Personal Data Processing Policy

Last updated: November 5th, 2020

1. General provisions

1. This Privacy Policy describes Company policies and procedures on the collection, use and disclosure of User information when using the Service.
2. We use Personal data to provide and improve the Service. By using the Service, User agrees to the collection and use of information in accordance with this Privacy Policy.
3. The Company sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of Personal data, including the protection of rights to privacy, personal and family secrets.
4. The present Privacy policy regarding the processing of Personal data shall apply to all information that the Company may obtain about visitors to the website https://spayz.io/.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy policy:

1. “User” — the individual accessing or using the Service, or the Company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
2. “Company” (referred to as either "the Company", "We", "Us" or "Our" in this Policy) — owner of the website, for more info refer to: info@spayz.io.
3. “Affiliate” — an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
4. “Website” — https://spayz.io/.
5. “Service” — the Website and applications connected hereto.
6. “Service Provider” — any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
7. “Personal Data” — any information that relates to an identified or identifiable individual.
8. “Cookies” — small files that are placed on User’s computer, mobile device or any other device by a website, containing the details of User’s browsing history on that website among its many uses.
9. “Device” — any device that can access the Service such as a computer, a cellphone or a digital tablet.
10. “Usage Data” — data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
11. “Depersonalisation of personal data” - actions making it impossible to determine the ownership of personal data by a specific User or another personal data subject without the use of additional information.
12. “Personal data processing” — any action (operation) or a set of actions (operations) performed with personal data using automation means or without the use of such means, including collection, recording, systematisation, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data.

Types of Data Collected

Personal Data

1. While using Our Service, We may ask User to provide Us with certain personally identifiable information that can be used to contact or identify User. Personally identifiable information may include, but is not limited to:
   • Email address
   • First name and last name
   • Phone number
   • Usage Data - when website also collects and processes depersonalised data about visitors (including cookies) using the Internet statistical services (Google Analytics and others);
2. Data mentioned above is hereafter united by the general concept of Personal data.

Usage Data

1. Usage Data is collected automatically when using the Service.
2. Usage Data may include information such as Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that User visits, the time and date of the visit, the time spent on those pages, unique device identifiers and other diagnostic data.
3. When User accesses the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device, mobile device unique ID, the IP address of mobile device, mobile operating system, the type of mobile Internet browser, unique device identifiers and other diagnostic data.
4. We may also collect information that User’s browser sends whenever User visits our Service or when accesses the Service by or through a mobile device.

Tracking Technologies and Cookies

1. We may use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.
2. User can instruct the browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if User does not accept Cookies, User may not be able to use some parts of our Service.
   Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on the personal computer or mobile device when User goes offline, while Session Cookies are deleted as soon as User closes web browser. Learn more about cookies: All About Cookies.

Legal basis of personal data processing

1. The Company processes the Personal data of the User only in case it is being filled in and/or sent by the User independently via special forms on the website https://spayz.io/. By filling in the appropriate forms and/or sending their personal data to the Company, the User consents to this Privacy policy;
2. The Company processes Depersonalised data about the User if it is allowed in the settings of the User's browser (saving cookies and the use of JavaScript technology is enabled).

Purposes of personal data processing

1. The Company may use Personal Data for the following purposes:
   • To provide and maintain our Service, including to monitor the usage of our Service.
   • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services that User has purchased or of any other contract with Us through the Service.
   • To contact User: To contact by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
   • To provide User with news, special offers and general information about other goods, services and events which we offer that are similar to those that User have already purchased or enquired about unless User have opted not to receive such information.
   • To manage User’s requests: to attend and manage requests to Us.
2. We may share Personal Data in the following situations:
   • With Service Providers: We may share Personal Data with Service Providers to monitor and analyze the use of our Service, to contact User.
   • For Business transfers: We may share or transfer User’s personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
   • With Affiliates: We may share User’s information with Our Affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

Retention of Personal Data

1. The Company will retain Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain Personal Data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
2. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Personal Data

1. Personal Data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of User’s state, province, country or other governmental jurisdiction where the data protection laws may differ than those from User’s jurisdiction.
2. User’s consent to this Privacy Policy followed by submission of such information represents User’s agreement to that transfer.
3. The Company will take all steps reasonably necessary to ensure that Personal Data is treated securely and in accordance with this Privacy Policy. Prior to the start of the cross-border transfer of Personal Data, the Company is obliged to ensure that the foreign state, into the territory of which the transfer of personal data is supposed to be carried out, provides reliable protection of the rights of personal data subjects.
4. Cross-border transfer of personal data into the territory of foreign states that do not meet the requirements above can be carried out only if the personal data subject agrees in writing to cross-border transfer of their personal data and/or in case of the execution of a contract, to which the personal data subject is a party.

Disclosure of Personal Data

Business Transactions

If the Company is involved in amerger, acquisition or asset sale, Personal Data may be transferred. We willprovide notice before Personal Data is transferred and becomes subject to adifferent Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Personal Data in the good faith belief that such action is necessary to:
• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Personal Data

The security of Personal Data processed by the Company is ensured by the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

1. The Company ensures the safety of Personal Data and takes all possible measures to prevent access of unauthorized persons to personal data.
2. Under no circumstances will the User's Personal Data be transferred to third parties, except for cases related to the implementation of the current legislation and Privacy Policy.
3. In case of revealing inaccuracies in personal data, the User can update the data independently by sending a notification to the Company's email address info@spayz.io  marked "Updating of personal data".
4. The period of personal data processing is unlimited. The User can at any moment withdraw their consent to the processing of personal data by sending a notification to the Company via email to the Company's email address info@spayz.io marked "Withdrawal of consent to the processing of personal data".

Detailed Information on the Processing of Personal Data

Service Providers have access to Users’ Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service, like Google Analytics.

Children's Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If User is a parent or guardian and is aware that a child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

Links to Other Websites

1. Our Service may contain links to other websites that are not operated by Us. If User clicks on a third-party link, User will be directed to that third party's site. We strongly advise all Users to review the Privacy Policy of every site they visit.
2. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

1. We may update our Privacy Policy from time to time. We will notify Users of any changes by posting the new Privacy Policy on our Website and update the "Last updated" date at the top of this Privacy Policy.
2. User is advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

1. The User can get any clarifications on issues of interest relating to the processing of their personal data by contacting Us via e-mail info@spayz.io.
2. The current version of the Policy is available for public access on the Internet at https://spayz.io/privacy-policy.