The following text is currently available in English only.
Thank you for your interest in our company and application. Data protection and data security are very important to us. We would like to inform you about data collection, processing and use when using our application. As well as objection, revocation and other rights to which you are entitled as a person affected by data collection and use.
This we do in compliance with the applicable data protection legislation and have committed to a vast selection of Privacy Laws form across the globe based on our customer base. In particular we adhere to the;
Europe`s General Data Protection Regulation (GDPR);
California`s Consumer Privacy Act (CCPA);
USA`s Federal Trade Commission FIPs (FIPs);
Australia`s Privacy Act 1988 (Privacy Act);
Canada`s Personal Information Protection and Electronic Documents Act (PIPEDA).
KM.Company of Kharkiv, Ukraine is the Controller of your personal data.
What is personal data?
Personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”).
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Our application is not intended for children and we do not knowingly collect data relating to children.
What data do we collect?
We may collect data or ask you to provide certain data when you use our application and services. The sources from which we collect Personal Data are:
Data collected directly from you or your device relating to an identified or identifiable natural person (“Data Subject”) and may include direct identifiers such as username, apple id, email address.
Data collected through indirect identifiers such as login account details, login password, payment details, or IP address.
Data collected that is linked, for example if you have used our service and later choose us again, we will link your data and treat that linked data as Personal Data.
We organise collected Personal Data as Account Data and Licensing Data.
As described above, we link data and if we have already collected some of your data, we will only ask you for the remaining data that is necessary to carry out the service contracted for.
How personal data is collected
We collect personal data in the following ways:
you may provide personal data when you download our application, request services, subscribe to our premium feature or use our feedback form or otherwise or correspond with us.
we automatically collect personal data (technical and usage) when you interact with our application and we may also receive technical data about you if you download and install our application.
On what grounds do we use Personal Data?
We use your Personal Data for the following purposes and on the following grounds:
On the basis of fulfilling our contract (when use our application or buy a premium feature)
On the basis of your consent (when you contact us)
On the basis of legal obligations (for obligations such as tax, accounting, anti-money laundering, or when a court or other authority asks us to)
On the basis of our legitimate interest (for communications about security, privacy and performance improvements of our services. Or for establishing, exercising or defending our legal rights.)
Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
When do we disclose your Personal Data?
We disclose your Personal Data in response to your business enquiry or your request for information within our Company in order to provide the best service possible and within our legitimate interest.
We may share your information with organisations that help us provide the services described in this Data Protection Policy and who may process such data on our behalf and in accordance with this Data Protection Policy, to support this application and our services. For example, with our legal other professional advisors.
In relation to information obtained about you from your use of our application, we may share a cookie identifier and IP data with analytic and advertising network services providers to assist us in the improvement and optimisation of our application which is subject to our Cookies Policy.
We may disclose personal information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the application and its users.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.
You can learn how long your information is held and when it is destroyed from our Data Retention Policy which you can request using our contact form.
You have the right to:
information about the processing of your personal data
obtain access to the personal data held about you
ask for incorrect, inaccurate or incomplete personal data to be corrected
request that personal data be erased when it’s no longer needed or if processing it is unlawful
object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation
request the restriction of the processing of your personal data in specific cases
receive your personal data in a machine-readable format and send it to another controller (‘data portability’)
request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision
Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time through our contact form.
California Privacy Rights
Sources and Categories of collected personal information
(you can find all sources and categories of collected personal information above)
Business or commercial purpose for collecting information
(you can find all purposes of processing personal information above)
Categories of third parties with whom the business shares personal information
(you can find all categories of recipients of personal information listed above)
In addition to the rights as explained, under California’s “Shine the Light” law, California residents who provide personal information (as defined in the statute) to obtain products or services are entitled to request and obtain from us, once per calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediate prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain the information about data we hold about you or to effect the opt out, please contact us.
How do we protect your Personal Data?
We protect your data using state of the art technical, and physical safeguards and operate a firm system of policies, confidentiality agreements, digital safeguards and procedures to ensure the highest level of administrative protection.
In more detail to access our database the user must be authorised, is challenged through a two-way authentication system and use an encrypted VPN. Also, the removal of Personal Data from our location is forbidden and made by using a complex encryption system very difficult. We use cutting edge antivirus and anti-malware software and up-to-date firewall protection. Moreover, authorised personnel must have a legitimate need to know interest such as being your point of contact or service your user account.
The data we collect from you may be stored, with appropriate technical and organisational security measures applied to it, on our servers in the USA. In all cases, we follow generally high data protection standards and advanced security measures to protect the personal data submitted to us, both during transmission and once we receive it.
To exercise any of your rights, or if you have any questions or complaints about our use of your Personal Data and this policy, please contact us using our contact form.
Do Not Track
This Application does not support “Do Not Track” requests.
Do Not Sell My Personal Information
We do not sell information that directly identifies you. In fact, we do not even share that type of information except with service providers who can use the information solely to provide a service on our behalf, when a consumer directs us to share the information. If applicable, you can choose whether you want this sharing or not. Remember, we don’t sell data that directly identifies you unless we have your explicit permission, no matter what choice you make. To make your choices please contact us.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Automated decision-making and profiling
We do not use automation for decision-making and profiling.
Individual(s) or companies that have been approved by us as a recipient of organizational Personal Data and from which KM.Company has received confirmation of their data protection practices conformance with the requirements of this policy. Commercial Partners include all external providers of services to KM.Company and include proposed Commercial Partners. No Personal Data information can be transmitted to any vendor in any method unless the vendor has been pre-certified for the receipt of such information.
Personal Data Training
All new hires entering KM.Company who may have access to Personal Data are provided with introductory training regarding the provisions of this policy, a copy of this policy and implementing procedures for the department to which they are assigned. Employees in positions with regular ongoing access to Personal Data or those transferred into such positions are provided with training reinforcing this policy and procedures for the maintenance of Personal Data and shall receive annual training regarding the security and protection of Personal Data and company proprietary data
Personal Data Audit(s)
KM.Company conducts audits of Personal Data information maintained by KM.Company in conjunction with fiscal year closing activities to ensure that this policy remains strictly enforced and to ascertain the necessity for the continued retention of Personal Data information. Where the need no longer exists, Personal Data information will be destroyed in accordance with protocols for destruction of such records and logs maintained for the dates of destruction.
Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, KM.Company will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible and in no event be later than the commencement of the payroll period after which the breach was discovered.
Confirmation of Confidentiality
All company employees must maintain the confidentiality of Personal Data as well as company proprietary data to which they may have access and understand that that such Personal Data is to be restricted to only those with a business need to know. Employees with ongoing access to such data will sign acknowledgement reminders annually attesting to their understanding of this company requirement.
Violations of Personal Data Policies and Procedures
KM.Company views the protection of Personal Data to be of the utmost importance. Infractions of this policy or its procedures will result in disciplinary actions under KM.Company’s discipline policy and may include suspension or termination in the case of severe or repeat violations. Personal Data violations and disciplinary actions are incorporated in KM.Company’s Personal Data onboarding and refresher training to reinforce KM.Company’s continuing commitment to ensuring that this data is protected by the highest standards.
Cookies and Similar Technologies
We also use OneSignal for Push Notifications, Amplitude for better customer engagement, Qonversion for our subscription services, Firebase for managing our application infrastructure and FB SDK for integration of fakebook’s services in our application.
Analytics, Advertising, Anti-Cheat, and Anti-Fraud technologies in our Services. These technologies may utilize the same cookies or similar mechanisms as further described below.
This Data Protection Policy and our commitment to protecting the privacy of your personal data can result in changes to this Data Protection Policy. Please regularly review this Data Protection Policy to keep up to date with any changes.
Queries and Complaints
Any comments or queries on this policy should be directed to us using the following contact details.
KM.Company, Kharkiv, Ukraine
If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.