PRIVACY POLICY

1. SCOPE OF APPLICATION and CONSENT

1.1. Sole proprietor "ROMAN CHYKHICHYN", the person registered under the laws, located at the address: Poland, Warsaw city, Masovian district, Klobucka street, 6D, 02-699 (hereinafter - the Company), shall be the Administrator of Users Personal Details Database Vas.trade, usa.vas.trade, ua.vas.trade, vas.ua

1.2. Personal data of users of Vas.trade, usa.vas.trade, ua.vas.trade, vas.ua are processed on secure servers located both within and outside of the European Economic Area.

1.3. This Privacy Policy describes the procedure established by the Company for processing of the personal data collected using the website vas.trade, usa.vas.trade, ua.vas.trade, vas.ua (hereinafter referred to as the Site), the VAS mobile application (hereinafter referred to as the mobile application) and related services and tools that allow users to register on the Site, publish or view already published advertisements in real time, use another VAS service related to the above. In all these cases, the Company processes personal data of users exclusively within the framework of the requirements of the Legislation of the Poland and the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data. This Privacy Policy has been developed in accordance with the provisions of these documents.

1.4. By using the Site and/or the mobile application and/or other related VAS services and tools, the User gives his consent to the Company to process his personal data, such as the username; region of residence, e-mail address, contact phone number, other contact information and at the wish of the user; ip- addresses, other communication data of users; messages, letters, statements transmitted to the user by other users and vice versa, and also gives his consent to the transfer of his personal data to the third parties, including the transfer of the personal data abroad, to any third country, in accordance with this Privacy Policy and with Vas.trade, usa.vas.trade, ua.vas.trade, vas.ua Services User Agreement.

1.5. Users should be aware that when following some links posted on the Site or in a mobile application they may be redirected to sites (applications, etc.) of other companies outside the hosting space of the Company, where information about Users is collected outside the direct control of the Company. In such case, the Privacy Policies of sites and/or applications of the third parties shall govern the procedure for processing of information received from the users by these third parties.

2. INFORMATION COLLECTED, RECEIVED AND PLACED BY THE COMPANY

2.1. Account Information: When the User creates an account on the Site, the Company may request certain information, such as a valid email address and password. An account includes information about them such as geographic location, first and last name, phone number and related information, including photos that they can upload to their account. (The account allows users to contact each other to express interest in their offers). Users are responsible for all information they post to public accounts. The user should carefully consider all risks associated with the fact that he is giving certain information – in particular, the address or information about the place of his exact location – public. If the user decides to enter the site using a third-party operator’s authentication service, for example, Facebook information, the Company may receive an additional profile, or other information, access to which is provided by such a third party.

2.2. Announcements and Transactions: As part of the activities of its website, the Company may post information, including personal and contact information, necessary to complete transactions between the buyer and the seller, to send messages and communicate with users among themselves, and to make payments. All information required for posting announcements is requested when creating an account. Users are responsible for all information that they post on the site. The user should carefully consider all the risks associated with the fact that he makes certain information – in particular, address or other personal information – public.

2.3. Games, Advertising and Promotion: As part of its website operations, the Company may collect personal information such as name and contact information when users participate in games, quizzes and other marketing promotions organized at the Site or at the third-party sites by the Company. As part of the activities of its site, the Company may also process information related with the effectiveness of advertising campaigns, including which publications were viewed on the Site and on the third-party sites.

2.4. Customer Servicing: When Users contact the Customer Service Department, the Company may – within the scope of the operations of its website – collect personal information necessary to fulfill the User’s request and receive feedback if necessary. The Company may also contact the User using the existing account contact information provided for this purpose. The Company may also collect other information about communication with Users, for example, any support requests submitted by Users, or any feedback provided by them.

2.5. Website and Mobile Data: The Company may automatically receive and register with its servers information from the user’s browser or any device, including IP address, software and hardware attributes, pages requested by the User, mobile identifiers, application usage information, and/or information about other devices used or system level information. This can occur at the Site or at the mobile application, or at the services of the third parties. Additional information on how the users can control and/or block such collection of information is located below in section 6 of this policy.

2.6. Information obtained as a result of surveys: The Company may collect and store information obtained as a result of surveys that may be conducted by the Company or the third-party contractors involved by the Company, namely information regarding gender, age, marital status, personal preferences, etc.

2.7. Attached Information: The Company may also add information lawfully obtained from business partners or the third parties to the Company’s existing data about its users.

2.8. Information available from user profiles in multi-user Internet platforms (social networks): By registering at the Site or by logging in the site using the authentication services of social networks, the User provides the Company with consent to collection and processing of information available from the corresponding profiles on social networks, as well as publication at the relevant social networks of information about the actions of the User on the Site and/or in the mobile application.

Information that the Company does not collect or process:

The company does not collect or process personal data on racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, and similar information.

3. IP-ADDRESS, COOKIES and MOBILE IDENTIFIERS

3.1. Within the scope of activity of its site, the Company may collect certain information by using technologies such as Cookies (cookies), pixels (pixels), and local storage (like on your browser, or mobile device).

3.2. COOKIES are small text files that store information directly on the user’s computer, his mobile phone or other device.

3.3. The pixels (pixels) are small digital images, which are part of the code on web pages that allow another server to measure website viewability and are often used in conjunction with cookies (cookies). The code tracks if and when (and on which page) a pixel is loaded to indicate that the user is interacting with a page or part of a page on the Site.

3.4. With the help of cookies (cookies) the web server may save, for example, preferences and settings on the user’s computer, his mobile phone or another device(s) that is further automatically restored next visit. Or, in other words, files, cookies (cookies) are, among other, serve to make use of the site more beneficial, thus, for example, that the User should not have to repeat the login process upon the next visit. The Company uses both persistent and session cookies. Persistent cookies remain on the User’s computer for a longer period of time and session cookies are automatically deleted when the browser window is closed.

3.5. The Company may allow the third parties, such as advertising and/or analytical services providers, to collect information using these types of technologies directly on the Website’s web page or the mobile application. The data they collect is protected according to the applicable privacy policies of these third parties.

4. USE OF PERSONAL DATA

4.1. To provide its services, the Company may use the information that the Company collects and places for the following purposes:

4.1.1. providing customer service, including for creating and managing user accounts, solving technical difficulties and accessing various functions;

4.1.2. adaptation of offers and experience, including advertising at their own services or services of the third parties;

4.1.3. control over general and individual activity of Users, such as keyword search, activity on the publication of ads and deals, as well as for traffic management at the Site;

4.1.4. communication with our users, including on the matters of service, customer service or authorized marketing communications through any available communication channels;

4.1.5. conducting research and analytical activities in order to improve our service;

4.1.6. ensuring compliance with Vas.trade, usa.vas.trade, ua.vas.trade, vas.ua Services User Agreement, including countering fraud and abuse;

4.1.7. assessment of certain factors of personal information, in particular, to analyze and predict personal preferences, interests, behavior or location.

4.2. The Company will store your personal data for as long as it is necessary to achieve the purposes for which it was collected, including to comply with any legal, accounting or reporting requirements.

If your account is inactive for more than 24 months, we reserve the right to delete your account, including all personal data stored in it, which means that you will no longer be able to access and use it.

If you have any questions regarding the storage period, please contact us via Support.

5. INFORMATION EXCHANGE

5.1. The company may share the information it collects with affiliates located in any third country. These companies can only process and use the received personal data for the purposes specified in clause 4 of this Privacy Policy. In this case, the transmitted data remains the subject of this Privacy Policy.

5.2. The company does not provide personal information not related parties, except when there is appropriate permission of the Users, or under the following circumstances:

5.3. The Company may use third-party service providers to provide some components of its services, in such cases, the providers do not have the authority to use the personal data obtained through the Company’s Website, other than to provide the Company’s services, and the personal data themselves are the subject of this Privacy Policy.

5.4. The company reserves the right, in accordance with legal requirements, to exchange information with individuals and government agencies for the following purposes:

fight against fraud and abuse on the Site;

to investigate alleged violations of the law or to counter any other alleged violations of the Vas.trade, usa.vas.trade, ua.vas.trade, vas.ua Services User Agreement. trade by Users.

5.5. The Company can provide personal data of users at the request of the competent authorities, drawn up in accordance with the requirements of the law.

5.6. In accordance with the Privacy Policy, the Company undertakes not to rent or sell any of the User’s personal data. If the business of the Company or a part of this business is sold or reorganized, and the Company transfers all, or almost all of its assets to a new owner, then the personal data of users may be transferred to the buyer to ensure continuity of the Site servicing.

5.7. The Company may transfer certain anonymized information (various data that does not allow the identification of Users one by one) to the third-party service providers, trusted partners or authorized researchers in order to better understand which advertising or services Users may be interested in, to improve the overall quality and efficiency of services on the Site or service, or to ensure its contribution to scientific research, which, in the opinion of the Company, can bring great social benefits.

5.8. The Company may transfer the information that it collects to the third parties that provide services to the Company for the purpose of conducting research or providing services to Users, while the data that is transmitted is the subject to this Privacy Policy, and the third parties involved do not have the right to use the received information otherwise than to provide services to the Company.

5.9. In cases of transfer of personal data provided for by this section 5 of the Privacy Policy, informing the User about the transfer of his personal data remains at the discretion of the Company.

6. USER CONTROL

6.1. Access, Correction and Deletion: Users who have created an account or posted publications on the Site can access, correct or delete the information they provide. The User is responsible for the accuracy of the data provided or messages on the Site. If the User’s account was created through an identity provider (for example, Facebook Connect), the User can also disable or change the account information through the settings of the identity provider (for example, on facebook.com). The posted information can be changed or deleted at the user’s personal account at the Site web page or in the application. The Company may stop processing the User’s personal data if it receives a written notification from the User about the withdrawal of consent to the processing of personal data.

6.2. Choice of the third parties: Certain third parties operating on the site, for example, Google Adwords, enable users to revoke their consent to the collection and use of their data for advertising based on user activity.

6.3. Cookies (Cookies): Most of the common PC (desktop) and mobile web browsers (for example, Safari, Firefox, Internet Explorer, Chrome, Opera) provide controls that allow the user to limit or block installation of cookies (Cookies) on your system. Note that disabling the Cookies (Cookies) for the first category domains (sites visited) and other domains (sites related with visited) in some cases can lead to the limited functionality of these websites.

6.4. Other rights of Users in connection with the processing of their personal data by the Company:

6.4.1. to know about the location of the personal data base containing the personal data of Vas.trade, usa.vas.trade, ua.vas.trade, vas.ua users, its purpose and name, location of the owner and managers of the personal data or to provide an appropriate order to receive this information to authorized users of the Site, except as otherwise provided by law;

6.4.2. to receive information about the conditions for providing access to personal data, including information about the third parties to whom the personal data of the Site users are transferred;

6.4.3. to access your personal data;

6.4.4. to receive not later than thirty calendar days from the date of receipt of the request, except as otherwise provided by law, an answer about whether his personal data is being processed and also to receive the content of such personal data;

6.4.5. to make a reasoned demand to the owner of personal data with his refusal to the processing of personal data;

6.4.6. to make a reasoned demand to the owner and/or manager of personal data to change or destroy the personal data, if these data are processed illegally or are unreliable;

6.4.7. to protect personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision thereof, as well as to protect against provision of information that is inaccurate or disgraces honor, dignity and business reputation;

6.4.8. to address complaints to state authorities and officials whose powers include ensuring protection of personal data or to the court about the processing of the personal data;

6.4.9. to apply remedies in case of violation of legislation on the protection of personal data;

6.4.10. to withdraw consent to processing of personal data;

6.4.11. to know the mechanism of automatic processing of personal data;

6.4.12. to protection against an automated solution that has legal consequences for users of the Site.

7. SECURITY

7.1. All information we collect is reasonably protected by technical means and security procedures in order to prevent unauthorized access or use of data. Company affiliates, trusted partners and third-party service providers undertake to use the information received from the Company in accordance with our security requirements and this Privacy Policy.

8. DATA PROCESSING AS A PART OF PORTAL SERVICES FOR VAS DEVELOPERS

VAS integration is a tool for individuals or legal entities who would like to place their publications on the vas.trade, usa.vas.trade, ua.vas.trade, vas.ua platform using the API.

In order to provide VAS integration services, we process the personal data of our users who are software developers or contractors/employees of such developers (together “the Developer” or “the Developers”). For this specific service, we process: application name, contact person, email address, phone number and other data.

VAS integration services require activation with VAS account details. Each time the Developer adds a new application (the “Application”), a special form must be filled in and additional information regarding the Application and contact person must be provided to us in accordance with the VAS integration Terms of Use. Providing us with data in the required form is entirely voluntary, but nevertheless necessary for the use of the API services.

Within the scope of the use of VAS integration services, we also process data about Developers’ activities within the Vas.trade, usa.vas.trade, ua.vas.trade, vas.ua website. We process the aforementioned information for proper fulfillment of the contract concluded with us, improving our services and based on the premise of our legitimate interest in preventing fraud or abuse, as well as ensuring that the Application complies with the provisions of the VAS Service User Agreement.

VAS is not responsible for the lawfulness of the processing of users’ personal data as part of the Application added by the Developer. The obligation to provide accurate information about the rules for using the Application, security policy and other information required by current legislation, in particular the provisions on the protection of the personal data, is borne by the Developer. VAS binds the Developers to update and maintain the Application, in particular, to ensure the security of user data processed through it. In order to exercise his rights in accordance with the personal data protection provisions, any User using the Application must contact directly the Developer or the person specified in the relevant document describing the rules for using particular Application.

9. CHANGES TO THIS POLICY

9.1. The Company may update this privacy policy from time to time, the new version of the Privacy Policy comes into force from the moment it is posted on the Internet at the address specified in this paragraph, unless otherwise provided by new edition of the Privacy Policy. The current version of the Privacy Policy is always on page at the link https://usa.vas.trade/privacy-policy
9.2. If the Company has made any changes to the Privacy Policy that the User does not agree with, he is obliged to stop using the services of the Site. The fact of continuing to use the site is a confirmation of the consent and acceptance by the User of the respective edition of the Privacy Policy.