This Privacy Policy (hereinafter referred to as the “Policy”) describes how the Service Provider processes personal data that it receives from persons who purchase services or otherwise interact with the Service Provider, including when using the websites of the Service Provider, at addresses on the Internet using the promobile.app domain (hereinafter referred to as "Web Resources").
‍


The Privacy Policy was created so that each person interacting with the Service Provider, including when using the Web Resources, could make conscious decisions on granting consent to the processing and use of his personal data by the Service Provider.
‍


The privacy policy contains the following sections:

- The purpose of processing and the composition of personal data that are processed

- Obtaining consent and the period of storage of personal data

- Protection of personal information

- Rights of a person in connection with the provision of personal data

- Use of cookies

- Privacy policy changes

- Contact Information

Personal data is information or a set of information about an individual (hereinafter referred to as the "person") with the help of which it can be specifically identified. The list of these personal data is determined in the Privacy Policy. The personal data that a person provides about himself must be accurate and reliable.

The service provider collects, selects, organizes and distributes personal data in order to fulfill the tasks of its business activities, including the provision of services. The full range of business activities of the Service Provider is indicated in its registration and on the Web resources.



Personal data is processed only if there is the consent of the subject of personal data to perform the specified actions.
‍


The purpose of personal data processing is:

- client identification

- conclusion of transactions, their execution and provision of document flow by the Service Provider

- provision of services, their improvement and development

- marketing and advertising

- processing requests of a person made using Web resources and providing answers to them

- resolution of claims and disputes

- Ensuring accounting, financial reporting and compliance with tax laws

- another purpose to ensure the activities of the Service Provider in accordance with the law.

The collection of information containing Personal Data can be carried out automatically when using the Web Resources, as well as by providing a person with information about himself.
‍

The information is processed automatically on the Web Resources of the Service Provider and its composition:

- Domain name

- IP-address with which the person uses the Web resources

- type of browser and operating system

- date and time of visiting Web resources

- viewed web pages, if a person went to the Web resources through a link from another website
- his address.

In addition, when using the Web Resources from a mobile device, the location of the Person may also be transmitted if the Person does not block access to such information.
‍


Information provided by the Person and its composition:

- last name and first name

- E-mail address

- phone number

- other data permitted by law.

The service provider processes personal data and accumulates it in a database in information and analytical systems, where they are stored in a systematic way and used for a specific purpose.
‍

The service provider is the owner of the following personal data bases:

- client base

- Accounting base.

The list of personal data bases may be changed by the Service Provider, and corresponding changes are made to the Privacy Policy, which is available on the Web Resources.

Consent of a person to the processing of personal data can be provided in the following forms:

- documents in paper form with details that allow to identify this document and the Person

- electronic documents with details that allow to identify this document and the person

- marks, messages, implicit actions of the Person on the Provider's Web Resources, indicating that they have read and consented to the collection and processing of personal data by the Person under the terms of the Privacy Policy.

Without prejudice to the foregoing, consent by a person may also be provided in the course of concluding transactions with the Service Provider, in accordance with applicable law.
The person has the right to withdraw his consent to the processing of personal data at any time. Withdrawal of consent shall not affect the lawfulness of the processing carried out by the Service Provider prior to its completion.

The service provider stores personal data for the following periods:

- in relation to the Person who visits the Web resources, the Service Provider may store at least three years, unless the law establishes other obligations for the subjects of relations in the field of personal data protection

- in relation to the Person who seeks advice or is a customer of services, the latter may store at least six years, unless the law establishes other obligations for the subjects of relations in the field of personal data.

The Service Provider is obliged to take all necessary actions and implement the rules and technical measures to protect personal data from unauthorized processing and/or distortion and/or forgery. All partners, employees, consultants involved in the processing of personal data, and persons processing personal data at the request of the Service Provider are obliged to respect the confidentiality of personal data and comply with the requirements of legislation in the field of personal data protection, as well as the terms of transactions concluded with the Service Provider in this parts. In transactions with persons related to the processing of personal data or processing personal data, the Service Provider includes an obligation to maintain confidentiality and restrict access to personal data.



The service provider, in order to ensure its work and achieve the purpose of processing personal data, may provide access to personal data to the following categories of legal entities and individuals:

- employees of the Service Provider and the involved consultants, including such as lawyers, accountants, administrators, IT specialists, line managers and other professionals with whom the Service Provider has agreements

- state bodies exercising control and supervision over the activities of the Service Provider, other state bodies by virtue of the law

- persons through whom it is possible to make orders and / or payments through the Web resources of the Service Provider

- individuals or legal entities to whom the Service Provider may order works/services, including processing and administration of documentation, translation of documentation, IT services, supply services and software maintenance

- persons who analyze data and create statistics on the use and visits of web resources, such as Google Analytics
- persons providing marketing and advertising services, in particular, but not limited to, developing campaigns, studying demand and responding to services, delivering offers, and so on.



The specified list of categories is not exhaustive and may change in the course of the Service Provider's work. All persons, regardless of the category, who have access to personal data, including those who process them, in case they violate the requirements of legislation in the field of personal data protection, are liable in accordance with the norms of the law governing the obligations of individuals or legal entities in this area.

The Service Provider is obliged to take all necessary actions and implement the rules and technical measures to protect personal data from unauthorized processing and/or distortion and/or forgery. All partners, employees, consultants involved in the processing of personal data, and persons processing personal data at the request of the Service Provider are obliged to respect the confidentiality of personal data and comply with the requirements of legislation in the field of personal data protection, as well as the terms of transactions concluded with the Service Provider in this parts. In transactions with persons related to the processing of personal data or processing personal data, the Service Provider includes an obligation to maintain confidentiality and restrict access to personal data.



The service provider, in order to ensure its work and achieve the purpose of processing personal data, may provide access to personal data to the following categories of legal entities and individuals:

- employees of the Service Provider and the involved consultants, including such as lawyers, accountants, administrators, IT specialists, line managers and other professionals with whom the Service Provider has agreements

- state bodies exercising control and supervision over the activities of the Service Provider, other state bodies by virtue of the law

- persons through whom it is possible to make orders and / or payments through the Web resources of the Service Provider

- individuals or legal entities to whom the Service Provider may order works/services, including processing and administration of documentation, translation of documentation, IT services, supply services and software maintenance

- persons who analyze data and create statistics on the use and visits of web resources, such as Google Analytics
- persons providing marketing and advertising services, in particular, but not limited to, developing campaigns, studying demand and responding to services, delivering offers, and so on.



The specified list of categories is not exhaustive and may change in the course of the Service Provider's work. All persons, regardless of the category, who have access to personal data, including those who process them, in case they violate the requirements of legislation in the field of personal data protection, are liable in accordance with the norms of the law governing the obligations of individuals or legal entities in this area.