PRIVACY POLICY
This document “Privacy Policy” (hereinafter referred to as the “Policy”) is the terms for processing the Personal information by CONNETY

USER’S CONSENT:
By checking the box “I agree” accompanied with the link to this Policy you (hereinafter also referred to as “User”) with your own free will and for your benefit give your written consent to the processing of User’s Per
Terms and Definitions
  1. Agreement – Agreement on use of the Platform, executed based on Terms of Service that is posted and/or available on the Internet at: connety.com/terms, License Agreement on use of the Products, executed based on the Public Offer that is posted and/or available on the Internet at: connety.com/license as well as other agreements entered into with the User, when it is expressly stipulated by the terms and conditions thereof.
  2. CONNETY Platform (Platform) – means CONNETY’s software platform that includes the Website website www.connety.com, connety.com (including any subdomains and subdirectories), Products and other software applications and databases of CONNETY designed for newsletter delivery and business process automation.
  3. Products means software programs and databases in the form of the Platform’s components and/or the Platform’s functionality that are provided by CONNETY to Users for use under the terms and conditions of the separate license agreement executed pursuant to the Public offer to enter into the license agreement that is posted and/or available in the Internet at connety.com/license.
  4. User – means a person or entity that has entered into the Agreement with CONNETY in an order stipulated therein.
General Provisions
  1. This Policy is an integral part of the Agreement as well as other agreements, when it is expressly stipulated by the terms and conditions thereof. Therefore, when executing the above said agreements by methods defined therein including by registration on the website www.connety.com, connety.com and/or using the Platform you fully accept the terms of this Policy.
  2. Methods of processing of Personal Information include any action (operation) or a combination of actions (operations) with Personal Information including collection, recording, systematization, storage, updating (refreshment, modification), extraction, use, transfer (provision, access) including transfer to the territories of other countries, depersonalization, blocking, deletion, destruction in the purposes established by this Policy with/without the use of automated facilities.
  3. The terms and definitions provided for by the Agreement are used herein, as well as other agreements entered into with the User, unless otherwise provided for by this Policy or follows from the merits thereof. In other cases, the terms used in the Policy shall be interpreted in accordance with the applicable laws, the business practice, or scientific doctrine.
Personal Information
  1. Personal information in this Policy means as follows:
  2. Information that the User provides about him/her on registration or authorization, as well as during further use of the Platform, including personal data of the User.
  3. Data transmitted in a depersonalized form in automatic mode, depending on the settings of the User’s software.
  4. CONNETY is entitled to establish requirements for the composition of the User’s Personal Information, which are mandatory for the use of the Platform. If certain information is not marked by the CONNETY as mandatory, it is provided or disclosed by the User at his/her discretion.
  5. When being registered in the Platform, the User shall provide in the mandatory manner: name and business email.
  6. Publicly available information. By adding information to the profile, the User makes available to an unlimited number of persons, i.e. makes it publicly available some portion of profile information that depends on the User’s settings for displaying profile information in the Platform. By adding (submitting for adding) information to the profile User provides informed consent to access of unlimited range of persons to such information.
  7. CONNETY will not verify whether the User has the necessary consent for the processing of the provided Personal Information in accordance with this Policy, believing that the User acts in good faith, carefully and makes every effort to obtain all necessary agreements of the subjects of personal data.
  8. CONNETY collects and stores data about the User’s activities in the Platform, using log files. In the event that the actions are committed by an logged-in User, such information is related to the User’s profile.
  9. The User understands and accepts the possibility of using third party software in the Platform; as a result, such third party can receive and transmit the data in a depersonalized form as stipulated in the paragraph 2.1.2 hereof.The aforementioned third party software includes the following analytics and advertising services:
  10. ‘Google Analytics’ that collects and processes data according to privacy policy available at: policies.google.com/privacy;
  11. ‘Facebook’ that collects and processes data according to privacy policy available at: web.facebook.com/full_data_use_policy;
  12. The scope and conditions for collecting impersonal data by using third party software are determined directly by its titleholders and may include:
  13. browser data (type, version, cookies*);
  14. operating system data (type, version, screen resolution);
  15. query data (time, source, IP address).
  16. other impersonal information about User’s activity in the Platform.
  17. The scope and conditions for collection and use of impersonal data by these services are determined directly by these services’ providers and governed by the relevant policies available at their websites.
  18. Accepting this Policy as well as applying certain setting in his/her software including settings of device’s operating system, the User agrees with conditions for collection and use of data by the providers of above listed software services.
  19. *Cookies are small text files recording onto the user’s device and containing information about user’s actions in the Internet. Some of these files serve to determine location, others – to save the user’s settings. User at his/her on discretion sets up in user’s browser the parameters of cookies’ use. However, it is not recommended to turn off use of all cookies because in that case User will not be able to use some functionality of the Platform.
Legal basis of processing of Personal information
  1. The legal basis on which CONNETY relies for the use of Personal information includes:
  2. Processing of Personal information where User has given consent for one or more specific purposes;
  3. Processing of Personal information that is necessary for performing a contract to which User is a party;
  4. Processing of Personal information that is necessary for CONNETY to comply with a legal obligation according to applicable law.
Policy with regard to children
CONNETY does not intentionally collect personal data from children younger than 16, it does not request it and does not allow them to use the Platform. Persons under 16 are not allowed to provide personal information including name and e-mail. If CONNETY gets to know that the information was collected from a child under 16, CONNETY shall immediately delete such information. If you think we could have obtained any information from a child or about a child under 16, please, contact us through e-mail indicated below.
Purposes for Personal Information Processing
  1. CONNETY performs processing, including collection and storage of the Personal Information required for entering into and executing agreements with the User.
  2. CONNETY is entitled to use the Personal Information for the following purposes:
  3. Entering into the Agreement on use of the Platform;
  4. Fulfillment of obligations under the Agreement, including provision the User with access to the Platform;
  5. Functionality of the Platform implies processing of User’s profiles. Therefore, when fulfilling the Agreement and rendering the Platform, CONNETY stores, organizes and displays in the Platform the Users’ profiles containing the Personal Information.
  6. Identification of the User within the fulfillment of the obligations under the Agreement;
  7. Providing communication with the User for the purpose of support and improving the quality of the Platform, including by way of notification with the involvement of third parties;
  8. Marketing, statistical and other research based on depersonalized data from the analytics systems stipulated in the paragraph 3.7. hereof for the purpose of improvement of the Platform.
  9. Targeting of advertising and/or informational materials based on depersonalized data from the analytics systems stipulated in the paragraph 3.7. hereof.
User’s Rights to User’s Personal Information
  1. Subject to specific provisions of applicable law, the User has the right:
  2. to be informed about the collection and use of his/her personal data.
  3. to access his/her personal data and have it corrected if it is wrong or incomplete.
  4. to restrict the processing of his/her personal data where the accuracy of the personal data is contested, where the processing is unlawful, and where CONNETY no longer needs the personal data for the purposes for which CONNETY has processed it.
  5. to object to the processing of his/her personal data and also restrict its processing in those instances where CONNETY undertook processing of it in carrying out a task in the public interest or where necessary for our legitimate interest where there is no compelling reason for its continued processing.
  6. to withdraw consent that User had given to the collection and processing of his/her personal data at any time. If User does withdraw his/her consent to the collection and processing of personal data, that withdrawal shall not affect the lawfulness of any processing by CONNETY that is based on the consent User had given before he/she withdrew it.
  7. to obtain the deletion of his/her personal data when it is no longer relevant to the purposes for which it was collected or processed, when User has withdrawn consent and there is no basis for us to continue processing, when User has objected to further processing and there is no compelling interest for continued processing, and when the data was unlawfully processed.
  8. not to be a subject to a decision based solely on automated processing, including profiling, which produces legal affects concerning User or similarly affecting User, except where there is a lawful basis for continued processing.
  9. to receive personal data in a structured, commonly used, and machine readable form for the purpose of data portability in those instances where CONNETY processes by automated means personal data that User has provided.
  10. These rights may be exercised by using the tools CONNETY offers in the Platform or by contacting CONNETY with specific request through the methods described below. CONNETY will address any such requests in a timely manner and according to applicable law. In certain cases, CONNETY may ask User to verify identity before acting on User’s request. If User is unsatisfied with CONNETY’s response, User may refer his/her complaint to the relevant supervisory authority in User’s jurisdiction.
Personal Information Storage Retention
All Personal Information that is collected will be stored only as long as is necessary to accomplish the purpose for which it is collected, and/or as long as is permitted or required by applicable law. Periodically, CONNETY will review its data processing systems to determine whether or not the purposes for the collection and processing of User’s personal data remain valid. That determination will be based on factors that include, but are not limited to, whether or not you are still in contact with CONNETY, whether or not any requests made by User from CONNETY have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between User and CONNETY, and whether or not there is a contractual or legal basis for continuing to retain User’s personal data. Based on that review and any notifications received from data subjects, CONNETY will update its systems.
Requirements for the Personal Information Protection
  1. CONNETY stores the Personal Information and provides its protection against unauthorized access and distribution in accordance with internal terms and regulations.
  2. With regard to the User’s Personal Information, its confidentiality is protected, except for publicly available information (paragraph 3.4 hereof) and other cases when the technology of the Platform provided on its basis or the configuration of the User’s software provides for an open exchange of information with other users of the Platform or with any Internet users.
Transfer of the Personal Information
  1. CONNETY is entitled to transfer Personal Information to third parties in the following cases:
  2. The User expressed his/her consent to such actions, including when the User applies the settings of the used software that specifically allow or do not limit the provision of certain information;
  3. The transfer is performed as the functionality of the Platform and/or necessary in the context of the specificity of the Platform;
  4. In connection with use in the Platform of third party software for collection and processing of User’s data. Specifically, CONNETY may use the third party software for collection and processing of User’s data according to clause 3.7. of this Policy.
  5. Due to the transfer of the Platform to the possession, use or property of a third party, including the assignment of rights under contracts concluded with the User in benefit of such third party;
  6. Upon request of a court or other state authority within the procedure established by law;
  7. To protect the rights and legitimate interests of CONNETY in connection with failure to comply with the agreements entered into with the User;
  8. Transfer of Personal Information to affiliated and unaffiliated companies, including distributors and suppliers of the Platform, operating on behalf of CONNETY. As part of this activity, the interaction of these companies with the User and providing him with information about the Platform, services and other offers of the respective companies that may be of interest to the User, processing payment transactions, filling orders, providing services related to location. Where necessary, third party service providers obtain Personal Information to perform their functions, and CONNETY prohibits them from using Personal Information for any other purpose.
Amendments to and deletion of the Personal Information
  1. The User is entitled at any time to independently edit the Personal Information in his/her account with the Platform.
  2. The User is entitled to delete his/her own account with the Platform or to exercise other rights related to the processing of his/her personal data by sending to CONNETY a request at the address indicated below.
Amendments to the Privacy Policy
  1. This Policy may be amended or terminated unilaterally by CONNETY without prior notice to the User. The new version of the Policy becomes effective after posting on the CONNETY’s Website, unless otherwise provided for by the new version of the Policy.
  2. The current version of the Policy is on the CONNETY’s Website at: connety.com/privacy.