Privacy and personal data protection policy

This Privacy Policy (hereinafter referred to as the "Policy") has been developed by MODALISM Limited Liability Company, represented by the Director Kostyantyn Kostyantynovich Riabov, acting on the basis of the Charter, USREOU code: 45125802, (hereinafter referred to as the "Company" and/or the "Administration") in accordance with the current legislation of Ukraine, including, but not limited to, the Law of Ukraine "On Personal Data Protection" No. 2297-VI as of June 01, 2010, for its use in the course of business activities as well as establishing the procedure for obtaining, collecting, accumulating, storing, processing, using, ensuring the protection and disclosure of personal data (hereinafter referred to as the "Data") of the Users of the website https://modeis.me (hereinafter referred to as the "Website").

Please read this Policy carefully to understand the principles of processing of Users' Personal Data. This Privacy and Personal Data Protection Policy sets out the Сompany's procedure for processing personal data, the types of personal data collected, the purposes for which personal data is used, the Сompany's interaction with third parties, the security measures taken to protect personal data, the conditions for accessing personal data, as well as the contact details enabling users to obtain access to, make changes to, block or delete their personal data and to answer any questions they may have regarding the protection of personal data.

Data processing means any action on data, including, but not limited to: any access, provision, distribution, collection, systematisation, storage, accumulation, recording, transfer, blocking, deletion, clarification, updating and/or modification, depersonalisation and other ways of using data by the company.

This Policy covers the Company's activities both on and off the Internet, including the personal data collected by the Company through various channels, such as websites, applications, social networks, etc. This Policy does not apply to websites accessed via hyperlinks posted on the present Website.

The owner and administrator of Personal Data shall be MODALISM Limited Liability Company, represented by the Director Kostyantyn Kostyantynovich Riabov, acting on the basis of the Charter, USREOU code: 45125802.

Please note that cookies are used on this Website. During each visit to the https://modeis.me site, the Administration may collect information on the devices used by Users and the networks connected to while using the related services. This may include the following information: IP address, account connection information, browser type and version, type and version of browser plug-ins, operating system and platform, information about the User's visit, including the URL route to, through or from the website https://modeis.me, the products/services you consulted or searched for, download errors, time spent on certain pages, etc. The Company collects the following information through the use of various technologies, including cookies.

Cookies are small text files stored on the User's devices when the User visits the website https://modeis.me. The website may use cookies to understand what content the User is interested in and to remember this content if the User uses the website again. The Administration stores cookies to ensure the technically optimised provision of services.

Cookies that may be used by the Company cannot harm the User's devices. If the User agrees to the processing of their personal data, the Administration is automatically authorised to use cookies each time the User uses the website https://modeis.me.

Personal Data Sources

This Policy applies to Personal Data received by the Company from or about the User from the following sources:

• the website https://modeis.me operated by the Company under its own domains/URLs, and the pages managed by the Company on social networks, such as Facebook, Instagram, YouTube, etc;
• e-mail, text and other electronic messages;
• electronic registration forms or similar forms collected by the Company by e-mail or through direct use of the website https://modeis.me;
• social networks (e.g. Facebook, Instagram, YouTube, Google, etc.), market research (unless the feedback is provided on an anonymous basis), third party data aggregators.

Personal Data Collection and Use

The Company collects and uses the following Personal Data and information:

• Personal Data provided by the User to the Company, enabling the User to be contacted, such as the User's name, postal address, e-mail address, social network data or phone number;
• data relating to logging on to the User's account, including telephone number, e-mail address, User's ID and password, other data necessary for the provision of services to Users of the Website, communication with Users, including when the User contacts the Website's support service;
• demographic information describing the demographic and behavioural characteristics of the User. for example, date of birth, age or age range, gender, geographical location, etc;
• information from the computer/mobile device on the computer system or other technological device used by the User for accessing the Website or the Applications, such as the IP address used to connect the computer or device to the Internet, the operating system type, the web browser type and version. If the User accesses the Website via a mobile device, such as a smartphone, the information collected will also include, where permitted, the User's unique device identifier, advertising identifier, geographic location and other similar data relating to the mobile device;
• any information that the User voluntarily shares with the Company about his/her experience of the Services and other products, by leaving feedback, comments, requests for customer assistance, complaints, claims and other requests;
• any information from social networks that the User shares publicly on a social network, or any information included in the User's profile on a social network (e.g. Facebook, Instagram, YouTube). To opt-out of providing such information on a social network, the User must visit the website of the social network concerned;
• payment information that the Administration needs for order fulfilment or information used by the User when placing an order (purchase) on the Website, such as debit or credit card details (cardholder's name, card number, expiry date, etc.). In any case, the Administration will handle financial and payment information in accordance with applicable laws, rules and security standards;
• information provided by Users to the Company when entering into service agreements by accepting a public offer published on the Website and/or entering into agreements for the provision of additional services on the Website.

Purposes of Personal Data collection, use and processing

The Company shall use and processe data for the following purposes:

• administering and updating the Website as well as providing technical support for the Services;
• creating, registering and identifying a User Account;
• communicate with Users for the purpose of providing services, processing payments, conducting settlement operations, creating and implementing User protection programmes, sending mail lists, e-mails, including for the purpose of sending commercial offers, notifications of promotions and other company news;
• evaluating and analysing the market, products, services and facilities provided by the Company, improving the quality of those services and facilities, assigning ratings, analysing User activity, searching for keywords, managing the Website traffic, analysing and forecasting User preferences and interests;
• direct provision of services ordered by the User;
• sending e-mail notifications at the Users' request;
• considering requests and complaints submitted by Users concerning the use of the Website;
• ensuring the Website's security and preventing fraud ;
• checking compliance with the terms of use of the Website (including checking personal messages sent via the Website service, if the User is given an option of exchanging private messages);
• any other purpose insofar as it is sufficient to ensure the quality of service provision and guarantee the implementation of civil, economic and tax relations.

The Company also uses Users' personal data for marketing purposes in accordance with the legislation of Ukraine. When using your Personal Data for direct marketing purposes (commercial newsletter and marketing communications on new products, services and offers that we believe may be of interest to you), we include a link where you can unsubscribe in the future.

Personal Data Protection

The Company shall ensure the application of all relevant obligations of confidentiality, as well as technical, operational and organisational security measures to prevent any unauthorised or illegal disclosure or processing of Information and Data, its accidental loss, destruction or damage, however you should note that there is no absolutely secure and error-free means of transmitting data over the Internet.

The Company shall not be liable for the operation of servers, Internet service providers or the activities of third parties responsible for preventing or restricting access to the Website, for any leakage of information caused by third parties, or for the disclosure by Users of their Personal Data, including authorisation data on the Company's Website, in application software interfaces and in applications.

The User shall acknowledge that in the event of negligence on his/her part regarding the security and protection of his/her data and authorisation data (password, login), third parties may obtain unauthorised access to the User's account and data. The Company shall not be responsible for any damage caused by such access.

Interaction of the Company with Third Parties Regarding Personal Data

The Company shall not transfer any Personal Data to third parties unless such transfer is required by law, at the request of the person concerned by the Personal Data or in other cases stipulated in the present Policy.
The Company fully understands that Personal Information is a valuable and inalienable asset, including the personal non-proprietary rights of any individual User, and therefore shall take all possible steps to protect Users' Personal Information voluntarily and knowingly transferred to the Company.

The Website may contain links to other websites (for informational purposes only). If you follow a link to other websites, the present Policy will not apply to those sites.

However, the Administration may transfer the information received from Users in connection with the provision of the Services to third parties for the purpose of fulfilling its obligations under the Services in an appropriate manner.

In this regard, the Company would advise you to consult the Privacy and Personal Data Protection Policy of each website before submitting any personal data allowing the User to be identified.

User Responsibilities

The User shall be obliged, in particular, but not limited to:

• not to take actions aimed at misleading other Users;
• not to provide their Personal Data to third parties for use;
• not to collect, systematise, store, process or disseminate the personal information of other Users;
• not to attempt to access the personal data of other Users by any means whatsoever, including, but not limited to, fraud, breach of trust, selection of authentication and identification data, etc.

If the User registers on the Company's Website, application software interfaces and applications on behalf of and in the interest of third parties, the User confirms, by giving such consent, that he/she has sufficient authority to carry out such actions, including consenting to the processing of his/her Personal Data on their behalf under the conditions stipulated above, as a representative of such third parties.

User Rights

The User shall have the right, in particular, but not limited to:

• know about the sources of collection, the location of their personal data, the purposes and the procedure for their processing, the location or place of residence (stay) of the owner or manager of the personal data; or give an appropriate instruction to share this information with persons authorised by the owner, except in cases established by law;
• obtain information about the conditions for granting access to personal data;
• access to own personal data;
• submit a reasoned request to the owner of personal data with an objection to their processing;
• submit a reasoned request on the change or destruction of their personal data to any owner and manager of personal data, if data are processed illegally or are unreliable;
• to the protection of their personal data against unlawful processing and accidental loss, destruction, damage in connection with the premeditated concealment, non-provision or delayed provision, as well as to the protection from providing information that is false or disgraces the honour, dignity and business reputation of individuals;
• know the mechanism of automatic processing of personal data.

Period of Storage of Personal Data

The User's consent to the processing of Personal Data is valid for an indefinite period. The period of storage of personal data shall be unlimited. Users ' Personal Data shall be processed within a period not exceeding the time required in accordance with their legitimate purpose and the purposes set out in the present Policy.

The information published on the Administration's Websites shall be protected by the current legislation of Ukraine regulating intellectual property rights. The information published may not be duplicated, translated, archived or copied to other electronic media.

Changes to the Privacy and Personal Data Protection Policy

The present Policy may be amended and supplemented periodically and without prior notice to Users, particularly in the event of changes to legal requirements. If the Company changes the way of processing the Users' Personal Data, the present Policy shall be updated. The Administration shall also reserve the right to modify the Company's approach to Data processing and to the present Policy at any time.

If any provisions of the present Policy, clauses or parts thereof are found to be contrary to the current legislation of Ukraine or invalid, this will not affect the other provisions of the present Policy, which will remain fully valid and effective, while any other invalid or unenforceable provisions unless further action is taken by the parties will be deemed to be amended and corrected to the extent necessary to ensure its validity and enforceability.

The terminology used in the present Policy shall have the same meaning as in the Public Agreement (Offer) for the provision of information and consulting services, unless otherwise specified. For any questions regarding this Privacy Policy, please send an email to info@modeis.me.