to personal data collection, storage and processing by sending a corresponding message to the Service Organizer.

The corresponding request for consent withdrawal shall be considered within 72 hours from the moment of withdrawal receipt. After that, the Service Organizer shall make the corresponding decision.

5.5. Objection to Processing

The User may require the Service Organizer not process its personal data for particular purposes by sending a corresponding request to e-mail: support@offergate.pro.

MESURES FOR THE USERS’ PERSONAL DATA PROTECTION

6.1.The Service Organizer shall take all possible measures to ensure the Users' information security and protection from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties. The Service Organizer shall constantly introduce and update confidentiality and security measures to prevent from unauthorized disclosure, transfer or processing of the User’s personal data, including the following:

  • Limited access to the production database at the network level;
  • Limited access to the production database at the processes/ Users’ level;
  • Password policy for access to the production database;
  • Encryption of data transmission;
  • Data encryption in the database (for card data and account data);
  • WAF (web application firewall);
  • DdoS protection;
  • Internal password change policies;<
  • Compliance with PCI Data Security Standard;
  • Wide application of antivirus software.

6.2. If the User knows or assumes that its personal data has been lost, stolen, misappropriated, or otherwise actually or allegedly unauthorizedly used, the User shall immediately contact the Service Organizer.

7. USER’S AGE

7.1. The Service Organizer collects personal data based on consent received from the Data Subjects who have reached the age of 18 years.

7.2. By registering on the Website and giving consent to the Service Organizer, the corresponding User acknowledges that he/she has reached the age of 18 years and has all rights to provide the Service Organizer with consent to the personal data processing.

8. CONFIDENTIALITY POLICY CHANGE. APPLICABLE LAW. FINAL PROVISIONS

8.1. The current version of this Policy is available to all interested parties on the Website.

8.2. The Service Organizer may at any time update and amend the provisions of this Confidentiality Policy. New version of the Confidentiality Policy becomes effective when it is posted, unless otherwise provided by the provisions of the new version of the Confidentiality Policy. The current edition is always on at: https://offergate.pro/policy.

8.3. The law of the Service Organizer’s country is applied to this Policy and relationship between the User and the Service Organizer arising in connection with the application of this Confidentiality Policy.

8.4. The Services can be used only by legally capable persons. If the Service Organizer becomes aware that a person who is not legally capable has provided it with personal information, the Service Organizer shall immediately delete such information.

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