Privacy Policy

This Privacy Policy (the "Policy") applies to your use of our websites: https://efircards.com/, https://client.efir.org.ua/, https://app.efir.org.ua/ (hereinafter referred to as the "Websites", each a "Website") and determines what data is collected when you visit our Websites and when you accept offers posted on our Websites, and determines how your personal data is processed and used.

DEFINITION OF TERMS

1.1. "Administration" means the authorised owner of the Website represented by "AVADA MEDIA" LLC, which, acting on behalf of the Website, processes personal data, as well as defines the purpose/goals of personal data processing, the composition of personal data to be processed, actions (operations) performed with the help of personal data.

1.2. "Website(s)" – online platforms on the domains: https://efircards.com/, https://client.efir.org.ua/, https://app.efir.org.ua/ .

1.3. "User of the Website" (hereinafter referred to as the User) is a person who has access to the Website, via the Internet or other networks and interacts with or uses the Website.

1.4. "Services/Service" means goods/services posted on the Website and which may be purchased by the Users.

1.5. "Order" – an offer, which consists in the registration of the User's (Customer's) intention to purchase the Service.

1.6. "Personal data" means information or a set of information about an individual who is identified or can be identified by them.

1.7. "Data" is a set of confidential information and the User's Personal Data, authorisation data, which are deliberately provided by the User when using the Website and, in particular, when registering on the Website.

1.8. "Personal data subject" means an identified or identifiable natural person in respect of whom personal data is processed.

1.9. An "identifiable natural person" is a person who can be directly or indirectly identified.

1.10. "User's consent" means full, unconditional and voluntary, informed and unambiguous, specific and free acceptance, in the manner prescribed by this Privacy Policy, of the terms of this Privacy Policy and its annexes.

1.11. "Personal data processing" – any action (operation) or set of actions (operations) with personal data performed with the help of automation tools or without the use of such tools, including collection, registration, recording, archiving, systematisation, organisation, structuring, ordering, combining, clarification (updating, changing), retrieval, use, transfer/disclosure (distribution, provision, access, provision in any other way), depersonalisation, blocking, storage, adaptation, modification, restriction, deletion, destruction of personal data.

1.12. "Operator" – an individual or legal entity, a state body that processes personal data on behalf of the Administration.

1.13. "Partners" means any business entities related to the Administration by contractual relations, which are granted the right of limited access (in particular, but not exclusively, licensees) to the Website in order to provide services and goods, disseminating and/or providing information about their services and/or products (including information materials and messages published on their behalf or in their interests), as well as receiving applications from Users.

1.14. "Third party" means a natural or legal person, public authority, agency or body other than the data subject, the owner, controller, processor and/or persons who are authorised to process personal data under the direct supervision of the owner, controller or operators authorised to process personal data.

1.15. "Hyperlink Referrer" (Referrer/Referral Person) – a Third Party whose Hyperlink the User clicked on and within which the User registered on the Website.

1.16. "Hyperlink" means a hyperlink of a Referral Person created through the Services, which the User followed and within which he/she registered on the Website.

1.17. "Recipient" means a natural or legal person, public authority, agency or other body to whom personal data is disclosed, whether or not it is a third party. The processing of such data by such public authorities shall comply with the applicable data protection regulations in accordance with the purposes of processing.

1.18. "Confidentiality of personal data" is a requirement to prevent and suppress the dissemination of personal data without the consent of the personal data subject or the existence of a legal or contractual provision (requirement).

1.19. "COOKIES" are small text files that store information directly on the user's computer, mobile phone or other his/her device.

1.20. "Pixels" are small digital images that are part of the code on web pages that allow another server to measure the viewing of a web page, and are often used in conjunction with cookies.

1.21. "IP address" is a unique network address of a node in a computer network built using the IP protocol.

1.22. Other terms used in the Privacy Policy are defined by the current legislation of Ukraine.

2. SUBJECT OF PERSONAL DATA PROCESSING. CONSENT TO THE PROCESSING OF PERSONAL DATA. SCOPE OF APPLICATION

2.1. The processing of personal data is necessary to fulfil the purpose and objectives provided for in this Privacy Policy, to perform an agreement to which the personal data subject is a party or intends to become a party, to fulfil a legal obligation of the Administration, protection of the vital interests of the personal data subject, for the purposes of the legitimate interests of the Administration or a third party, except as provided by applicable law.

2.2. The personal data of Users is processed by the Administration, registered under the laws of Ukraine with a location at the address: 7 Dvorianska St., Odesa, 65023, Ukraine.

2.3. The Administration collects information (personal data) in the order and manner specified in this Privacy Policy, applicable law, directly and/or indirectly.

2.4. The direct collection of personal data is, for example, receiving data that the User sends/provides through the Website and/or in the process of communicating with the Administration via a web request (chat), e-mail, telephone, letter, social networks, messengers, etc.

2.5. The indirect collection of personal data is, for example, the receipt of User data from third parties, including, for example, business partners, subcontractors in technical, payment and other services or from external publicly available sources.

2.6. Personal data processing and, in particular, decision-making based on the results of processing, may be carried out in automated and/or non-automated forms.

2.7. The administrator, controller and owner of the database of personal data provided by the User is the Administration.

2.8. Personal data of Users is processed on secure servers.

2.9. All personal data bases belonging to the Administration are located in data centres or at the address of the Administration.

2.10. The Administration shall keep records of personal data processed by it and falling within its area of responsibility.

2.11. The Administration may delegate the processing of personal data to the Operators. When delegating the authority to process personal data to the Operators, the Administration shall take all necessary actions stipulated by law.

2.12. The Administration processes the personal data of Users only if there is a "Consent" of the Personal Data Subject – User.

2.13. This Policy and its annexes are deemed to be accepted by Personal Data Subjects without any reservations or exceptions by making any voluntary, informed and unambiguous, specific, freely given expression of intent by which an individual in the form of an unambiguous action (confirmation act), other affirmative actions, in particular, but not exclusively, in the form of an application and/or the Order, by contacting the Administration/Operator using the contact details posted on the Website and/or when registering/entering/using the Website, in other ways provided for by the Website and/or in other ways specified in this Policy: agrees to the terms and terms of this Privacy Policy, provides (confirms) its consent to the Administration: to the processing of its personal data specified in the Policy; to the adoption of automatic individual decisions (taken on the basis of automated processing of personal data); to transfer their personal data to third parties, including the transfer of personal data abroad, to any third country, including in order to obtain by the User services/goods from these third parties; to perform other actions provided for by this Policy, applicable law, necessary to fulfil the specific purposes of processing personal data under this Policy.

2.14. Acceptance of this Policy in the manner prescribed by it indicates that the User agrees to receive system and other information messages from the Administration by posting information on the Website, by electronic mailings, phone calls and other available means, as well as that he/she has read the terms of this Policy and its annexes, understands, agrees to them and undertakes to comply with them.

2.15. The User guarantees that it has the necessary legal capacity, as well as all the rights and powers necessary and sufficient to conclude and fulfil the terms of this Policy as a personal data processing agreement.

The Administration is not obliged to verify the User's compliance with the requirements of the Policy and shall not be liable in case of non-compliance with these requirements.

2.16. The User's consent is voluntary and direct.

2.17. By agreeing to the processing of personal data, the personal data subject (User) and the Administration conclude an agreement on the processing of personal data, the terms of which are set out in this Policy.

2.18. To ensure the proper and lawful processing of personal data of the personal data subject, the Administration reserves the right to additionally verify the accuracy and veracity of the personal data provided by the User, and, in particular, identification of the personal data subject by the method chosen by the Administration, in particular, by requesting information and documents from the User to confirm his/her identity and the information provided by him/her, other personal data of the User and other necessary data.

2.19. Identification of the personal data subject includes digital identification of the personal data subject, for example, through an authentication mechanism, such as the same credentials used by the data subject in order to contact the Administration or receive the Services.

2.20. In case of an unsuccessful attempt to verify personal data or the identity of the User, the Administration may suspend, restrict or block the User's access to the Website/Services.

2.21. When the User-subject of personal data provides consent to the processing of personal data within the Website/Services of the Administration to other persons, including those located abroad, in accordance with this Policy, he/she is considered to be notified of such transfer of personal data concerning him/her.

2.22. The User's consent to the acceptance of this Policy shall be deemed sufficient notification of the User of the inclusion of his/her personal data in the User database and the processing of personal data.

2.23. Users should be aware that when clicking on some of the links posted on the Website, they may be redirected to websites (with applications, etc.) of other companies outside the Website hosting space, where information about Users is collected beyond the direct control of the Administration. In this case, the privacy policy rules of third-party websites and/or applications will regulate the procedure for processing information received from Users by these third parties.

3. OBJECTIVES AND PURPOSE OF PERSONAL DATA PROCESSING

3.1. The personal data of the Users, as provided to the Administration, will be used for the purposes specified in this Policy. In particular, the Administration may process personal data for the following purposes:

3.1.1. demonstration of advertising, sponsorship and other information materials;

3.1.2. providing/selling the Services and improving them;

3.1.3. conducting surveys on behalf of the Administration/Partners or third parties and evaluating the effectiveness of advertising or other information materials for the purpose of compiling statistics, improving the Services and/or the Website;

3.1.4. providing customer service, solving technical difficulties and access to various functions of the Website and Services;

3.1.5. providing information offered on the Website;

3.1.6. providing additional information about the Services;

3.1.7. on the basis of information stored on the Website, to make individual offers that may be displayed on other platforms or on other websites, as well as on social media pages. These can be offers that the User can find directly on the platforms or third-party products and offers that may be of interest to him/her;

3.1.8. adaptation of offers and experience, including advertising on its services or services of third parties;

3.1.9. to control the general and individual activity of Users, such as keyword searches, placing orders, concluding transactions, selecting Services, as well as to manage traffic on the Website;

3.1.10. communicating with Users, including regarding the Service, customer service or permitted marketing communications through any available communication channels;

3.1.11. conducting research and analytical activities to improve the Websites;

3.1.12. ensuring compliance with the agreement with the Users of the Websites, including the fight against fraud and abuse;

3.1.13. assessing certain factors of personal information, in particular to analyse and predict personal preferences, interests, behaviour and location;

3.1.14. keeping records;

3.1.15. contributing to the overall organisational goals;

3.1.16. reporting on the impact and effectiveness of the Services provided;

3.1.17. launching/administering the Website;

3.1.18. processing of the User's application/order and/or the User's role;

3.1.19. for training and/or quality control;

3.1.20. fulfilment of legal obligations that are binding on the Administration in accordance with the applicable laws provided for by the Policy. For example, in relation to regulatory, governmental and/or law enforcement authorities with which the Administration may work (e.g, tax claims);

3.1.21. to identify the client as the User of the Website, to communicate with the User, including for the provision of Services, payment processing, settlement operations, reporting, accounting and management accounting, creation and implementation of bonus programmes, User protection programmes, sending newsletters by mail, e-mail, including for the purpose of sending commercial offers, notifications of promotions and other news;

3.1.22. fulfilment of contractual obligations concluded with Users;

3.1.23.censuring the provision of services/goods to the Users by third parties;

3.1.24. fulfilment of the legitimate interests of the Administration, which are, in particular:

enabling Users to access the Website and otherwise interact with it;
Users receiving Services and/or services/goods of third parties;
detecting security incidents, protecting against malicious, misleading, fraudulent or illegal activities and holding accountable those responsible for such activities;
measuring interest and engagement in the Services;
short-term temporary use, for example, contextual advertising settings;
improving, upgrading or expanding the Services, Website;
development of new products, goods and services (including Services);
ensuring internal quality and safety control;
authentication and verification of Users' identity;
adjustment to identify and eliminate errors in the Services and the operation of the Website;
audit related to interactions, transactions and other compliance activities;
ensuring compliance with the agreements and policies of the Website;
meeting information security needs and protecting Users;
resolving legal issues;
other actions aimed at fulfilling the purpose and objectives of personal data processing.

3.2. Fulfilment of other purposes to which the User has given consent.

4. PERSONAL DATA PROCESSED

4.1. Orders, agreements: Within the framework of the Website, the Administration may process information, including personal and contact information, necessary for the transaction between the User and the seller/performer of the Services, in particular information about: geographic location, first name, patronymic and surname, date of birth and gender, credit card and other financial account information, and transaction data, including the Services offered, viewed or purchased on the Website, telephone number and related information, including photographs, education, profession and length of service, time for the provision of services, performance of work and receipt of goods, and language proficiency, IP address, audio/video recording if the User contacts the seller/provider of the Services, which is the Administration, by means of a video/audio call, User content (e.g. messages, reviews, etc.), skills, tests passed, test results, other information provided by the User on the Website.

4.2. Customer service for Users: When Users contact the Administration, the latter, if necessary, may collect personal information in the course of the Website's operation necessary to fulfil the User's request and receive feedback, in particular, audio/video recording, if the User contacts the Administration by means of an audio/video call, information about the Services used by the User or which, in the opinion of the Administration, may be of interest to the User. The Administration may also contact the User by using the existing contact information provided for this purpose. The Administration may also collect other information about communication with the Users, for example, any requests to the support service submitted by the Users or any feedback provided by them, in particular, in the form of reviews left by the Users. The correspondence data may include the content of the communication and metadata related to the communication. The Website will generate metadata related to communications made through the Website's contact forms.

4.3. Website and mobile data, User's actions on the Website, information from Cookies: The Administration may automatically receive and register, otherwise process on its servers unique device and application identifiers, browsing history or other data on the use of the Website, information from the User's browser or any device, including the User's IP address, geolocation, software and hardware attributes, pages requested by the User, the URL or advertisement that referred the person to the Website, the search terms that the User entered into the search engine and that led them to the Website, the parts of the Website that the User visited, the hyperlinks that the User clicked on, which pages or content the User has viewed and for how long, data contained in browser databases, including SQL databases, mobile identifiers (including mobile device identifiers such as Google Advertisement ID, IFA or IFV), information about the use of applications, and/or information about other devices used, or system-level information, other similar information and statistics regarding the User's interaction with the Website, such as the response time of the content, loading errors and the duration of visits to specific pages of the Website, etc. within the scope of the purpose of processing personal data under this Policy. This may occur on the Website or on the services of third parties. Additional information on the collection and processing of Cookies, as well as how Users can control and/or block such collection of information, is available in the Cookies Policy.

4.4. Information received as a result of surveys: The Administration may process information received as a result of surveys that may be conducted by the Administration or third-party contractors engaged by the Administration, namely information on: gender, age, marital status, personal preferences, etc.

4.5. Information to be added: The Administration may also add information legally obtained from business partners or third parties, including to existing data about Users.

4.6. Information required for the provision of services/goods to Users by third parties: Within the framework of the Website, the Administration may process information, including personal and contact information, necessary for the execution of a transaction between the User and the seller/performer of services/goods, other third parties, services/goods which the User receives and/or intends to receive, in particular information about: name, surname, telephone number, e-mail address, date of birth (day and month), gender, methods of identification of the User, IP address.

4.7. Non-identifying information: The Administration may process other information that does not directly identify the User, such as postal codes, demographic data and other data, depending on the purpose and goals of processing personal data.

4.8. The Administration also collects/processes any other personal data that the User wishes to share with the Administration.

4.9. The user who, within the meaning of the Law of Ukraine "On Personal Data Protection", acts as the owner of personal data or the recipient or manager of personal data of personal data subjects, undertakes to comply with the requirements of the said Law on the processing of personal data (in particular, using information (automated) systems).

4.10. By accepting this Policy, the User guarantees that he/she has received and has all legal grounds (necessary permits and consents) to collect, register, accumulate, store, adapt, modify, update, use and distribute (publish, transmit), depersonalise, destroy, otherwise process personal data and other information that constitutes the content of personal data regarding third parties using the Services/Website, and guarantees the full and unconditional consent of such persons to all provisions of this Privacy Policy.

4.11. In case of changes in the personal data provided by the User, the User undertakes to provide the Administration with updated, reliable information (personal data) and, at the request of the Administration, the originals of the relevant documents to update the provided personal data as soon as possible.

4.12. Information that the Administration does not collect or process: The Administration does not collect and process personal data on racial or ethnic origin, political, religious or worldview (philosophical) beliefs, membership in political parties and trade unions and similar information, genetic data, biometric data for the purposes of unified identification of an individual, data on the state of health or data on the sexual life of an individual or his/her sexual orientation, personal data of children (if information on the relevant age of the individual is available).

4.12.1. The provision of clause 4.12. does not apply if the subject of personal data has given explicit consent to the processing of such personal data for one or more specified purposes, and/or in other cases determined by law.

4.13. If the Administration becomes aware that a child under the age of 18 (for personal data subjects located in Ukraine) has provided personal data to the Administration, the Administration shall take all necessary efforts to delete such information. If you are a legal representative of a child or a person who has parental rights in relation to a child and believe that the Administration processes your child's personal data, please contact us at the addresses/requisites specified in this Policy.

4.14. The Administration, taking into account the available technical and administrative capabilities, makes reasonable efforts to verify in the cases provided for in clause 4.13 of the Policy that the User's consent has been given or authorised by the child's legal representative or by a person who has parental rights in relation to the child (the bearer of parental responsibility in relation to the child).

5. COOKIES AND MOBILE IDENTIFIERS

5.1. During the operation of the Website, the Administration may collect certain information using technologies such as cookies, pixels and local storage, other similar technologies.

5.2. The User can learn more about the processing of cookies by reading the Policy on the use of cookies.

5.3. The Cookie Policy is an annex to this Policy and is an integral part of it.

6. STORAGE OF PERSONAL DATA

6.1. The Administration will retain personal data of Users for as long as necessary to achieve the purposes for which they were collected, including to fulfil any legal, accounting or reporting requirements, and for ongoing fraud prevention, backup and business continuity purposes. Personal data should not be stored longer than necessary for these purposes. The Administration stores the User's personal data for the time (period) necessary to provide access to the Website and related services of the Website, Services, the provision of services/goods to the User by third parties, as well as for the duration of the Administration's legitimate interest in storing this data.

6.2. Personal data is stored in a form that allows for the identification of data subjects no longer than is necessary for the purposes of processing. In any case, the Administration deletes personal data, except for those that must be stored to fulfil its legal obligations (for example, mandatory retention periods).

6.3. The User's personal data may be stored for longer periods than specified in clauses 6.1.-6.2. of the Policy, as long as they are processed solely for the purposes of public interest, scientific or historical research or statistical purposes, together with the conditions for taking appropriate technical and organisational measures to guarantee the rights and freedoms of the data subject ("storage restriction").

6.4. To ensure that personal data is not stored for longer than necessary, the Administration periodically reviews the personal data stored.

6.5. Notwithstanding the other provisions of this section of the Policy, the Administration may store personal data of Users when such storage is necessary to comply with a legal obligation of the Administration, or to protect the vital interests of Users or the vital interests of another individual.

6.6. To determine the appropriate storage period, the Administration takes into account the volume, nature and sensitivity of personal data, the potential risk of damage from unauthorised use or disclosure of Users' personal data, the purposes for which the Administration processes the Users' personal data, as well as whether the Administration can achieve these purposes by other means and the relevant legal requirements.

6.7. If the User does not want to receive any more contacts from the Administration, the Administration will save the basic information about the User in order to fulfil the User's request and avoid sending unwanted materials to the User in the future.

6.8. In case of any questions regarding the period (term) of data storage, the User can contact the Administration using the contact details posted in this Policy.

7. INFORMATION EXCHANGE AND DISCLOSURE

7.1. The Administration does not share, sell, or lease personal data of Users to third parties for marketing purposes. However, as a rule, the Administration may disclose personal data to selected third parties to achieve the purposes set out in this Privacy Policy.

7.2. The Administration may transfer the Data collected in accordance with this Policy to the Partners between the respective Websites and applications owned or operated by the Administration or used by it, however, the Data collected in accordance with the Terms of Use of the Application Website and this Policy is always protected in accordance with the provisions of this Policy and the laws of Ukraine. At the same time, the Partners/third parties are solely responsible for compliance with the legal requirements for Data processing.

7.3. The Administration may share the information it collects:

with affiliates (companies acting on the basis of common ownership or under common control) located in any third country. These companies may only process and use the personal data received for the purposes specified in Section 3 of this Policy. In this case, the transmitted data remains subject to this Policy;
with data protection advisers to the extent reasonably necessary to obtain professional advice or to establish, exercise or defend legal claims, whether in a judicial, administrative or non-judicial proceeding;
suppliers and subcontractors for the performance of any contract, such as IT service providers such as website hosts, cloud storage providers and email clients;
insurers;
lawyers providing legal assistance to the Administration;
financial companies that collect or process payments on behalf of the Administration;
social media platforms only with the express permission of the User;
regulatory authorities, such as tax authorities, law enforcement and judicial authorities, other competent authorities, in cases determined by applicable law;
advertisers and advertising networks;
analysts and search engine providers.

7.4. The Administration may use third-party service providers to provide some components of its services, in such cases, the suppliers do not have the authority to use the personal data received through the Website, except for the provision of services to the Administration, and the personal data itself is the subject of this Privacy Policy.

7.5. The Administration reserves the right, in accordance with the requirements of the law, to exchange information with individuals and public authorities for the following purposes:

combating fraud and abuse on the Website;
investigating alleged violations of the law or dealing with any other alleged violations of the agreement with the Website Users;

7.6. The Administration may provide personal data of the Users at the request of the competent authorities, executed in accordance with the requirements of the current legislation and if there are grounds provided for by the current legislation.

7.7. In the event that the Administration's business or part of this business is sold or reorganised, and the Administration transfers all or substantially all of its assets to the new owner, the personal data of Users may be transferred to the buyer to ensure the continuity of the Website/Services/services/goods of third parties.

7.8. The Administration may transfer certain anonymised information (data that does not allow to identify Users individually) to third-party service providers, trusted partners or authorised researchers in order to better understand which advertising or services may be of interest to Users, to improve the overall quality and efficiency of the Website services, or to contribute to scientific research that, in the opinion of the Administration, may be of great social benefit.

7.9. The Administration may transfer the information it collects to third parties that provide services to the Administration for the purpose of conducting research or providing Services to Users, in this case, the data transmitted is subject to this Privacy Policy, and the involved third parties have no right to use the information received other than to provide services to the Administration.

7.10. The Administration may transfer personal data of Users to third parties who provide services/goods to Users or whose services/goods the User intends to receive, and the data transferred is subject to this Privacy Policy, and the third parties involved shall not be entitled to use the information received other than to provide services/goods to the Users and to fulfil the agreements concluded between the User and such third party.

7.10.1. Terms and conditions of disclosure/transfer of personal data of Users to third parties specified in clause 7.10. of this Policy:

- the User agrees that by clicking on the Hyperlink (referral hyperlink of the referrer) and registering within such hyperlink on the Website,

- he/she identifies a third party (which is the Referrer of the hyperlink), to whom the Administration has the right to transfer/disclose the User's personal data specified in this Privacy Policy, and such third party has the right to process the transferred/disclosed personal data of the User;

- the disclosure/transfer of the User's personal data to such third parties occurs after the User registers on the Website via the Hyperlink, but only to the extent necessary to identify the User and provide services/goods to him/her by such third parties;

- identification of third parties who provide services/goods to the User or whose services/goods the User intends to receive is carried out by checking the Referral Person by the Administration, through the referral hyperlink (Hyperlink) of which the User has followed and within which the User has registered on the Website.

7.11. Personal data may be transferred abroad (outside the place of personal data processing) in the following cases:

cooperation with foreign entities, which is regulated by the current legislation and is binding;
unequivocal consent to such transfer by the personal data subject. Unequivocal consent to the transfer of personal data abroad is considered to be the acceptance of this Privacy Policy in the manner prescribed by this Policy;
the need to conclude or perform a transaction between the personal data controller and a third party – a personal data subject in favour of the personal data subject;
the need to protect the vital interests of personal data subjects;
the need to protect the public interest, establish, enforce and ensure a legal claim;
in other cases stipulated by law.

7.12. Personal data shall be transferred to foreign parties related to personal data only if the relevant state ensures proper protection of personal data in cases established by the applicable law.

7.13. The Administration reserves the right to disclose the User's personal data to third parties, including in order to protect the rights, property or safety of the Administration, its staff/employees, Users and other persons.

7.14. In cases of transfer of personal data provided for in this section of the Policy, informing the User about the transfer of his personal data remains at the discretion of the Administration, except as provided for in this Policy or applicable law.

7.15. The User should be aware and understand that when personal data is voluntarily disclosed by the User on public areas of the Website, this information, together with any information disclosed in the User's message, may be collected and used by third parties and may lead to unwanted messages from third parties. Such activities are beyond the control of the Administration, and this Policy does not apply to such information. Any materials in chats or other public areas on the Website are accepted with the understanding that they are available to all third parties. If the User does not want his/her messages/comments/reviews to be viewed by unauthorised persons, the User is advised not to make any statements.

7.16. The Administration may collect additional information about the Users from third-party information sources in order to fulfil the purposes set out in this Policy.

8. USER CONTROL. USER RIGHTS

8.1. Users can access personal data and other information specified by law, restrict the processing of personal data, correct, supplement, delete the Data they have provided. The User is responsible for the accuracy of the data provided or messages on the Website. The Administration may terminate the processing of the User's personal data in case of receipt of a written notice from the User about the withdrawal of consent to the processing of personal data.

8.1.1. In order to exercise the rights provided for in clause 8.1. of this Policy, the User must send a relevant request to the Administration at the addresses/contacts provided for in this Policy.

8.1.2. In a request for correction, updating, deletion of information, the User must necessarily indicate what kind of information he/she requests to correct, update or delete.

8.1.3. The Administration will resolve the relevant request of the User within the time limits specified by law.

8.2. Cookies: Most major computer (desktop) and mobile web browsers (e.g. Safari, Firefox, Internet Explorer, Chrome, Opera) provide controls that allow the User to restrict or block the installation of Cookies on Users' systems. Please note that disabling cookies for domains of the first category (visited sites) and other domains (sites related to visited sites) may in some cases lead to limited functionality of these websites.

8.3. Other (non-exhaustive) rights of Users in connection with the processing of their personal data by the Administration:

to have access to their personal data and other information specified by law;
to receive, no later than 30 (thirty) calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his/her personal data is processed or stored, as well as to receive the content of such personal data;
to submit a reasoned request to the owner/controller of personal data with an objection to the processing of personal data;
to submit a reasoned request to change or destroy personal data by the owner and/or controller of personal data if such data is processed illegally or is unreliable, except as provided by law;
restrict the processing of personal data in cases provided for by law;
withdraw consent to the processing of personal data;
withdraw consent to receive notifications from the Administration regarding the Services, other information, except for the information that is necessary to fulfil the User's request;
to protect personal data;
to file complaints about the processing of personal data with the Administration, public authorities and officials responsible for ensuring the protection of personal data, or in court;
apply legal remedies in case of violation of the legislation on personal data protection;
contact the Administration in accordance with the procedure established by the Policy;
have other rights stipulated by the current legislation, this Policy and its annexes.

8.4. The legislation of Ukraine that applies to a controller, owner or operator may restrict, by means of a legislative instrument, the scope of obligations and rights provided for by the legislation, if such restriction preserves the essence of fundamental rights and freedoms and is a necessary and proportionate measure in a democratic society to ensure compliance with the requirements of the law.

9. SECURITY AND PROTECTION OF PERSONAL DATA

9.1. All information collected by the Administration is protected within reasonable limits by technical, administrative and physical security measures and procedures to prevent unauthorised or unlawful access or use of personal data, as well as against unintentional loss, destruction or damage to personal data, in accordance with the risks.

9.2. Processing of personal data is carried out in a manner that ensures proper security of personal data.

9.3. Affiliates of the Administration, reliable partners and independent service/goods providers, third parties specified in this Policy are obliged to use the information received from the Administration in accordance with the security requirements and this Privacy Policy.

10. AMENDMENTS TO THIS POLICY

10.1. This Privacy Policy was last updated on 02.02.2024.

10.2. The Administration 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 Website at the address specified in this section, unless otherwise provided by the new version of the Privacy Policy.

10.3. The current version of the Privacy Policy is always available on the Website page at: https://efircards.com/privacy-policy/.

10.4. If the Privacy Policy is updated, the User can read it at the following link https://efircards.com/privacy-policy/.

10.5. In case the Administration has made any changes to the Privacy Policy with which the User does not agree, he/she is obliged to stop using the Website and Services.

11. RESPONSIBILITY

11.1. For failure to comply with their obligations under the Privacy Policy, the User shall be liable in accordance with applicable law.

11.2. The User is obliged to reimburse the Administration for all losses and damages that could be directly or indirectly caused by the breach of the User's obligations.

11.3. The User is solely responsible for the dissemination of data for access to the Service/Website (identifiers, passwords, etc.), for the dissemination of personal data of third parties (including the Administration), for the material of the content, including for the compliance of the content with the norms of the current legislation.

12. FINAL PROVISIONS

12.1. This Policy is mandatory for use by Operators, Partners, Administration, third parties specified in the Policy and other persons directly involved in the Processing of Personal Data and/or have access to the Data in connection with the performance of their official duties and/or contractual obligations to maintain the confidentiality of the Data received from the Administration.

12.2. All suggestions or questions regarding this Privacy Policy should be sent in the form of feedback in accordance with Section 13 of this Privacy Policy.

12.3. The User agrees to use the legislation of Ukraine as the applicable law/acting legislation on the processing and protection of personal data.

12.4. With regard to any issue that directly or indirectly relates to the Privacy Policy, the User agrees that the dispute shall be settled in the competent Ukrainian courts, in the manner and in accordance with the procedure established by the current legislation of Ukraine.

12.5. The invalidity of a separate part of the Privacy Policy does not entail the invalidity of other parts of the Privacy Policy as a whole. In the event that certain provisions of the Privacy Policy are amended, cancelled by the parties or invalidated, the remaining provisions shall remain valid and binding on the Parties to the personal data processing agreement.

12.6. In the event that this Privacy Policy does not regulate certain provisions, rights and obligations, they are regulated and established by the current legislation of Ukraine.

13. HOW TO CONTACT THE ADMINISTRATION

13.1. The User can contact the Administration in the following ways:

by post to the specified address: 7 Dvorianska St., Odesa, 65023, Ukraine;
using the contact form (chat) on the Website;
by e-mail, at [email protected].