Privacy Policy
Introduction
This document describes the privacy policy of marketexchangers.com (the "Resource"/("Website").
This Policy has been developed by Company as part of its data collection and processing efforts, and to protect the personal information of users and the privacy of individuals who visit our website and use our Resource's services.
The Resource is the controller and Processor and undertakes to protect your privacy, to process your data in an open and transparent manner and in accordance with the Personal Data Protection Regulation (EU) 2016/679 and the relevant data protection legislation applicable in Ukraine.
Key terms
Controller - means a natural or legal person, public authority, agency or other body that, alone or in conjunction with others, determines the purposes and means of processing personal data; where the purposes and means of such processing are determined by EU law or the law of EU member states. Controller or specific criteria for its determination may be provided for under EU or Member State law;
Processor - means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the "controller";
Personal data is any information that relates to any identified or unidentified natural person ("data subject"); an identified natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, online identifier or one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social
DPO (Data Protection Officer) - A person appointed by the Company who has official responsibility for making sure the organization respects data protection;
Data Protection Authority - means an independent government agency charged with overseeing compliance with applicable data protection regulations and laws.
What information do we collect?
We collect, store and use the following information:
1. Cookies according to the Cookies Policy, which is posted on our Resource;
2. We collect information about the history of your use of the Resource - device information, IP address, time and duration of use. This information is used to manage your usage sessions, protect your rights, and troubleshoot problems with your account.
3. If you request our support at support@marketexchangers.com, we will retain your email address. This information is necessary to further resolve your request.
How do we use your personal information and for what purposes?
We only use your personal information for the purposes set forth in this privacy policy.
1. For quality service delivery and to fulfill obligations under agreements between users and us;
2. For user support services for purposes of communicating with the user, providing support, maintaining a database to track and improve the quality of the service and communications with users, to contact the user about updates to the Resource or about the user's account;
3. For advertising and promotion - to send email newsletters, to inform about our products and services, promotions, bonuses;
4. To ensure compliance with relevant laws and regulations - collecting personal data for the purpose of continuous monitoring of activities to prevent third-party rights violations, as part of the fight against fraud, placement of illegal (unlawful) content on the Resources;
5. Web analytics - using Google Analytics: collecting information about users visiting our Website and mobile applications, IP addresses, pages visited, time of visit, which sites were used before visiting our Resources, type of browser and operating system. Our goal is to improve our website and mobile apps.
6. Cookies according to the Cookies Policy, which is posted on our Resource.
We do not use automated decision-making policies, including profiling.
Users can unsubscribe from email newsletters by clicking the appropriate button in our emails.
To whom do we share your personal information?
1. We share users' email addresses with a third party, https://esputnik.com/uk, which conducts email newsletters. This third party may only use user information to perform services on our behalf or disclose it to the extent they are required to do so by law or in connection with any legal proceedings;
2. To law enforcement/judicial authorities under applicable law. The Company will disclose all available Personal Information to the police and any other appropriate law enforcement authorities in cases of money laundering, fraud or other crimes;
3. To protect our legal rights and interests in the event of a user committing crimes, violating the legal rights and interests of third parties;
4. to third parties (seller, buyer) when selling the Company's assets or when the Company purchases assets;
5. Transfer of your personal data to third countries or to an international organization:
Your personal data may be transferred to third countries [i.e., countries outside the European Economic Area] using the following two tools:
1) EU-US privacy requirements for US companies under the GDPR;
2) Signed standard contractual clauses for other third countries under the GDPR provisions.
Processors in third countries are required to comply with European data protection standards and provide appropriate safeguards regarding the transfer of your data in accordance with Article 46 of the GDPR.
How long do we keep your personal data?
1. All data will be stored in a format that identifies data subjects no longer than is necessary for the purpose of processing personal data. Your personal data will be kept for at least five (5) years from the date of your registration, unless you submit a separate request to delete your personal data.
2. Personal data may be kept for longer periods if the personal data is processed solely for archiving purposes and for reasons of general interest, scientific or historical research, as well as for statistical purposes and for the protection of any legal rights.
User rights
You have the following rights with respect to your personal information that we hold:
1. To gain access to your personal data. This allows you, for example, to obtain a copy of the personal data that we have about you and verify that we are legally processing it.
2. Request a correction of the personal information we have about you. This allows you to correct any incomplete or inaccurate data we have about you.
3. Request a deletion of your personal information. This allows you to ask us to erase your personal information [known as the "right to be forgotten"] where there is no good reason to continue processing it.
4. Object to the processing of your personal data where we rely on a legitimate interest and there is something about your particular situation that you object to processing on that basis. If you file an objection and we are unable to provide compelling legitimate grounds for processing that override your interests, rights and freedoms - then we will no longer process your personal data.
5. Withdraw the consent you have given us to process your personal data at any time. Please note that any Withdrawal of consent does not affect the lawfulness of processing based on the consent before it is withdrawn or amended by you.
In the event that you wish to make a complaint regarding how we have processed your personal data, please contact the DPO by emailing suppotr@marketexchangers.com.
Valid Data Subjects Access Requests, which are listed below, will be processed within 30 days:
- Find out where the data controller contains any information about them.
- Obtain a description of the data about them and, if permissible and practical, a copy of the data.
- Obtain information about the purposes for which the data is being processed and where the data was obtained.
- Obtain information about whether the information is disclosed to anyone other than the first recipient of the data, and if so, the identity of those recipients.
- Obtain information about the length of time the data has been stored.
In accordance with Article 12 (3) of the GDPR, we will provide a request under Articles 15-22 to the data subject without undue delay and in any event within one month of receipt of the request. This period may be extended for an additional two months when necessary, taking into account the complexity and number of requests.
If any of the information we hold about you is incorrect or incomplete, you may legally request that the information be corrected, restricted or deleted by sending a request to suppotr@marketexchangers.com.
To exercise any of your rights or if you have other questions about our use of your personal information, please contact DPO at the address above.
Protection of personal data
After the collection, the user's personal information is transmitted to our servers, which are located in Ukraine and in the EU. We provide organizational and technical measures to protect personal data. The appropriate level of data protection is set by our corporate rules
We will take necessary and sufficient organizational and technical measures to protect user information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
We are not responsible for the illegal actions of third parties, hackers, criminals or other third party abusers who may violate the terms of this privacy policy and attempt to gain possession of all or part of your personal information.
Only our authorized employees involved in the maintenance of the Site have direct access to personally identifiable information. Such employees maintain strict confidentiality and prevent unauthorized third parties from accessing personal information.
Third party sites
Our Resource may contain links to other websites. We are not responsible for the content, terms and conditions or privacy policies of third party websites. We encourage users to be careful when they leave our Resource and to read the privacy statements of websites that collect personal information.
Third-party websites may contain their own cookies. We are not responsible for their use of cookies.
Changes to our privacy policy
We may modify or change this Privacy Policy from time to time by posting a new version on our Site.
However, we recommend that you check this page periodically so that you are always aware of any changes to the Privacy Policy.
User consent
User's processing of personal data is based on the user's consent, which he or she gives when registering.
It is the user's responsibility to familiarize themselves with the terms of this Privacy Policy.
The user may withdraw their consent at any time. This can usually be done on the profile page or by sending a separate application according to the provisions of this Policy.
Withdrawal of consent will not affect the legality of processing based on consent previously.